HACCP-based food defense systems

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Zarz¹dzanie i Finanse Journal of Management and Finance Vol. 13, No. 2/2015
Ma³gorzata Z. Wiœniewska*
Ma³gorzata Z. Wiœniewska
Introduction
The increasing complexity of food and feed production systems,
the development of food processing technologies, the changes in the consumer needs and in the way of living and consumption, the introduction
of novel foods and application of new food, as well as a food chain elongation may lead to new or unforeseen (emerging) risks for food safety. Not
without significance is increased globalisation of trade, people migration,
social inequalities, and turbulent political and social situation. All these
factors may have a negative impact on human and animal safety, on
health, environment and economy. From the perspective of Europe this
can be proved by the PERIAPT report, prepared by VWA (Voedsel en
Waren Autoriteit) – Food and Consumer Product Safety Authority
in Hague, that additionally shows that presently known risks may re-occur and increase in frequency, due to the expansion of the European internal market, altered human habits or changes in conditions and methods
of food production [Noteborn, Ooms, 2005, p. 4]. Moreover, during
the last few decades, the media, government leaders, scholars and national security analysts have all called attention to the potential threat presented by terrorism as a means for political instability. It is nothing new
that food became a weapon in the hands of terrorists. These issues are
of great general concern. Nowadays, according to the WHO – World
Health Organization, responsible governments, private companies, farmers, cannot ignore the possibility that terrorists, criminals and other antisocial groups may target the safety of food supply [WHO, 2008, p. 3]. Deliberate contamination of food and food chain, the food terrorism, as a real
danger, becomes a subject of care for many countries and different institutions worldwide. According to WHO food terrorism can be defined
as the act of threat of deliberate contamination of food for human consumption with chemical, biological or radio-nuclear agents for the purpose of causing injury or death to civilian populations and/or disrupting
* Assoc. Prof., Ph.D. Hab., Unit of Quality and Environmental Management, Department
of Enterprises Economics, Faculty of Management, University of Gdañsk, Armii Krajowej
101, 81-824 Sopot, [email protected]
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social, economic or political stability [WHO, 2008, p. 4]. What is interesting, as specialists assume, in the same time, there are some common week
points in today’s food safety supervision, like, i.a. [Emerging Risks..., 2005,
p. 10]:
– too much trust in existing assessment systems and protection measures,
– neglecting open transparent regulatory procedures,
– downplaying insider threats and consumer perception,
– underestimating interdependencies and complexities of food production systems,
– underestimating the ‘enforcement power’ of labelling and impact
of incremental changes,
– adopting a too reactive approach to risk management,
– bypassing a two-way communication and exchange of information between all stakeholders,
– less weight to criteria such as ethics and cultural aspects as compared
to technical issues,
– ignoring human factor and employees behaviour,
Underestimating the possibility of malicious contamination.
Considering the fact that the terrorists or other criminals rely on
a lack of preparedness [Olson, 2012, pp. 1–8] and that the weakest points
are usually the most vulnerable for negative, deliberate activity, it is required to implement the methods to protect against a potential or real attack. These proactive methods, based on the risk assessment, prepared
in accordance with the best practices in the world, as proposed by
the most experienced bodies and specialists, and implemented by food
producers seem to be the best solutions in the times of new threats, arising
from the unstable social, economical and political situation. What’s more,
the implementation of such methods by the manufacturer, food supplier,
is increasingly accented by food retailers, and, if evidenced in documents,
treated as a ticket on the shelf in the supermarket. Currently the most recommended proactive methods for food defense are CARVER+Shock,
HACCDP and TACCP. The first one has been already described by the author of the article [Wiœniewska, 2008, pp. 301–307], therefore the aim
of the paper is to present, to analyze and then, to compare the last of two
indicated, which respectively, are a kind of an extension, and of the modification of HACCP system. The research problem is to answer the question: What are the main differences and similarities between HACCDP,
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TACCP and HACCP? To resolve the problem the literature analysis,
the official documents and specifications review and analysis were used
as the research methods, as well as the methods of synthesis and conclusion. The first stage of the research plan is to recognize the character
of HACCDP method versus HACCP system, the second stage of the research is to recognize the specificity of TACCP versus HACCP, the third
stage of the research is to compare HACCDP with TACCP and based on
that – to find out the main differences and similarities between those three
approaches.
