## Pas 96:2017 Guide To Protecting And Defending Food And Drink From Deliberate Attack Publishing And Copyright Information

The BSI copyright notice displayed in this document indicates when the document was last issued. © The British Standards Institution 2017. Published by BSI Standards Limited 2017.

## Isbn 978 0 580 98099 2

ICS 67.020
No copying without BSI permission except as permitted by copyright law.

## Publication History

First published March 2008 Second edition March 2010 Third edition October 2014 Fourth (current) edition November 2017

## Contents

Foreword ..................................................................................................... 	 ii Introduction .
................................................................................................ 	 iv
1 Scope .
........................................................................................................ 	 1
2 Terms and definitions .............................................................................. 	 1 3 Types of threat ......................................................................................... 	 4 4 Understanding the attacker .
................................................................... 	 8
5 Threat Assessment Critical Control Point (TACCP) .
................................ 	 10
6 Assessment .
.............................................................................................. 	 13
7 Critical controls ........................................................................................ 	 16 8 Response to an incident .......................................................................... 	 18 9 Review of food protection arrangements ............................................. 	 19
Annexes
Annex A (informative) TACCP case studies.
................................................ 	 20
Annex B (informative)  Sources of information and intelligence about 
emerging risks to food supply.
.................................................................... 	 41
Annex C (informative) Complementary approaches to food and drink 
protection.
.................................................................................................... 	 43
Annex D (informative) 10 Steps to cyber security: A board level 
responsibility)............................................................................................... 	 44 Bibliography................................................................................................. 	 45
List of figures
Figure 1 - A food supply chain .
.................................................................. 	 2
Figure 2 - Outline TACCP process .
.............................................................. 	 11
Figure 3 - Risk scoring matrix .
.................................................................... 	 15
Figure A.1 Threat identification.
................................................................. 	 22
Figure A.2 - Threat prioritization .............................................................. 	 28 Figure A.3 - Vulnerability assessment .
....................................................... 	 30
Figure A.4 - FryByNite workflow ............................................................... 	 31 Figure A.5 - Threat prioritization .............................................................. 	 35 Figure A.6 - Threat prioritization .............................................................. 	 40
Figure B.1 - Global dissemination of information and intelligence about 
emerging risks to food .
............................................................................... 	 42
List of tables
Table 1 - Risk assessment scoring .
.............................................................. 	 15
Table 2 - Approaches to risk reduction ..................................................... 	 16 Table 3 - Tamper evidence ......................................................................... 	 17
Table 4 - Personnel security .
....................................................................... 	 17
Table A.1 - Threat information .................................................................. 	 21
Table A.2 - Threat identification .
............................................................... 	 23
Table A.3 - Threat assessment .
................................................................... 	 26
able A.4 - Threat assessment report 20170602 .
........................................ 	 29
Table A.5 - Threat information................................................................... 	 32
Table A.6 - Threat assessment .
................................................................... 	 33
Table A.7 - Threat register.......................................................................... 	 36
Table A.8 - Possible sources of malicious activity affecting F. Armer & 
Daughters Ltd.
.............................................................................................. 	 38
Table A.9 - Threat assessment.
.................................................................... 	 39

## Foreword

This PAS was sponsored by the Department for Environment, Food & Rural Affairs (Defra) and the Food Standards Agency (FSA). Its development was facilitated by BSI Standards Limited and it was published under licence from The British Standards Institution. It came into effect on 16 November 2017.

This PAS is not to be regarded as a British Standard. It will be withdrawn upon publication of its content in, or as, a British Standard.

Acknowledgement is given to the following organizations that were involved in the development of this PAS as members of the steering group:

•	 Agrico UK Limited •	 British Frozen Food Federation (BFFF) •	 Campden BRI
•	 Crowe Clark Whitehill LLP
•	 Danone
The PAS process enables a guide to be rapidly developed in order to fulfil an immediate need in industry. A PAS can be considered for further development as a British Standard, or constitute part of the UK input into the development of a European or International Standard.

