Validation and Verification as

applies to Management
Systems of Food Safety

Yogesh Jain
Niche Quality Solutions Private Limited
9303205440, [email protected]
www.nicheqs.com 1
 Definition: Validation

<food safety> obtaining evidence that a

control measure for combination of control
measures will be capable of effectively
controlling the significant food safety hazard

Note 1: Validation is performed at the time a control

measure combination is designed, or whatever changes
are made to the implemented control measures.
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 Definition: Verification
confirmation, through the provision of objective
evidence, that specified requirements have been
fulfilled.

Requirements: Need or expectation that is stated,

generally implied or obligatory.

Note: Generally implied means that it is customer or

common practice for the organisation and interested
parties that the need or expectation under
consideration is implied.
Note: A specified requirement is one that is stated, for
example in documented information.
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Note:
Distinction between Validation, Monitoring,
Verification

validation is applied prior to an activity and provides

information about the capability to deliver intended
results;
monitoring is applied during an activity and provides
information for action within a specified time frame;
verification is applied after an activity and provides
information for confirmation of conformity.

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Context
Can HACCP control Quality or legal aspects
within food manufacturing?

Cases of deliberate food contamination and

food fraud are noted quite regularly

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Context
HACCP helps to prevent unintentional contamination

TACCP and VACCP prevents intentional

contamination

Intentional contamination requires human

intervention

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Context of the Organization

Ref. PAS 96(2014) – PAS for the protection of food from

intentional attack viz.
1. Economically motivated adulteration
2. Malicious contamination,
3. Extortion,
4. Espionage,
5. Counterfeiting and
6. Cyber-crime

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TACCP and VACCP

Help assess specific threats to biz from

intentional contamination from
◦ Rogue employees
◦ Pressure groups
◦ Ideologically motivated individuals
◦ Terrorists

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 Know Your Xs
Know your
◦ Staff
◦ Contractors
◦ Cleaners
◦ Visitors

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TACCP
THREAT ASSESSMENT CRITICAL CONTROL POINT
 Management Process to defend a food supply chain from intentional
contamination

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VACCP
Vulnerability Assessment Critical Control Point
 Case of Horsemeat scandal 2013
◦ (Contamination of Beef with horsemeat)
 VACCP def.: Management process to defend a food supply chain from
any form of dishonest conduct that impacts detrimentally on the quality or
authenticity of food and drink.
◦ FBO to think like criminals to assess economically motivated dilution, substitution or
concealment
◦ Another vulnerability: Mislabeling or misdescription, varietal misdescription, incorrect
country of origin / origin (in case of GI), adulteration, dilution, concealment,
counterfeiting and unapproved enhancements.

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VACCP
VACCP (Vulnerability Assessment Critical

Control Point)
-  management process to defend a food
supply chain from
 dishonest conduct that impacts detrimentally on
the quality or authenticity of food and drinks. 

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VACCP – Historical and potential opportunities

Most of the times it is only economically

motivated –
◦ beef contaminated with horsemeat  may result
into ethical or social issues; sometimes religious
also
But sometimes it goes on to safety issue also
e.g.
◦ Illegal textile dye – economically motivated – but
as well a food safety incident. Sudan dyes case
(toxic, potential carcinogens)

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VACCP

VACCP (Vulnerability Assessment Critical Control Point)

-  Management process to defend a food supply chain from

 dishonest conduct that impacts detrimentally on the quality or authenticity of
food and drinks. 
 Focus on food fraud and include systematic prevention of any potential
adulteration of food, whether intentional or not, by identifying the vulnerable
points in a supply chain.
 Concerned with economically motivated adulterations (EMA) include

 product substitutions,

 unapproved product enhancements,

 counterfeiting,
 stolen goods and

 others. www.nicheqs.com 14
 ADVANTAGES OF TACCP & VACCP

 Demonstrate your commitment to food safety

 Reduce the likelihood of a deliberate attack
  Reduce the impact of an attack on your food business
 Reassure stakeholders about the safety of your
production and supply chain
 Enhance your brand reputation
 Better management of risks, both now and in the future

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Questions TACCP team can use
Who might want to attack us?
How might they do it?
Where are we vulnerable?
How can we stop them?

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TACCP Implementation Diagram

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 Audit Findings pertaining to Food Fraud
and Food Defence
Food fraud risk assessment found not carried out for rice
and gram raw material.
Starch substitution in corn flour found not captured as
historic incident for the food fraud risk assessment.
(Maize starch is sometimes used to adulterate (dilute)
other specialty starches such as sago
https://trello.com/c/r2n4IqlB/294-maize-corn )

Food defence risk assessment found not carried out for

few of the activities viz. chemical storage, Laboratory
and by products storage area.