1. HACCDP as the extension of HACCP system
Since years HACCP system has been proven effective as a food safety
measure, referring to accidental hazards. It is a safety method that identifies and monitors hazards associated with food production before they
happen. It is the cornerstone of many businesses’ food safety plans, and,
according to European food law, is obligatory to be implemented by food
business operators. According to Article 5 of Regulation (EC) No 852/2004
of the European Parliament and of the Council on the hygiene of foodstuffs requires food business operators to put in place, implement and
maintain a permanent procedure based on Hazard Analysis and Critical
Control Point (HACCP) principles. HACCP is a preventive tool for
the production of safe food products and is based on technical and scientific principles applicable to every step of the food production chain, from
farm to table. HACCP was developed by Pillsbury Company, after a request from the National Aeronautics and Space Administration
in the 1960s, to ensure the safety of foods used in the American space program. It has changed and developed over the years. In 1991, the National
Advisory Committee on Microbiological Criteria for Foods published
a report determining the basic principles of the system as it is known today. After that it has been included, as the recommended system, in Codex Alimentarius, currently in the form of document CAC/RCP 1-1996,
rev. 4-2003.
As WHO convinces, the concepts and principles of HACCP commonly used for food safety risk assessment are also useful for addressing
food defense concerns [Short summary..., 2007, pp. 1–7]. In other hand, according to different food safety specialists, like P. Takhistov and C. Bryant
[Takhistov, Bryant, 2006, pp. 34–43], the tools used for food safety are not
designed for food defense, and are not addressed to intentional, malicious
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contamination. HACCP principles, as shows PAS 96:2014, have not been
routinely used to detect or mitigate deliberate attacks on a system or process. Such attacks may include deliberate contamination or fraud. Deliberate acts may have food safety implications but can harm organizations
in other ways, such as damaging business reputation or extorting money
[PAS 96:2014, 2014, p. iii]. Food defense therefore, at minimum, requires
the HACCP system to be extended or modified with regard to the new
threats and their consequences.
Having above in mind it seems to be interesting to present the modified version of HACCP in the form of HACCDP, described by Ch. Yoe and
J.G. Schwartz [Yoe, Schwartz, 2010], food safety specialists from Maryland University in United States. HACCDP is the synthesis of a HACCP
and covers the vulnerability assessment aspects, where vulnerability can
be defined as ease of an attack at the point, place of the food processing cycle. HACCDP, Hazard Analysis Critical Control and Defense Points, is
proposed as an extension of HACCP. It is recommended to be implemented rather in small or medium food companies than in bigger entities,
where system CARVER+Shock is useful as a more comprehensive.
HACCDP implementation stages are similar to those connected with
HACCP, as it is presented in the table 1.
Table 1. HACCDP and its steps
No.
HACCDP implementation steps
The reference to HACCP system
and to food defense plan
1
HACCP preliminary step 1
Assemble the HACCP team.
2
Describe the product.
3
Identify intended use.
4
Construct a flow diagram.
5
Conduct and on-site review
of the flow diagram.
6
HACCP principle 1
Conduct a hazard analysis.
7
HACCP principle 2
Determine the CCPs.
8
HACCP principle 3
Establish critical limits.
9
HACCP principle 4
Establish monitoring procedures.
10
HACCP principle 5
Establish corrective actions.
11
HACCP principle 6
Establish verification procedures.
No.
HACCDP implementation steps
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The reference to HACCP system
and to food defense plan
12
HACCP principle 7
Establish record-keeping and
documentation procedures.
13
Food Defense Plan
Determine CDPs in your process.
14
Food Defense Plan
Devise food defense mitigations.
15
Food Defense Plan
Implement, test, assess and
maintain the defense mitigations.