•	 Department for Environment, Food & Rural Affairs
(Defra)
•	 Food Standards Agency

## Supersession

•	 GIST Limited
This PAS supersedes PAS 96:2014, which is withdrawn.

•	 McDonald's Europe •	 National Cyber Security Centre (NCSC)

## Information About This Document

•	 Sodexo Limited •	 Tesco UK
This is a full revision of the PAS 96:2014, and introduces the following principal changes:

•	 Tulip Limited
•	 normative and informative references have been
•	 University College London
updated;
•	 Willis Towers Watson
•	 subclause 3.7 Cyber-crime has been revised; •	 subclause **6.2.4** added to cover vulnerabilities related
to cyber-attacks;
Acknowledgement is also given to the members of a wider review panel who were consulted in the development of this PAS.

•	 two new fictional case studies have been added as
subclauses A.5 and A.6 to illustrate cyber security issues;
•	 Annex B updated; •	 Annex D added covering 10 steps to cyber security; •	 some editorial amendments have been undertaken.
The British Standards Institution retains ownership and copyright of this PAS. BSI Standards Limited as the publisher of the PAS reserves the right to withdraw or amend this PAS on receipt of authoritative advice that it is appropriate to do so. This PAS will be reviewed at intervals not exceeding two years, and any amendments arising from the review will be published as an amended PAS and publicized in Update Standards.

## Use Of This Document

As a guide, this PAS takes the form of guidance and recommendations. It should not be quoted as if it were a specification or a code of practice and claims of compliance cannot be made to it.

## Presentational Conventions

The guidance in this standard is presented in roman (i.e. upright) type. Any recommendations are expressed in sentences in which the principal auxiliary verb is "should".

Commentary, explanation and general informative material is presented in smaller italic type, and does not constitute a normative element.

## Contractual And Legal Considerations

This publication does not purport to include all the necessary provisions of a contract. Users are responsible for its correct application. Compliance with a PAS cannot confer immunity from legal obligations.

## Introduction

The food industry sees the safety of its products as its main concern. Over the years, industry and regulators have developed food safety management systems which mean that major outbreaks of food poisoning are now quite unusual in many countries. These systems typically use Hazard Analysis Critical Control Point (HACCP) principles which are accepted globally.1) 
HACCP has proven to be effective against accidental contamination.

It explains the TACCP process, outlines steps that can deter an attacker or give early detection of an attack, and uses fictitious case studies (see Annex A) to show its application. Broadly, TACCP places food business managers in the position of an attacker to anticipate their motivation, capability and opportunity to carry out an attack, and then helps them devise protection. It also provides other sources of information and intelligence that may help identify emerging threats 
(see Annex B). The TACCP process assumes and builds on a business' existing effective operation of HACCP, as many precautions taken to assure the safety of food are likely to also deter or detect deliberate acts. It also complements existing business risk management and incident management processes.

HACCP principles however have not been routinely used to detect or mitigate deliberate attacks on a system or process. Such attacks include deliberate contamination, electronic intrusion, and fraud. Deliberate acts may have food safety implications but can harm organizations in other ways, such as damaging business reputation or extorting money.

The focus of this PAS is on protecting the integrity and wholesomeness of food and food supply. Any intending attacker, whether from within a food business or its supply chain or external to both, is likely to attempt to elude or avoid routine management processes. It should help food businesses mitigate each of these threats, but the approach may also be used for other business threats.

The common factor behind all such deliberate acts is people. These people may be within a food business, may be employees of a supplier to the food business, or may be complete outsiders with no connection to the food business. The key issue being their motivation, they may aim to cause harm to human health, business reputation, or make financial gains at the expense of the business. In any of these situations it is in the interests of the food business to protect itself from such attacks. 

No process can guarantee that food and food supply are not the target of criminal activity, but the use of PAS 96 can make it less likely. It is intended to be a practical and easily used guide and so is written in everyday language and is to be used in a commonsense rather than legalistic way. 

