Dr. Ramakrishnan Nara Technical Program Director Perry Johnson Registrars (PJR, USA)

Dr.
Ramakrishnan Nara
Technical Program Director
Perry Johnson Registrars (PJR, USA)
Objectives
 Introduce you to emerging concepts
 Assist you in developing TACCP and

VACCP
Food Risk Matrix
Source: Adapted from: Spink (2006), The Counterfeit Food and Beverage Threat,
Association of Food and Drug Officials (AFDO), Annual Meeting 2006
Motivation
Food Quality Food Fraud Economic gain
Harm
Public Health,
Food Safety Food Defense
Economic or
Terror
Un-
Intentional
intentional
HACCP, VACCP &TACCP- Acronyms
 HACCP (Hazard Analysis Critical Control
Point)
 TACCP (Threat Assessment Critical Control

Point System), and/or
 VACCP (Vulnerability Assessment Critical

Control Point System)
HACCP- Hazard Analysis Critical
Control Point System
 Logical and scientific approach to food safety
 Procedures to prevent customer from food born illness
 Proactive rather than reactive
 Science based; risk based
 Step wise process:

 Identifies hazards
 Installs preventative measures to eliminate or reduce
hazards in foods
Food Chain
 Crop Producers
 Feed Producers
 Primary Food Producers
 Food Manufacturers
 Secondary Food Manufacturers
 Wholesalers
 Retailers
 Consumers
TACCP
Threat Assessment Critical

Control Point
TACCP- Threat Assessment Critical
Control Point
TACCP aims to:
 Reduce the likelihood (chance) and consequence
(impact) of a deliberate attack;
 Protect organizational reputation;
 Reassure customers and the public that

proportionate steps are in place to protect food; and,
 Demonstrate that reasonable precautions are taken

and due diligence is exercised in protecting food.
Types of Threats
 Economically Motivated Adulteration

(EMA)
 Malicious Contamination
 Extortion
 Espionage
 Counterfeiting
 Cyber crime
Examples of Threat-Economically
Motivated Adulteration (EMA)
 In 2013, a food factory in Asia was labelling cooking
oil as peanut and olive when it contained none of
these oils.
 A 2013 report suggested that one third of retail fish
in the USA was mislabeled. Examples, tilapia sold as
red snapper and tilefish sold as halibut.
 In 2010, some producers of buffalo mozzarella in
Italy were accused of adulteration of their product
with cow’s milk.
Ref: http://www.foodnavigator asia.com/Markets/False-foodlabels- on-82-impure-
oils-in-China;
http://oceana.org/sites/default/files/National_Seafood_Fraud_Testing_Results_Hig
hlights_FINAL.pdf.
Examples of Malicious contamination
 In 2005, a major British bakery reported that several

customers had found glass fragments and sewing
needles inside the wrapper of loaves.
 In 2013, a major soft drinks supplier was forced to
withdraw product from a key market when it was
sent a bottle which had had its contents replaced
with mineral acid. The attackers included a note
indicating that more would be distributed to the
public if the company did not comply with their
demands.
Examples of Extortion
 In 1990, a former police officer was convicted

of extortion after contaminating baby food
with glass and demanding money from the
multi-national manufacturer.
 In 2008, a man was jailed in Britain after
being convicted of threatening to bomb a
major supermarket and contaminate its
products.
Examples of Espionage
 One business consultancy uses the theft of

the intellectual property of a fictitious
innovative snack product as an example of
commercial espionage.
 In July 2014, Reuters reported that a woman
was charged in the USA with attempting to
steal patented U.S. seed technology as part of
a plot to smuggle types of specialized corn for
use in China.
The TACCP Process
It is a 15 step process as indicated below.
1. Assess new information
2. Identify and assess threats to organization
3. Identify and assess threats to operation
4. Select product
5. Identify and assess threats to product
6. Devise flow chart of product supply chain
7. Identify key staff and vulnerability chain
8. Consider impacts of threats identified
The TACCP Process-contd.
9. Identify which supply points are more critical

10. Determine if control procedures would
detect the threat
11. Likelihood Vs Impact = Priority
12. Identify who could carry out
13. Decide and implement necessary controls
14. Review and revise
15. Monitor horizon scans and emerging risks.
Assessment of Threats- Risk Assessment
Scoring
Likelihood Score Impact
Very high chance 5 Catastrophic
High chance 4 Major
Some chance 3 Significant
May happen 2 Some
Unlikely to happen 1 Minor
Ref: PAS 96:2014

