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How To Do a Vulnerability Assessment for Food Fraud

Updated 30th December 2022

What is a vulnerability assessment?

 

A vulnerability assessment is a risk-assessment-style evaluation of a food’s vulnerability to food fraud.

A food fraud vulnerability assessment is a documented assessment that identifies vulnerabilities to food fraud and explains how those vulnerabilities were identified.

Vulnerability assessments are also done to assess the threat of a malicious attack on food.  Malicious attacks include attacks conducted for extortion, ideological reasons or terrorism. We call these issues of food defense. To learn more about vulnerability assessments for food defense (intentional adulteration), click here.

Why ‘vulnerability’ and not ‘risk’? 

 

  • A risk is something that has occurred before and will occur again. A risk can be quantified using existing data.
  • A vulnerability is a weakness that can be exploited.  A vulnerability can lead to a risk.

Food fraud is difficult to estimate and quantify, so we use the word vulnerability rather than risk.

Why do a vulnerability assessment?

 

  1. To protect consumers: Food that is vulnerable to food fraud presents significant risks to consumers.  Food that is adulterated or diluted   [Read more…]

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Acronym Decoder

BRC: British Retail Consortium.  A group of British companies that publish guidance and standards for food manufacturers, including a food safety standard that is also commonly referred to as BRC.

CoOL or COOL: Country of Origin Labelling.

EMA: Economically motivated adulteration or substitution. EMA is a subset of food fraud and is defined as the fraudulent, intentional substitution or addition of a substance, or dilution of a substance for the purposes of economic gain.  Non-EMA food fraud includes black market importation and trading of food and alcoholic beverages for the purposes of avoiding duty and taxes.

DEFRA: The Department for Environment, Food and Rural Affairs, a United Kingdom government department responsible for food production and standards as well as environmental and agricultural responsibilities.

FDA:  Food and Drugs Administration.  The FDA is the name of a regulatory body in a number of countries, including USA, Philippines and India.

FSA: Food Standards Agency, a United Kingdom government regulatory body.

FSMA: Sometimes pronounced ‘Fizzmah’.  Stands for Food Safety Modernisation Act (United States of America).

FSSC 22000: A food safety management system standard similar to ISO 22000 but with extra requirements incorporated to meet the requirements of a GFSI standard.

GFSI: Global Food Safety Initiative.  The GFSI is a group of food companies whose mission is to harmonize, strengthen, and improve food safety management systems around the globe.  The GFSI provides direction and approval to organizations that create food safety management systems, so a GFSI-approved food safety standard is one that represents international best practice.  Well known GFSI standards include BRC, FSSC 22000 and SQF.

GMO: Genetically Modified Organism.

HACCP:  HACCP is a set of principles designed to control and prevent food safety risks during food production.  The principles of HACCP are codified (written down) by the Food and Agriculture Organization of the United Nations (FAO).  Download the 2020 revision of the HACCP Code here.

HARCP: Hazard Analysis Risk-based Preventive Control.  HARCP = food safety as legislated by the United States.  This acronymn being used by some in the USA when talking about the requirements of the recently enacted Food Safety Modernisation Act (FSMA) in that country.  HARCP is claimed to differ from HACCP by including requirements for preventive controls.  Read more about HARCP here.

IA: Intentional Adulteration.  Within the US Food Safety Modernisation Act (FSMA), Intentional Adulteration specifically refers to malicious adulteration that is intended to cause widescale harm.  Learn more about intentional adulteration here.

ISO 22000:  ISO is the International Organization for Standardization.  They have thousands of standards across many different businesses, products and systems.  ISO 22000 is the ISO standard for food safety management systems.  Like other major food safety management systems it is based on the principles of HACCP.

NSF:  a pseudo-government organization head-quartered in the United States that is active in the area of food safety and sanitation.

SQF:  Safe Quality Food Institute.  The Safe Quality Food Institute owns and publishes a group of food safety standards also known as SQF that is a GFSI – approved standard.

USP: United States Pharmacopeial Convention.  USP is a non-profit organization that creates identity and purity standards for food ingredients and food chemicals, as well as for medical drugs.

TACCP: Threat Assessment Critical Control Point.  TACCP = prevention of malicious threats to food.

VACCP: Vulnerability Assessment Critical Control Point.  VACCP = food fraud prevention.  Learn more about TACCP and VACCP here.

Learn about Vulnerability Assessments, what they are and how to do them, here.