The purpose of PAS 96 is to guide food business managers through approaches and procedures to improve the resilience of supply chains to fraud or other forms of attack. It aims to assure the authenticity and safety of food by minimizing the chance of an attack and mitigating the consequences of a successful attack. PAS 96 describes Threat Assessment Critical Control Points (TACCP), a risk management methodology, which aligns with HACCP, but has a different focus, that may need input from employees from different disciplines, such as human resources, procurement, security and information technology. 

## 1 Scope

This PAS provides guidance on the avoidance and mitigation of threats to food and food supply. It describes a risk management methodology, Threat Assessment Critical Control Points (TACCP), which can be adapted by food businesses of all sizes and at all points in food supply chains. While concerns for the safety and integrity of food and drink are paramount and much of the PAS is focussed on them, it needs to be stressed that its scope covers 'All Threats' and protection of all elements of food supply. This includes the viability of businesses within the supply chain. It is intended to be of use to all organizations, but is of particular use to managers of small and medium sized food enterprises without easy access to specialist advice. 

## 2 Terms And Definitions

For the purposes of this PAS, the following terms and definitions apply.

## 2.1 Cyber Security

protection of devices, services and networks — and the information on them — from theft or damage
{SOURCE: NCSC Glossary [2]}

## 2.2 Food Defence

procedures adopted to assure the security of food and drink and their supply chains from malicious and ideologically motivated attack leading to contamination or supply disruption

NOTE The term food security refers to the confidence 
with which communities see food being available to 
them in the future. Except in the limited sense that a 
successful attack may affect the availability of food, 
food security is not used and is outside the scope of this 
PAS. 

## 2.3 Food Fraud

dishonest act or omission, relating to the production or supply of food, which is intended for personal gain or to cause loss to another party2)
NOTE 1 Although there are many kinds of food fraud the two main types are:

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;
2)	 the deliberate misdescription of food, such as:

## 2.6 Hazard

•	 products substituted with a cheaper alternative, 
for example, farmed salmon sold as wild, and Basmati rice adulterated with cheaper varieties;
something that can cause loss or harm which arises from a naturally occurring or accidental event or results from incompetence or ignorance of the people involved

•	 making false statements about the source of 
ingredients, i.e. their geographic, plant or animal origin.

## 2.7 Hazard Analysis Critical Control Point (Haccp)

system which identifies, evaluates, and controls hazards which are significant for food safety NOTE 2 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.

{SOURCE: CODEX Alimentarius. General Principles of Food Hygiene [1]}

## 2.4 Food Protection Procedures Adopted To Deter And Detect Fraudulent Attacks On Food 2.8 Insider 2.5 Food Supply

individual within or associated with an organization and with access to its assets but who may misuse that access and present a threat to its operations elements of what is commonly called a food supply chain NOTE An example of a food supply chain is given in Figure 1. Figure 1 is not intended to be comprehensive.

## 2.9 Personnel Security

procedures used to confirm an individual's identity, qualifications, experience and right to work, and to monitor conduct as an employee or contractor NOTE 1 Not to be confused with 'personal security'. NOTE 2 Personnel security principles are used to assure the trustworthiness of staff inside an organization, but may be applied to the staff of suppliers within processes for vendor accreditation.

## 2.10 Threat

something that can cause loss or harm which arises from the ill-intent of people NOTE Threat is not used in the sense of threatening behaviour or promise of unpleasant consequence of a failure to comply with a malicious demand.

## 2.11 Threat Assessment Critical Control Point (Taccp)

systematic management of risk through the evaluation of threats, identification of vulnerabilities, and implementation of controls to materials and products, purchasing, processes, premises, people, distribution networks and business systems by a knowledgeable and trusted team with the authority to implement changes to procedures

## 3 Types Of Threat 3.1 General

for many years.6) It is not clear whether the burgers actually contained enough beef to satisfy any official regulation.

Deliberate acts against food and food supply take several forms. Clause 3 describes the characteristics of the main threats to food authenticity and safety - economically motivated adulteration (EMA) and malicious contamination, and explains the nature of other threats, particularly the rapidly growing misuse of digital techniques. 