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 Audit Findings pertaining to Food Fraud
and Food Defence
Worrying levels of mycotoxins of various types found in
maize sampled from Polish maize farms and animal feed
production sites during a 2017 survey (n=81). Average
results were below the EU recommended maximums
however some samples exceeded the limits significantly.
15/01/2018 https://trello.com/c/r2n4IqlB/294-maize-corn
Inorganic Corn sold as Organic by farmer as reported in
https://trello.com/c/r2n4IqlB/294-maize-corn Case:
Missouri farmer pleads guilty to selling conventional corn
and soybeans as organic over more than 2 years.
19/12/2018

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Indian experience of adulteration
Sarita, Mukta magazines
◦ Case of adulteration of black pepper with
Papaya seed
◦ Cumin with several look-alike
◦ Rice with marble chips, etc.

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Source:
https://www.indiatoday.in/education-today/gk-current-affairs/story/co
mmon-food-adulterants-in-india-1370601-2018-10-19

1. Milk
A 2012 study conducted by the FSSAI across 33 states found that milk in India was
adulterated with diluted water, detergent, fat and even urea.
Some of the adulterants that are used in milk are water, chalk, urea, caustic soda and
skimmed milk, while Khoya is adulterated with paper, refined oil and skimmed
milk powder.
The level of adulteration in milk is dangerous to so many levels and has the highest
chance of causing stomach disorders.

2. Tea/Coffee
Tea and coffee are two most used beverages in India, and thus highly adulterated. Tea
leaves are usually adulterated with same coloured leaves, some might not even be
edible. Several cases of liver infection across the country have been reported due
to consuming adulterated tea.
Coffee seeds, on the other hand are adulterated with tamarind seeds, mustard seeds
and also chicori. These adulterants are the main cause of diarrhoea.

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Source:
https://www.indiatoday.in/education-today/gk-current-affairs/story/co
mmon-food-adulterants-in-india-1370601-2018-10-19

3. Wheat and other food grains

Wheat is very commonly adulterated with ergot, a fungus containing
poisonous substances and is extremely injurious to health.

4. Vegetables
Different coloured and textured vegetables are often coloured with
different dyes and substances. These vegetables are mostly adulterated
with malachite green, a chemical dye which is known to have
carcinogenic.

Common adulterants in fruits and vegetables are oxytocin sachharin, wax,

calcium carbide and copper sulphate.

5. Sweets
As per Indian regulations, silver must be 99.9 per cent pure for food as an
ingredient. However, silver vark may now contain aluminium.
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Source:
https://www.indiatoday.in/education-today/gk-current-affairs/story/co
mmon-food-adulterants-in-india-1370601-2018-10-19

6. Honey
Honey is commonly adulterated with
molasses sugar to increase the bottle quantity.
Also as per a study carried out by the Centre
for Science and Environment, most honey
brands in India contain varying amounts of
antibiotics  Over time these can induce
resistance to antibiotics, leading to blood-
related disorders and injury to the liver.

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Source:
https://www.indiatoday.in/education-today/gk-current-affairs/story/co
mmon-food-adulterants-in-india-1370601-2018-10-19

7. Dal
Most commonly adulterated dal is arhar dal
and is adulterated with metanil yellow - a
principal non-permitted food colour used
extensively in India  Long-term
consumption of metanil yellow on the
developing and adult brain causes
neurotoxicity.
Testing: By adding a few drops of HCl to a
test sample, if the solution turns pink, it
indicates the presence of metanil yellow.
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 Source:
https://www.indiatoday.in/education-today/gk-current-affairs/story/co
mmon-food-adulterants-in-india-1370601-2018-10-19

8. Spices
Turmeric adulteration with Metanil Yellow andn Red Oxide of Lead - the
later being highly carcinogenic. Recently, a major Indian supplier was
caught and had to destroy tons of adulterated turmeric.

Soap stone or other earthy material and foreign resinare the common
adulterant used in Asafoetida.

Papaya seeds, black berries are the common adulterant used in black
pepper as they are almost similar in size but tasteless (sometimes bitter).

Red chilli powder is adulterated with brick powder,

Salt powder or talc powder and artificial colours like Sudan Red.