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HACCP, VACCP and TACCP

  1. HACCP (Hazard Analysis Critical Control Point)  Pronounced ‘hassup’.  HACCP = keeping food safe from accidental and natural risks to food safety.
  2. VACCP (Vulnerability Assessment Critical Control Point) Pronounced ‘vassup’.  VACCP = prevention of economically motivated food fraud.
  3. TACCP (Threat Assessment Critical Control Point) Pronounced ‘tassup’.  TACCP = prevention of malicious threats to food, such as sabotage, extortion or terrorism.  This type of malicious threat is also referred to as Intentional Adulteration within the US Food Safety Modernization Act.  Outside of the US, TACCP is more often called ‘food defense’.

HACCP

  • HACCP is a set of principles designed to control and prevent food safety risks during food production.
  • HACCP is not enforced or regulated by any single organization.
  • The ideas of HACCP form the basis of every food safety management system standard that is in use today, including GFSI food safety standards.
  • The principles of HACCP are codified (written down) by the Food and Agriculture Organization of the United Nations (FAO), in a set of documents called the Codex Alimentarius , a latin phrase which translates to “Book of Food”.
  • FAO’s General Principles of Food Hygiene CXC 1-1969 contains the HACCP principles (sometimes called HACCP Codex).  Download the 2020 revision of the HACCP Code here: http://www.fao.org/fao-who-codexalimentarius/codex-texts/codes-of-practice/ (click the green check/tick mark on the right side of the page to download).

VACCP and TACCP

  • VACCP and TACCP are terms that emerged during the 2010s as standards agencies, government regulators and industry groups started considering methods to prevent food fraud and malicious tampering.
  • VACCP is for food fraud.
  • TACCP is for food defense.
  • The acronymns VACCP and TACCP are designed to leverage the food industry’s familiarity with HACCP.  However, the critical control ‘points’ in a VACCP and TACCP plan are nothing like the ‘critical control points’ in a HACCP plan.
  • The control points in a HACCP plan are operational steps in a food manufacturing process.  The points are connected to processes over which the food manufacturer can exercise direct control.
  • For deliberate tampering (food fraud and food defense) the controls do not fit onto a linear set of processes, they do not fit the definition of ‘critical control points’ in HACCP.
  • The terms VACCP and TACCP are falling out of favor within the food safety industry.  They are not referenced specifically within any of the GFSI food safety standards, nor within the USA’s FSMA.
  • Instead of ‘”VACCP” and “TACCP”, it is much better to say “Vulnerabilities to food fraud” or “threats of malicious tampering (=food defense)”.

More acronyms demystified here.

Take a free short course on food fraud here.

food safety food fraud

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Food Fraud Online Training Course

Food fraud requirements of BRC, SQF, FSSC and other food safety standards

How to meet the food fraud prevention requirements of major food safety standards

This course will make audit preparation a breeze.  It contains step-by-step instructions, worked examples and downloadable templates to help you meet the food fraud requirements of all major food safety standards.

sqf edition 8 food fraud

 

  • Learn about food fraud and how it can put your brand and your consumers at risk
  • Hear food fraud stories that will surprise you and learn ways to protect your business
  • Get step-by-step instructions for food fraud vulnerability assessments and food fraud mitigation plans, using real life examples
  • Download templates for vulnerability assessments, mitigation plans and food fraud prevention procedures
  • Proceed at your own pace; skip forward and back through the lessons, start and stop at your convenience*

The content is a mix of written words and short video clips, plus downloadable worked examples.

Ask the trainer a question at any time.

What’s included?

  • Food Fraud Commonly Affected Foods Ebook
  • Food Fraud Vulnerability Assessment template
  • Food Fraud Prevention Procedure template
  • Food Fraud Mitigation Plan template
  • Vulnerability assessment document – worked example
  • Raw Material Specification template
  • Food Fraud Team Job Descriptions
  • Top tips for audit preparation
  • Special 40% discount code for use on www.foodfraudadvisors.com
  • Optional exam and Certificate of Competency

Duration: 3.5 hours

Visit our training academy today

* course is available for 6 months after commencement

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What is the Difference Between Food Fraud and Food Defense?

 

Food Fraud

 A crime done for financial gain

Food Defense

 Protecting food from malicious adulteration, such as acts of terrorism or extortion

The difference between food fraud and food defense is that food fraud is done to make money, while food defense relates to acts that are done to create harm.  Food fraud perpetrators do not seek to cause harm, they seek to increase profits or otherwise benefit financially, so we say food fraud is economically motivated.  Food defense attacks are done to cause harm to consumers and companies.

 

Intentional Adulteration

 … happens when food is contaminated for the purpose of causing harm to consumers

Food Defence

 Protecting food from malicious adulteration, such as acts of terrorism or extortion

Intentional adulteration is the act of contaminating a food product with the intention of causing harm to the people who eat the food.  Food defense is a broader term that includes protection against adulteration of food, but can also extend to protection of equipment, assets and workers in food businesses.