In 2014 the Kenyan Dairy Board claimed that hawkers were putting lives at risk by adding preservatives (formalin and hydrogen peroxide) in a (probably futile) 
attempt to extend the shelf life of milk.7)

## Case 5 3.2 Economically Motivated Adulteration (Ema)

Staff in a European meat packer felt, mistakenly, that they could avoid a product being condemned as carrying foot and mouth disease by covering it with disinfectant.

NOTE Details of many other cases are available from the US Pharmacopeial Convention's Food Fraud Database at http://www.foodfraud.org/ [4]. 

In 2016, customs officials in Nigeria confiscated 2.5 tonnes of rice which they suspected was made from plastic.3)
The motivation of EMA is financial, to gain an increased income from selling a foodstuff in a way which deceives customers and consumers. This may be by either passing off a cheaper material as a more expensive one (see case 1), or it may be that a less expensive ingredient is used to replace or extend the more expensive one (see cases 2 and 3).

The avoidance of loss may also be an incentive for adulteration (see cases 4 and 5). Limited supply of a key material may encourage a producer to improvise to complete an order rather than declare short delivery to the customer.

Olive oil has been a frequent target for adulteration, often by other vegetable oils. In 2017 Italian authorities disrupted an organized crime ring which was exporting fake olive oil to the United States.4) Similarly, Brazilian officials reported that a very high proportion of olive oils tested did not meet the quality standards required by their labelling.5)

Spanish police have accused a beef burger manufacturer of using minced pork and soya to increase the perceived meat content of their products The intention of EMA is not to cause illness or death, but that may be the result. This was the case in 2008 when melamine was used as a nitrogen source to fraudulently increase the measured protein content of milk, resulting in more than 50 000 babies hospitalized and six deaths after having consumed contaminated infant formula.8) 6) Further information is available from: https://www.

euroweeklynews.com/3.0.15/news/on-euro-weekly-news/spainnews-in-english/144405-police-uncover-major-beef-food-fraudin-spain [8]. 

7) Further information is available from: http://www.

standardmedia.co.ke/article/2000107380/naivasha-hawkersusing-formalin-to-preserve-milk [9]. 

oliveoiltimes.com/olive-oil-business/italy-arrests-33-accusedolive-oil-fraud/55364 [6]. olive-oil-fraud/56395 [7].

cyanuric acid http://www.who.int/foodsafety/publications/ melamine-cyanuric-acid/en/ [10].

The common factor in many cases of EMA is that the adulterant is neither a food safety hazard, nor readily identified, as this would defeat the aim of the attacker. 

Common adulterants9) include water and sugar; 
ingredients that may be properly used and declared but improper use is food fraud. EMA is likely to be more effective for an attacker, and therefore present a greater threat to a food business, upstream on the food supply chain (see Figure 1) close to manufacture of primary ingredients. A successful adulteration (from the point of view of the attacker) continues without detection. EMA may need an insider but could be revealed by verification, for example, financial audit could reveal:

•	purchases which are unexplained by recipes, such as 
sudan dyes which have no place in spice manufacture; or
•	differences between quantities sold and quantities 
purchased, such as beef mince sold and bovine meat purchased, with horsemeat to make up the difference.

## 3.3 Malicious Contamination Case 6

In 2005, a major British bakery reported that several customers had found glass fragments and sewing needles inside the wrapper of loaves.10)

In 1984, the Rajneeshee sect in Oregon attempted to affect the result of a local election by contaminating food in ten different salad bars, resulting in 751 people affected by salmonella food poisoning.11) 

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.

In 2007, a bakery found piles of peanuts in the factory. It withdrew product and closed for a week long deep clean to re-establish its nut-free status. The motivation for malicious contamination may be to cause localized (see case 6) or widespread (see case 7) illness or death. In case 7, the attacker did not want the contamination to be detected before it was consumed, therefore the contaminant had to be an effective toxin with little effect on the palatability of the food. The motivation in case 8 was publicity. Public opinion would have been against the attackers if harm had been caused to members of the public, but the supplier could not take that risk. Materials which could be used by an attacker to gain publicity, or to extort money, are more readily found than those needed to cause widespread harm. The case of allergens (see case 9) shows the harm, impact and cost that can be caused to a business with little risk to the attacker. Contamination close to point of consumption or sale, as in case 7, (downstream in Figure 1) is more likely to cause harm to health than an attack on crops or primary ingredients. 

