Documenti di Didattica
Documenti di Professioni
Documenti di Cultura
2/2015
Magorzata Z. Winiewska*
Magorzata Z. Winiewska
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 Gdask, Armii Krajowej
101, 81-824 Sopot, m.wisniewska@ug.edu.pl
106
Magorzata Z. Winiewska
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 todays 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. 18] 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. Whats 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 [Winiewska, 2008, pp. 301307], 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,
107
108
Magorzata Z. Winiewska
HACCP principle 1
HACCP principle 2
HACCP principle 3
HACCP principle 4
10
HACCP principle 5
11
HACCP principle 6
109
12
HACCP principle 7
13
14
15
Description
110
Steps in food defense
plan development
Magorzata Z. Winiewska
Description
111
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
112
Magorzata Z. Winiewska
TACCP
implementation steps
Description
Select product
TACCP
implementation steps
113
Description
Consider impact
of threats identified
11 Determine if control
procedures will detect
the threat
12 Likehood versus
impact identify
priority
114
No.
Magorzata Z. Winiewska
TACCP
implementation steps
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.
115
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 cant 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
116
Magorzata Z. Winiewska
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
117
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
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 terrorists 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
Magorzata Z. Winiewska
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
of Research and Risk Assessment, The Hague.
2. FSIS Directive, 5420.1, Revision 7, 6/27/11, http://www.fsis.usda.gov/
wps/wcm/connect/09d861e7-affa-476d-ae32-5dfde9e23523/5420.1.pdf?
MOD=AJPERES, accessed 10.10.2014.
3. Noteborn H.P.J.M., Ooms B.W. (ed.) (2005), Emerging Risks Identification in Food and Feed for Human Health, VWA Food and Consumer
Product Safety Authority, Directorate of Research and Risk Assessment, The Hague.
4. Olson D. (2012), Agroterrorism Threats to Americas Economy and Food
Supply, FBI Law Enforcement Bulletin February.
5. Short summary on food defense (2007), IUFoST Scientific Information
Bulletin September, http://www.foodlawment.hu/downloads/iuf_
sib_food_defense.pdf, accessed 10.10.2014.
6. Takhistov P., Bryant C. (2006), Protecting the Food Supply, Food Technology No. 60(7).
7. USDA (2006), PBIS Profile Extension Instructions on Food Defense Plans
for Meat and Poultry Establishments, Food Safety Inspection Service,
20 April 2006. www.fsis.usda.gov/OPPDE/rdad/FSISNotices/28-06.pdf,
accessed 10.10.2014.
8. WHO (2008), Terrorist Threats to Food: Guidance for Establishing and
Strengthening Prevention and Response Systems. Food Safety Issues Series,
Geneva.
9. Winiewska M. (2008), HACCP to za mao, in: M. Winiewska, E. Malinowska (ed.), Jako, bezpieczestwo, ekologia w sektorze rolno-spoywczym. Kierunki rozwoju, FRUG, Sopot.
10. Yoe Ch., Schwartz J.G. (2010), Incorporating Defense into HACCP, Food
Safety Magazine August/September, http://www.foodsafetymagazi
ne.com/magazine-archive1/augustseptember-2010/incorporating-defense-into-haccp, accessed 10.10.2014.
119
Keywords
food defense, intentional contamination, HACCDP, TACCP, HACCP systems