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Elements and Performance Criteria

1. Form a threat and vulnerability team
   • Select a cross-functional team with personnel from across the organisation
   • Define roles of team members based on knowledge of the implications of food fraud and food vulnerabilities
   • Schedule regular team meetings to update and review Threat Assessment and Critical Control Points (TACCP) and Vulnerability Assessment and Critical Control Points (VACCP) plans
2. Develop a food defence plan
   • Undertake and document a threat assessment
   • Develop a flow chart of the supply chain and identify steps where there is potential threat to the organisation, key staff, operations and the product
   • Undertake a risk assessment to identify the critical control points (CCPs)
   • Identify where the controls are for each CCP and develop action plans to address breaches
   • Develop a food defence plan outlining the methods, responsibilities and criteria for preventing food adulteration
   • Document the plan and schedule a review at least annually
3. Develop a food fraud mitigation plan
   • Undertake and document a vulnerability assessment
   • Assess raw materials, direct food contact packaging and supply chains to identify where the site is vulnerable to food fraud
   • Undertake a risk assessment to identify the critical control points (CCPs)
   • Implement a food fraud mitigation plan to specify the methods of controlling food fraud vulnerabilities
   • Document the plan and schedule a review at least annually
4. Maintain records
   • Maintain records of the food defence plan securely and ensure they are readily accessible
   • Maintain records of the review of the food fraud vulnerability assessment and mitigation plan and ensure they are readily accessible