## 3.4 Extortion Case 10

In 1990, a former police officer was convicted of extortion after contaminating baby food with glass and demanding money from the multi-national manufacturer.12)

In 2008, a man was jailed in Britain after being convicted of threatening to bomb a major supermarket and contaminate its products.13)

## 3.6 Counterfeiting Case 14

In 2013, enforcement officers seized 9 000 bottles of fake Glen's Vodka from an illegal factory.16)  
The motivation for extortion by either an individual or group is financial, to obtain money from the victim organization. Such activity is attractive to the criminal mind when the product, like baby food (see case 10), is sensitive or where a company is seen as rich (see case 11). 

A small number of samples can be used to show the company that the attacker has the capability and is enough to cause public concern and media interest.

In 2011, 340 bottles of a famous Australian brand of wine were seized, following complaints of poor quality to the owner, which had no link with Australia.17)

## 3.5 Espionage Case 12

One business consultancy uses the theft of the intellectual property of a fictitious innovative snack product as an example of commercial espionage.14)

The motivation for counterfeiting is financial gain, by fraudulently passing off inferior goods as established and reputable brands. Both organized and petty crime can cause companies financial loss and harm to their reputation. The former, for example, can use sophisticated printing technologies to produce product labels that are indistinguishable from the genuine ones. The latter can steal genuine packs or even refill single use containers for resale. 

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.15)
Organized criminals may try to mimic the food contents closely to delay detection and investigation. Petty criminals may be tempted by a 'quick killing' and be less concerned in the safety of the food.

The primary motivation of espionage is for competitors seeking commercial advantage to access intellectual property. They may infiltrate using insiders to report, or may attack remotely through information technology systems. Alternatively, organizations may try to entice executives to reveal confidential information or use covert recording to capture such material, or they may simply steal the material, as case 13 suggests.

## 14) For Further Information On This Fictional Case Study Is 3.7 Cyber Crime Case 16

In 2014, Financial Fraud Action UK advised restaurant managers to stay vigilant as fraudsters are attempting to target their customers in a new phone scam. They phone restaurants claiming there is a problem with their card payments system, the restaurant is then told to redirect any card payments to a phone number provided by the fraudster.18) Modern information and communication technologies provide new and rapidly increasing opportunities for malpractice. In case 16 the fraudster uses social engineering to try to defraud both business and consumer. It is common for the attacker to try and exploit individual ignorance of the technologies involved. The fraud in this case is 'cyber-enabled', that is a familiar scam made easier by electronic communications. In total in England and Wales for the year to September 2016, the Office for National Statistics reported about 3.6 million frauds and nearly 2 
million cases of computer misuse.19) 

In 2016, reports suggested that criminals had hacked Deliveroo accounts to order food on victims' cards.20)

In 2015, Michigan-based Biggby Coffee reported a database breach with possible theft of customer information derived from loyalty card applications.21)  
The fraud in both cases 17 and 18 could be carried out remotely over the Internet with little chance of detection and justice for the perpetrator.

In 2016 the FBI and US Department of Agriculture alerted farmers to their increasing vulnerability to cyber-attack through their use of precision agriculture technology. 22) 
Such an attack could be cyber-enabled industrial espionage, or hacking - gaining unauthorized access to computer systems, perhaps with malicious intent.

In 2016 a major supermarket discovered that scales at its self-service check outs had been corrupted to enable distributed denial of service (DDOS) attacks on public websites. DDOS can be a real nuisance to companies, and lead to real losses when the company website is an important trading platform. The 'Internet of Things' (IoT) becomes more and more important; the Joint NCSC/NCA Threat Report23) exposes the vulnerability of (apparently innocuous) internet connected devices and their misuse by criminals. Identity theft is perhaps more familiar to the public, but organizations may be aware of their identity being stolen to enable procurement fraud, in which goods are ordered in their name but diverted to the fraudsters premises leaving the duped supplier and supposed purchaser to carry the cost and litigation.

