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Post by cazyncymru on Mar 30, 2015 10:13:48 GMT -5
Now you all know I've done my TACCP / VACCP , and whilst its not complete, I wondered if any of you would like to proof read it for me??? 
I'll even throw in my EACCP for free!
Cheers
Caz x |
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Post by evilredhead on Mar 31, 2015 10:54:55 GMT -5
Here is the VACCP that we mentioned via email. Thanks! VACCP.docx (17.22 KB) |
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Post by cazyncymru on Apr 1, 2015 4:15:02 GMT -5
I've just had a look at this, and frankly I don't think it's worth the paper its written on! I hate being so disparaging but if I was an auditor (thank god I'm not) I would think this a piss poor attempt and a cop out! I don't think it has addressed the fundamental questions. Really, does a supplier have a history of fraud? Like they'd admit it? and if so, their probably operating under a different company name, so it wont be traceable to them unless your going to delve into each directors individual history! So what do you do if they say they have no history but you find something on an internet search? how do you address that?
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Post by itrainsinside on Apr 1, 2015 7:27:14 GMT -5
Our audit is towards the end of September, so I anticipate much of my time in the near future being spent on developing ours. I have attended a pretty shotty seminar on it (didn't feel like I learned a whole lot) and have started doing some serious independent research. We are a co-packer, so we really have no label of our own, and only provide things like citric and malic acids....
I am wondering how in depth mine is going to have to go. But I'll be sure to have you fine folks proof-read for me also! Caz, I may not be the most informed on the subject, but if you are still needing someone to proof-read I would be glad to give you my thoughts.
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Post by itrainsinside on Apr 1, 2015 7:39:22 GMT -5
Also - regarding the VACCP doc from J. Young or whoever, (Thanks RedHead for posting!)
It seems to be an alright starting point if anything... I agree with you Caz, there is something substantial missing. I would expect that because this is a newer requirement that it is going to take some time to develop understanding (as well as receive some direction from auditing firms on expectations) but I would have gone further in developing criteria to base the vulnerability probability on.
I don't know how to word this eloquently so I'll just try to spit it out. I also feel like there should be some kind of guideline.. or minimum research involved. When they say "Food Fraud findings from internet search (yes / no)".... the research base (internet) is HUGE so essentially it gives me the feeling that they pick and choose what findings to draw a conclusion from.. which can be biased depending on the amount of work you feel like doing. (I hope that makes sense)
So anyways... like I was saying , maybe a good starting point but definitely needs some expansion.
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Post by cazyncymru on Apr 1, 2015 8:12:20 GMT -5
Ohh im sure that the BRC will issue a guideline; probably cost a fortune!
I Bought the CCFRA one at £150!!
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Post by Rick Ramsay on Apr 6, 2015 6:28:09 GMT -5
I'm still not even sure what TACCP and VACCP are. I've seen you guys mention it before but afaik we don't interact with those at all. I think I'm going to have to go to google and look around a bit.
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Post by cazyncymru on Apr 7, 2015 5:13:27 GMT -5
If your a BRC person, then V7 makes a big deal out of having a VACCP / TACCP study.
To be honest, there are many ways to do this, and I don't think any way is wrong, as long as the information collated is meaningful. I think you need to demonstrate that you have assessed (all) risks and how they could impact on the integrity, authenticity & food safety of your product. I think the main driver(s) are Integrity & Authenticity. Whilst your supplier approval procedure should be the starting point for this, it does not substitute from having a system that identifies potential risks and how you can control them. It might be that the control measure is your supplier approval process, but your supplier approval process is not the assessment.
Take for instance the purchase of raw milk
One potential vulnerability / threat is that the milk be adulterated or contaminated with milk with elevated somatic cells which would indicate poor cattle health. Your control would be that you only buy milk from an approved supplier who participates in a farm assurance scheme. Raw milk is regularly tested. But you cannot take responsibility for a farmer adding contaminated milk into a tank.
No matter what the BRC, or anyone else for that matter says, you cannot anticipate EVERY eventuality. So your TACCP / VACCP will always be a live document and subject to change at an time. Personally I think it has to be treated the same as HACCP, with regular reviews, review meetings for changes , information from horizon sweeping etc., documented. I look at incidents that don't necessarily affect my industry directly, but the outcome could impact. It is also difficult for technical managers to have to create these assessments. You now have to be an "expert" in all of your raw ingredients. It's made even more difficult if you have a supplier refuse to send you copies of their BRC reports (SAQ's will no longer be an accepted format for supplier approval going forward) and who has the time to audit all their suppliers?
So, whilst I embrace the introduction of VACCP / TACCP, I worry about the impact it will have on Food Safety as we'll all be too embroiled in ensuring that our suppliers comply, that we'll take our eye off the ball internally. I'm also concerned that the people auditing us won't be as clued up on VACCP / TACCP and a potential threat / vulnerability can affect our industry.
I've done my (draft) version, and you all know my stance on this. I will share with you privately; I'm not prepared to share publically.
Caz x
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