Explanation: CCP – Critical Control Point; CDP – Critical Defense Point
Source: Own elaboration based on: [Yoe, Schwartz, 2010].
As can be seen, similarly to HACCP system, the core element
of HACCDP is food defense plan. It can be defined as the plan used to reduce the risk of intentional contamination [FSIS Directive, 2011, p. 2]. The
USDA’s Food Safety and Inspection Service defines a food defense plan
as the document that sets out control measures developed by an establishment to prevent intentional adulteration of product. A food defense plan
should be developed, written, implemented, tested, assessed, and maintained if it is to be functional [USDA, 2006], what is additionally presented
in the table 2.
Table 2. Food defense plan preparation, as the element of HACCDP
Steps in food defense
plan development
Description
Appoint Food Defense
Coordinator
The coordinator will lead the team in developing,
implementing and maintaining HACCDP plan
Develop the Plan
The plan should include the following elements:
process vulnerability, facility security, supply chain
integrity, emergency response, like recall, disposal,
recovery and communication
Implement the Plan
The plan is implemented when the defense
measures identified are in place and being used
as intended. Implementation steps will include all
required approvals of the defense measures,
budgeting for the measures, installing the measures
and training personnel in the proper use and
execution of the measures.
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Steps in food defense
plan development
Description
Test the Plan
Plans can be tested in different ways. Simulations,
drills, tabletop exercises, mock incidents and
recalls, post-event evaluation and lessons learned,
evacuation procedures and continuity of operations
plans may be used.
Assess the Plan
The plan must be kept up to date and assesses on
a regular basis. Employee turnover or changes
in suppliers, the production process, contracted
services and production lines require reviewing,
updating and revising the plan. Occasionally, new
defense measures may be added to the food
defense plan.
Maintain the Plan
Maintenance activities may include purchasing
new or replacement materials or equipment
designed for food defense, making repairs or
(re)training employees.
Source: Own elaboration based on: [Yoe, Schwartz, 2010].
As can be seen HACCDP is a kind of an overlay of the HACCP system.
The similarities between the systems which can be observed are very clear,
what provides an opportunity to build up a successive approach against
intentional contamination. However there is one condition of the success –
the ability to differentiate CCPs from CDPs and to identify the consequences of the attack, which are more severe and more difficult to predict
than while assessing the probability of accidental contamination.
2. TACCP as the modification of HACCP system
TACCP (Threat Analysis and Critical Control Point) system had been
presented and described for the first time in 2008 in Publicly Available
Specification (PAS). The specification was developed by the Centre for
the Protection of National Infrastructure (CPNI) in collaboration with The
British Standards Institution (BSI). This original edition made use of preventative strategies within the World Health Organisation guidance on
the “Terrorist Threat to Food”, mentioned before in the paper. The revised
edition of PAS 96 has been published in 2010 and next, in 2014.
The purpose of TACCP is to enable proportionate control procedures
to be implemented so as to reduce the likelihood (chance) of malicious attack and to reduce the consequences (impact) of an attack. It is worth not-
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ing that the scope of the 2014 version is broader than the scope of the specification of PAS:2010. PAS:2010 provided guidance to food businesses on
approaches to the protection of their business from all forms of malicious
attack including ideologically motivated attack and to procedures to mitigate and minimize the impact of such an attack, whereas PAS 2014 provides guidance on the avoidance and mitigation of threats to food and
food supply, additionally including those referring to EMA – Economically Motivated Adulteration (EMA) – so-called food fraud. According to
PAS:2014, food fraud is committed when food is deliberately placed on
the market, for financial gain, with the intention of deceiving the consumer, and can be understood as [PAS:2014, 2014, p. 1]:
– the sale of food which is unfit and potentially harmful, such as: recycling of animal by-products back into the food chain, packing and selling of beef and poultry with an unknown origin, knowingly selling
goods which are past their “use by” date,
– the deliberate misdescription of food, such as: products substituted
with a cheaper alternative, for example, farmed salmon sold as wild,
and Basmati rice adulterated with cheaper varieties, making false
statements about the source of ingredients, i.e. their geographic, plant
or animal origin.