## 4 Understanding The Attacker 4.1 General

customers or auditors, or ad hoc sampling for analysis may deter their actions. 

The success of a deliberate attack on food or food supply depends on several things: 

a) 	 Does the attacker have the motivation and drive 
to overcome the obvious, and less obvious blocks to their actions? If the blocks seem massive and success seems unlikely, many would-be attackers 
would seek an easier target.
A supplier who cannot risk failure to deliver to a customer may take the chance that occasional adulteration would not be detected. Success on one occasion may make it easier to attempt a repeat. This opportunist may persuade themselves that the adulteration is legitimate, for example, chicken in a pork sausage would still be meat. 

b) 	 Does the attacker have the capability to carry 
out the attack? A group is more likely to find the resources and learn the skills needed.

## 4.4 The Extremist

c) 	 Does the attacker have the opportunity to carry out 
the attack? A physical attack needs physical access to the target, but a cyber-attack may only need access to a computer.
The extremist takes their cause or campaign so seriously that they distort its context and overlook wider issues. The dedication to their cause may have no limits and their determination to progress it can be great.

d) 	 Would the attacker be deterred by the chance of 
detection and/or any potential penalties?

## 4.2 The Extortionist

Extremists may want to cause harm and are likely to enjoy publicity after the event. It may not matter, and may be a benefit, if they themselves are harmed. The risk of failure is a deterrent, but the risk of capture after the event is not. They are typically resourceful and innovative in devising ways to attack. Some single issue groups may want to disrupt business operations and reputation but fear that mass harm to the public would damage their cause and lead them to lose support. 

## 4.5 The Irrational Individual

The extortionist wants to gain financially from an attack but does not want to be caught, and concentrates on avoiding detection. Their target is more likely to be a high profile business with lots to lose from negative publicity. They may work alone and be resourceful, secretive and self-interested. Cyber attacks across the world using 'ransomware' have demonstrated both how easily extortionists can now attack multiple victims and how difficult it is to bring them to justice.24) Some individuals may claim to be able to take action against a business while lacking the capability to carry it out; the business may judge the claim as not credible but still decide to respond appropriately. 

Some individuals have no rational motive for their actions. Their priorities and preoccupations have become distorted so they are unable to take a balanced view of the world. Some may have clinically diagnosed mental health issues.

## 4.3 The Opportunist

This individual may be readily deterred by simple steps which prevent them from gaining access to their target or make detection easy.

The opportunist may hold an influential position within an operation to be able to evade internal controls. They may have some technical knowledge but their main asset is access. They are likely to be discouraged by the chance of detection, so unannounced visits by 

## 4.6 The Disgruntled Individual

The disgruntled individual believes that an organization has been unfair to them and seeks revenge. For example, they may be an aggrieved employee or former employee, supplier or customer. They may have expert knowledge of the operation and access to it. This attacker is likely to be an individual rather than part of a group. If an insider, they could be dangerous, but are more likely to want to cause embarrassment and financial loss than harm to the public. If not an insider, this individual is more likely to claim or boast of having done something than actually being able to do it. 

## 4.7 Cyber Criminals And Other Malicious Digital Actors

Cyber criminals aim to subvert controls on computerized information and communications systems in order to stop them working effectively, to steal or to corrupt data which they hold, and/or to disrupt internet business. Their motivation may be criminal or even political, but may also be to demonstrate their expertise and ability to beat any protective system devised to stop them.  
Traditionally, this type of attacker has information and communications technology expertise that can cause commercial harm. However, as warned in the Joint UK NCSC/NCA threat report [25], "The lines between those committing attacks continue to blur, with criminal groups imitating states …… and more advanced actors successfully using 'off the shelf' malware to launch attacks."25) This may pose an increasing threat to food safety as internet activity increases.