The most expensive spice in the world. Saffron is adulterated by coloured

dried tendrils of maize cob.
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 Source:
https://www.indiatoday.in/education-today/gk-current-affairs/story/co
mmon-food-adulterants-in-india-1370601-2018-10-19

9. Butter and cream

Butter can be diluted with water or partially replaced with cheaper plant
oils such as palm oil, sunflower oil and soybean oil. This increases the
profits derived from a given volume of milk.

10. Ice cream

Most common adulterants in ice cream are pepperonil, ethyl-acetate,
butraldehyde, emil acetate, nitrate, washing powder etc are not less than
poison.

Pepperoil is used as a pesticide and ethyl acetate causes terrible diseases

affecting lungs, kidneys and heart.

Ice cream is manufactured in extremely cold chamber where fat is

hardened and several harmful substances are added. Also a kind of gum is
added which is sticky and slow melting. This gum is obtained by boiling
animal parts like tail, the nose, the udder etc.
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Testing of Food Fraud
Ifthe sweets are adulterated by boiling a small sample in water, cool it then add a few drops of
iodine solution. A blue color indicates the presence of starch. Also, sugar used in making these
sweets might be adulterated with tar dye which only makes it worse. Read more at: 

Turmeric powder: Indian cooking is incomplete without the use of turmeric powder. However,
a commonly used adulterant here is lead chromate, which gives it a bright yellow tinge and is
insoluble in water. To detect the presence of lead chromate, the powder can be mixed with
water and placed in a beaker. If adulterated, it will immediately leak colour.
Red chili powder: Red chili powder is the most commonly used spice in any Indian household,
and is perhaps also the most adulterated spice. Among the most commonly used adulterants in
chili powder are saw dust and brick powder. Add a teaspoon of chili powder to a glass of
water and swirl it. Adulterated chili powder will dispel a red swirl of colour.
Powdered spices: Starch, food colours, dust, and even horse dung are some of the commonly
used adulterants in powdered spices, and can lead to serious health complications. Immersing
powdered spices in water will ensure that the adulterants float on the surface of the water,
while the remaining spices settle at the bottom.
https://yourstory.com/2017/04/adulteration-spices

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Source:
https://vikaspedia.in/health/health-campaigns/beware-o
f-adulteration/safe-ground-spices
SN Spices Adulteration
01 Black Pepper Powder Addition of papaya seeds, starch and sawdust
02 Turmeric powder Addition of lead chromate, mentanil yellow, chalk powder or yellow
soap stone powder and starch: substitution with other rhizomes e.g.
arrrow root etc. Also visit:
https://explorers.zizira.com/adulteration-in-turmeric-powder-happens-
03 Chillies powder can-you-avoid-it/
Addition of brick powder, salt powder or talc powder, artificial
colours and dyes, colour, grit, sand, dirt, filth, saw dust, dried tomato
skin
04 Asafoetida (Hing) Addition of soap stone or other earthy material, starch, foreign resin
05 Coriander powder Addition of animal dung powder, seed removed coriander
06 Oregano Addition of other similar hebs and plant leaves
07 Curry Powder Addition of starch powder and sawdust
08 Cinnamon Substitution with Cassia
09 Cumin Addition of grass seeds coloured with chorcoal, immature fennel
10 Saffron Addition of coloured dried tendrils of maize cob, Sandalwood dust,
Tartrazine, Coconut threads
11 Cardamom Substitution with de-oiled cardamom, artificial colourant
(e.g.'applegreen', malachite green).

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Detection:
How to detect adulteration in ground spices at
home
Adulteration in ground spices can be checked
at home by using simple test methods listed in
Detect Adulteration with Rapid Test (DART)
booklet prepared by FSSAI. This booklet is a
compilation of common quick tests for
detection of food adulterants at household
level by citizens themselves. It can be
downloaded free from the FSSAI Website 
https://foodsmart.fssai.gov.in/PinkBook.pdf
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Dos and Don’ts to prevent fraudulent
spice purchase
No to buying powdered spices loose.
Yes to buy spices in packaged condition from trusted brands only. Prefer
purchasing AGMARK certified ground spices and look for AGMARK logo.
Check the FSSAI licence number on the package label.
Yesto whole spices from known/reputed stores / dealers and grind them at
home after proper cleaning and washing.
No to spices with extra shine and bright colours.
No to ground spices having lump formation or unpleasant odour.
Check mfg date, mfr details, best before date and other labelling declarations
before buying spices.
No - if package is damaged.
Look for FSSAI organic logo (Jaivik Bharat) on the pack while buying
organic spices.
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Questions

Thanks

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