Food fraud may also involve the sale of meat from animals that have
been stolen and/or illegally slaughtered, as well as wild game animals like
deer that may have been poached [PAS:2014, 2014, p. 2].
Threat Assessment Critical Control Point is the systematic management of risk through the evaluation of threats, identification of vulnerabilities, and implementation of controls to materials and products, purchasing, processes, premises, distribution networks and business systems by
a knowledgeable and trusted team with the authority to implement
changes to procedures, whereas the threat is defined as something that
can cause loss or harm which arises from the ill-intent of people
[PAS:2014, 2014, p. 3].
TACCP, according to PAS 96:2014 aims, i.a., to reduce the likelihood
(chance) of a deliberate attack, to reduce the consequences (impact) of an
attack and to protect organizational reputation. It helps to reassure customers, press and the public that proportionate steps are in place to protect food. It also satisfies international expectations and support the work
of trading partners and demonstrates that reasonable precautions are
taken and due diligence is exercised in protecting food. It is helpful
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in identifying specific threats to the company’s business, in assessing the
likelihood of an attack by considering the motivation of the prospective
attacker, the vulnerability of the process, the opportunity and the capability they have of carrying out the attack. The company, while implementing TACCP system, has the opportunity to assess the potential impact by
considering the consequences of a successful attack, to judge the priority
to be given to different threats by comparing their likelihood and impact.
What is important, TACCP cannot stop individuals or organizations
claiming that they have contaminated food, but it can help judge whether
that claim is likely to be true. Any such claim, if judged to be credible, and
any actual incident should be treated as a crisis [PAS:2014, 2014, p. 9].
In total TACCP system implementation is divided into 16 steps, what
is presented in the table 3.
Table 3. TACCP implementation steps
No.
TACCP
implementation steps
Description
1
Form TACCP system
TACCP could include individuals with
the following expertise: security, human
resources, food technology, process
engineering, production and operations,
purchasing and supply, distribution,
communications, commercial/marketing.
2
Assess new information There is a need to evaluate all new information
which has come to its attention.
3
Identify and assess
threats to organization
There is a need to identify individuals and/or
groups which may be a threat to
the organization and assess their motivation,
capability and determination.
4
Identify and assess
threats to operation
groups which may be a threat to the specific
operation (e.g. premises, factory, and site).
5
Select product
There is a need to select a product which is
representative of a particular process.
6
Identify and assess
threats to product
groups that may want to target the specific
product.
No.
TACCP
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Description
7
Devise flow chart
There is a need to draw a process flow chart for
of product supply chain the product from, but not limited by, ‘farm to
fork’ including, for example, domestic
preparation. The whole flowchart should be
visible at one time. Particular attention should
be paid to less transparent parts of the supply
chain which might merit a subsidiary chart.
8
Identify key staff and
vulnerable points
From an examination of each step
of the process there is a need to identify
the vulnerable points where an attacker might
hope for success and the people who would
have access.
9
Consider impact
of threats identified
There is a need to identify possible threats
appropriate to the product at each step and
assess the impact that the process may have
in mitigating the threats.
10 Identify which supply
points are most critical
There is a need to select the points
in the process where the threat would have
the most effect, and where they might best be
detected.
11 Determine if control
procedures will detect
the threat
There is a need to assess the likelihood
of routine control procedures detecting such
a threat.
12 Likehood versus
impact – identify
priority
There is a need to score the likelihood
of the threat happening, score the impact it
would have, and chart the results to show
the priority it should be given, and revise if this
risk assessment seems wrong.
13 Identify who could
carry it out?
where the priority is high, identify who has
unsupervised access to the product or process
and whether they are trustworthy, and if that
trust can be justified.
14 Decide and implement
necessary controls
There is a need to identify, record
confidentially, agree and implement
proportionate preventative action (critical
controls). The TACCP team should have
confidential reporting and recording procedure
that allows management action on decisions
but does not expose weaknesses to those
without a need to know.