Critical Controls- Access Control
. Access to premises/vehicles Relevant
Proportionate
1 Access to people on business only
2 Vehicle parking outside perimeter
3 Premises zoned to restrict access to those with a
business need
4 Visible and comprehensive perimeter fencing
5 Perimeter alarm system
6 CCTV monitoring/recording of perimeter
vulnerabilities
7 Monitored access points
8 Scheduled deliveries
9 Documentation checked before admittance
10 Missed deliveries investigated
Critical Controls- Access Control contd.
. Access to people/visitors/other aspects Relevant
Proportionate
11 Chip & PIN access control
12 Changing facilities, separate personal clothing from

work wear
13 By appointment only
14 Proof of identity required
15 Accompanied throughout
16 Positive identification of staff and visitors
17 CCTV monitoring/recording of sensitive areas
18 Limitations on access to mains services
19 BS ISO/IEC 27000 compliant 1cyber security
Ref: PAS 96:2014

Critical Controls- Tamper detection
. Detecting Tampering Relevant
Proportionate
1 Numbered seals on bulk storage silos
2 Numbered seals on stores of labels and labelled packs
3 Effective seals on retail packs
4 Numbered seals on hazardous materials
5 Close stock control of key materials
6 Recording of seal numbers on delivery vehicles
7 Secure usernames and passwords for electronic access
8 Incursion reporting by cyber systems
Ref: PAS 96: 2014

Critical Controls- Personnel Security
. Pre-employment check/on-going checks/End of Relevant
contract arrangements Proportionate
1 Proof of identity
2 Proof of qualifications
3 More sensitive roles identified with appropriate

recruitment
4 Staff in critical roles motivated and monitored
5 Whistleblowing arrangements
6 Temporary staff supervised
7 Access and ID cards and keys recovered
8 Computer accounts closed or suspended
9 Termination interview assesses security implications

Six Steps of Vulnerability Assessment (VA)
1. Conduct a risk analysis. Evaluate any significant risks and
exposures.
2. Determine the critical points for controlling the security.
3. Determine procedures and technical means of verifying each
critical point to control security.
4. Determine the corrective measures to be implemented when
the surveillance reveals that a critical point for security control
is no longer under control.
5.Apply verification procedures in order to confirm that the
system is functioning effectively.
6. Build up a file which includes all procedures and reports
concerning these provisions and their implementation.
VA and Economically Motivated
Adulteration (EMA)
Questions which the TACCP team could ask include:
• Are low cost substitute materials available?
• Have there been significant material cost increases?
• Has pressure increased on suppliers’ trading margins?
• Do you trust your suppliers’ managers, and their
suppliers’ managers?
• Do key suppliers use personnel security practices?
• Do suppliers think that we monitor their operation
and analyze their products?
VA and Economically Motivated
Adulteration (EMA)-contd.
• Which suppliers are not routinely audited?
• Are we supplied through remote, obscure chains?
• Are major materials becoming less available (e.g.
from crop failure) or alternatives plentiful (e.g. from
overproduction)?
• Have there been unexpected increases or decreases in
demand?
• Are we aware of shortcuts to the process which could
affect us?
• Are accreditation records, certificates of conformance
and analyzes reports independent
Q &A
Questions?

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Dr.

 Introduce you to emerging concepts

 Assist you in developing TACCP and

 TACCP (Threat Assessment Critical Control

 VACCP (Vulnerability Assessment Critical

 Procedures to prevent customer from food born illness

 Proactive rather than reactive

 Science based; risk based

 Step wise process:

Threat Assessment Critical

 Protect organizational reputation;

 Reassure customers and the public that

 Demonstrate that reasonable precautions are taken

 Economically Motivated Adulteration

 In 2005, a major British bakery reported that several

 In 1990, a former police officer was convicted

 One business consultancy uses the theft of

9. Identify which supply points are more critical

Very high chance 5 Catastrophic

High chance 4 Major

Some chance 3 Significant

May happen 2 Some

Unlikely to happen 1 Minor

Ref: PAS 96:2014

11 Chip & PIN access control

12 Changing facilities, separate personal clothing from

14 Proof of identity required

16 Positive identification of staff and visitors

17 CCTV monitoring/recording of sensitive areas

18 Limitations on access to mains services

19 BS ISO/IEC 27000 compliant 1cyber security

Ref: PAS 96:2014

1 Numbered seals on bulk storage silos

2 Numbered seals on stores of labels and labelled packs

3 Effective seals on retail packs

4 Numbered seals on hazardous materials

5 Close stock control of key materials

6 Recording of seal numbers on delivery vehicles

7 Secure usernames and passwords for electronic access

8 Incursion reporting by cyber systems

Ref: PAS 96: 2014

3 More sensitive roles identified with appropriate

6 Temporary staff supervised

7 Access and ID cards and keys recovered

8 Computer accounts closed or suspended

9 Termination interview assesses security implications

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