## 4.8 The Professional Criminal

Organized crime may see food fraud as a relatively simple crime, with big gains in prospect, little chance of apprehension, and modest penalties if convicted. The global trade in food in which food materials move, often with little notice, across enforcement area borders appears to encourage the professional criminal. The anonymity of the internet and the opportunity for remote intrusion into electronic systems makes cybercrime increasingly attractive to professional criminals. They may be deterred by close collaboration between food operations and national and international police authorities.

## 5 Threat Assessment Critical Control Point (Taccp) 5.1 Broad Themes 5.2 Taccp Process

TACCP should be used by food businesses as part of their broader risk management processes, or as a way of starting to assess risks systematically. TACCP aims to:

•	reduce the likelihood (chance) of a deliberate attack;
•	reduce the consequences (impact) of an attack;
In most cases TACCP should be a team activity, as that is the best way to bring skills, especially people management skills, together. For many small businesses the team approach is not practicable and it may be the job of one person. The TACCP team can and should modify the TACCP process to best meet its needs and adapt it to other threats as necessary to deal with four underlining questions:

•	protect organizational reputation;
a) 	 Who might want to attack us?
•	reassure customers, press and the public that 
b) 	 How might they do it?
proportionate steps are in place to protect food;
c) 	 Where are we vulnerable?
•	satisfy international expectations and support the 
d) 	 How can we stop them?
work of trading partners; and
•	demonstrate that reasonable precautions are taken 
and due diligence is exercised in protecting food.
by, in broad terms:

•	identifying specific threats to the company's business;
The flowchart (see Figure 2) outlines the TACCP process and focuses on deliberate adulteration and contamination. Further information on each element of the TACCP process set out in Figure 2 is given in the corresponding numbered list [see 5.2, 1) - 5.2, 15)].

•	assessing the likelihood of an attack by considering 
the motivation of the prospective attacker, the vulnerability of the process, the opportunity and the capability they have of carrying out the attack and the certainty of information on which the assessment is based;
•	assessing the potential impact by considering the 
consequences of a successful attack;
•	judging the priority to be given to different threats 
by comparing their likelihood and impact;
•	prioritizing threats based on risk, and communicating 
such a prioritization across trading partners for shared risk acceptance;
•	deciding upon proportionate controls needed to 
discourage the attacker and give early notification of an attack; and
•	maintaining information and intelligence systems to 
enable revision of priorities.
Food sector professionals want to minimize the chances of loss of life, ill health, financial loss and damage to business reputation that an attack could cause. TACCP cannot stop individuals or organizations claiming that they have contaminated food, but it can help judge whether that claim is likely to be true. Any such claim, if judged to be credible, and any actual incident should be treated as a crisis. The organization needs to take steps to keep operations running and inform those involved.

A standing TACCP team should be formed, which could include individuals with the following expertise:

•	security; •	human resources; •	food technology; •	process engineering; •	production and operations; •	purchasing and procurement; •	distribution and logistics; •	information technology;
•	communications; and •	commercial/marketing.
NOTE 1 The team may include representatives of key suppliers and customers. 

NOTE 2 For a small organization one person may have to cover all of these roles.

NOTE 3 While the HACCP team might provide a suitable 
starting point, the Business Continuity team might 
be a better model. The TACCP team is typically an 
established and permanent group able to continually 
review its decisions.

10) 	assess the likelihood of routine control procedures 
Since the TACCP process may cover sensitive material and could be of assistance to a prospective attacker, all team members should not only be knowledgeable of actual processes, but also trustworthy, discreet and aware of the implications of the process. The TACCP team should:

11) 	score the likelihood of the threat happening, score 
1) 	 evaluate all new information which has come to its 
attention;
2) 	 identify individuals and/or groups which may 
be a threat to the organization and its systems, especially electronic systems, and assess their motivation, capability and determination; 
3) 	 identify individuals and/or groups which may be 
a threat to the specific operation (e.g. premises, factory, site);
4) 	 differentiate product threats from other threats:
a) 	 for non-product threats, go to Clause 11; b) 	 for product threats, select a product which is 
representative of a particular process;
NOTE 4 For example, a suitable product would be typical of a particular production line and could be one which is more vulnerable.