15 Review and revise
There is a need to determine the review and
revise arrangements for the TACCP evaluation.
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No.
TACCP
16 Monitor horizon scans
and emerging risks
Description
There is a need to maintain a routine watch
of official and industry publications which give
an early warning of changes that may become
new threats or change the priority of existing
threats, including more local issues as they
develop.
Source: Own elaboration based on: [PAS:2014, 2014, pp. 10–11].
3. HACCDP versus TACCP
HACCDP and TACCP systems, as HACCP-based have several aspects very close to HACCP system. What’s more there are also many areas
which evidently make those two systems very similar to each other, however the systems are not identical.
First of all HACCDP had been presented by scientists, food specialist,
who described it in the form of the article, whereas TACCP system is
the result of the long term cooperation of different organizations that were
involved in the development of PAS:2008, PAS:2010 and then PAS:2014.
Among them are, i.a.: Agrico UK Limited, Bakkavor, Cargill, Department
for Environment, Food & Rural Affairs, Food and Drink Federation (FDF),
Food Standards Agency (FSA), GIST Limited, Global Food Security Programme, Heineken UK, Hilton Food Group plc, J Sainsbury plc, Leatherhead Food Research, McDonald’s Europe, Raspberry Blonde, SSAFE and
Tesco plc. Next, for the fact that TACCP is presented within the framework of Publically Available Specification under the auspices of BSI, it has
more formal character, as well as more standardized. It is worth to say that
PAS is not to be regarded as a British Standard. It will be withdrawn upon
publication of its content in, or as, a British Standard. Nevertheless both
approaches, as proposed by their authors, are, so far, voluntary, however
recommended to be applied by different food processors. What is interesting, HACCDP is better to be used for smaller and medium organizations,
whereas TACCP can be implemented by all food processors, regardless
of the size. As it was mentioned before, HACCDP is an extension
of HACCP system, and TACCP is rather a kind of HACCP modification,
including the specificity of food defense. It can be observed in the meaning and in the scopes of the subsequent implementation steps of TACCP,
where, i.a. HACCP principles have been transformed into TACCP principles. Another difference is the scope of the threats taken into account.
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HACCDP systems covers the threats connected with food terrorism, including food sabotage, whereas TACCP system distinguishes several
types of threats, connected with EMA (Economically Motivated Adulteration), with malicious contamination (in the sense of food terrorism and
sabotage), extortion, espionage, counterfeiting and cyber crime.
Very similar is the structure of the both approaches. They are based
on seven HACCP principles and on twelve implementation steps, as indicated originally in Codex Alimentarius for HACCP purposes. As can be
observed, in both systems very important is food defense plan, however
the information about that aspect in the context of HACCDP is rather simplified and general, unlike TACCP system, in which the plan has been described in great details. In very detailed form are also presented the rules
of the risk scoring matrix applicable in TACCP system implementation,
where the threat is categorized into five groups connected with the particular risks, like: very high risk, high risk, moderate risk, low risk and negligible risk, what depends on the scoring system addressed to likelihood
(very high chance, high chance, some chance, may happen chance, unlikely to happen chance) and impact of the particular threat (catastrophic,
major, significant, some, minor). In TACCP system, what can’t be observed in HACCDP described by Ch. Yoe and J.G. Schwartz [Yoe,
Schwartz, 2010], very helpful is the presentation of the critical controls,
which can be recognized as the prerequisites conditions of TACCP. These
conditions refer, i.a. to: access to premises, to vehicles, to access to people,
to screening of visitors, to detecting tempering, to pre-employment checks,
to on-going personnel security, as well as to the end of contract agreements, treated as the possible, vulnerable places, points of the threats for
the company.
To sum up, the main differences and similarities between the described systems are illustrated in the table 4.
Table 4. HACCDP, TACCP and HACCP – comparison
Aspect
Publication body
HACCDP
Scientists, food
safety specialists
TACCP
BSI
HACCP
Codex
Alimentarius
Commission
FAO/WHO
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Aspect
HACCDP
TACCP
HACCP
Character
Informal, not
standardized
Formal,
standardized
Formal,
standardized
(mainly
as published, i.e.
in the form of ISO
22000)
Implementation
Voluntary
Voluntary
Obligatory
in most countries
Interested
party/addressee
Small and
medium food
companies
All food
processors
All food
processors
HACCDP/TACCP Extension
versus HACCP
Modification
–
Object
of the interest
Threat
Threat
Hazard
Scope
Intentional
contamination,
without
specifying types
of threat; focused
on food terrorism,
including
sabotage
Intentional
contamination,
with specifying
types of threat
into EMA,
malicious
contamination,
extortion,
espionage,
counterfeiting,
cyber crime
Accidental
Structure
HACCP-based
HACCP-based
7 principles
Steps
15 steps in total;
of the implementa Codex
tion
Alimentarius
implementation
steps-based
16 steps in total;
Codex
Alimentarius
implementation
steps-based
12 steps in total,
according to
Codex
Alimentarius
Defense plan
General
HACCP-based
Precise
HACCP-based
HACCP plan
Examples, case
studies
General
Precise
General
in the form
of General
Principles of Food
Hygiene
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Aspect
HACCDP
TACCP
HACCP
Risk scoring
matrix
Not included
Included
Included
(Example:
Guidelines for
Risk Analysis
of Foodborne
Antimicrobial
Resistance
CAC/GL 77- 2011)
Critical controls
Not included
Included
Included
in the form
of General
Principles of Food
Hygiene
Source: Own elaboration.
Conclusion
As it has been proved and described in the paper, deliberate contamination of food requires new methods and new approaches to be implemented by food processors. All presented and mentioned systems (including CARVER+Shock) are HACCP-based and by that fact they seem to
be familiar for producers and ease to be integrated with existing practices
to protect the safety of the food product. Of course, one can conclude that
they involve the specific aspects connected with food defense area, particularly, a requirement to develope a food defense plan, that may be prepared with regard to the assumption of HACCP plan, and to assess
the risks connected with a particular threat. Depending on the current experience, on the personnel knowledge, on the identified, potential or real,
and observed hazards and threats, on the size of the company, food producer can choose the best solution for the company, to satisfy the needs
of individual and of the institutional customers in terms of food defense,
which can be defined as putting measures in place that reduce the chances
of the food supply from becoming intentionally contaminated using a variety of chemicals, biological agents or other harmful substances by people. The food producers has to be conscious that these agents could include materials that are not naturally-occurring or substances not
routinely tested for in food products. Very important is to be aware that
a terrorist’s goal might be to kill people, disrupt the economy, or ruin
the business and its reputation. What is crucial, intentional acts generally
occur infrequently and can be difficult to detect, and are very hard to pre-
118
dict. Therefore, there is not only a need to implement the methods, like
those described in the article, but also to encourage to exchange the experience among the companies, to compare the best practices, to allow food
processors to be more and better prepared in case of the attack. In turbulent times it seems to be an obligation.
References
1. Emerging Risks Identification in Food and Feed for Human Health (2005),
VWA – Food and Consumer Product Safety Authority, Directorate
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HACCP-based food defense systems (Summary)
The aim of this paper is to present and analyze systems for food defense,
based on the assumptions of the HACCP system, and then to compare them to
each other. In the first part HACCDP has been presented and it the second –
TACCP system. During the comparative analysis the interest has been focused on
factors such as: the body publishing the assumptions of the system, the character
of the system, obligatory issues, the addressee of the system, the type of system,
the object of interest, scope, structure of the system, the steps of implementation,
food defense plan, relevant examples, a reference to the risk assessment matrix,
and control areas. The similarities and differences between the systems were also
highlighted. In conclusion, it was pointed out that the choice of the presented approaches depends, i.a. on the previous experience of the company, on its size and
on the needs of customers. It was stated that the cooperation between the food
companies is required in the area of knowledge exchange and comparison
of the best practices for food defense.
Keywords
food defense, intentional contamination, HACCDP, TACCP, HACCP systems

HACCP-based food defense systems

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