12) 	where the priority is high, identify who has 
5) 	 identify individuals and/or groups that may want to 
target the specific product; 
6) 	 draw a process flow chart for the product from 
13) 	identify, record confidentially, agree and 
but not limited by, 'farm to fork' including, for example, domestic preparation. The whole flow chart should be visible at one time. Particular attention should be paid to less transparent parts of the supply chain which might merit a subsidiary chart;
7) 	 identify both the vulnerable points where an 
14) 	determine the review and revise arrangements for 
attacker might hope for success and the people who would have access from an examination of each step of the process;

8) 	 identify possible threats appropriate to the product 
at each step and assess the impact that the process may have in mitigating the threats; 
15) 	maintain a routine watch of official and industry 

NOTE 5 Model adulterants include low-cost 
alternative ingredients to premium components; 
model contaminants could include highly toxic 
agents, toxic industrial chemicals, readily available 
noxious materials and inappropriate substances like 
allergens or ethnically unwholesome foodstuffs.

NOTE 6 For example, cleaning may remove the 
contaminant, heat treatment may destroy it, and 
other food components may neutralize it.

9) 	 select the points in the process where the threat 
would have the most effect, and where they might best be detected;
detecting such a threat;

NOTE 7 For example, routine laboratory analysis 
could detect added water or unusual fats and oils; 
effective management of buying would challenge 
unusual purchase orders.

the impact it would have, and chart the results to show the priority it should be given (see 6.3), and revise if this risk assessment seems wrong; 

NOTE 8 Some lateral thinking may be needed. 
The TACCP team might ask, "If we were trying to 
undermine our business, what would be the best 
way?" It may consider how an attacker selects 
attack materials: 

•	availability; •	cost; •	toxicity; •	physical form; and/or •	safety in use, for example pesticides on farms and 
aggressive flavour materials in factories may be convenient contaminants.
unsupervised access to the product or process and whether they are trustworthy, and if that trust can be justified;
implement proportionate preventative action (critical controls). The TACCP team should have a confidential reporting and recording procedure that allows management action on decisions but does not expose weaknesses to those without a need to know (see case studies in Annex A); 

the TACCP evaluation; and

NOTE 9 Review of the TACCP evaluation should 
take place after any alert or annually, and at points 
where new threats emerge or when there are 
changes in good practice.

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. 
NOTE 10 An outline of some information and intelligence systems is given in Annex B.

## 6 Assessment

NOTE The following lists are not intended to be exhaustive of all questions that may be asked to assess a threat.

## 6.1 Evaluating Threats

The product, the premises and the organization and its information systems can be the target of an attack from a range of groups and individuals (see Clause 4), and each element should be assessed separately. The TACCP team should consider suppliers under financial stress, alienated employees and former employees, single issue groups, commercial competitors, media organizations, terrorist organizations, criminals and local pressure groups. Commonly, a short supply chain involving fewer people may be less risky than a longer supply chain. The TACCP team could ask the following questions to evaluate a threat: For the product:

•	Have there been significant cost increases which have 
affected this product?
•	Does this product have particular religious, ethical or 
moral significance for some people?
•	Could this product be used as an ingredient in a wide 
range of popular foods?
•	Does the product contain ingredients or other 
material sourced from overseas?
•	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 low cost substitute materials available? •	Has pressure increased on suppliers' trading margins?
For the premises:

•	Are the premises located in a politically or socially 
sensitive area?
•	Do the premises share access or key services with 
controversial neighbours?
•	Are new recruits, especially agency and seasonal staff, 
appropriately screened?
•	Are services to the premises adequately protected? •	Are external utilities adequately protected?
•	Are hazardous materials, which could be valuable to 
hostile groups, stored on site?
•	Are large numbers of people (including the general 
public) using the location?
•	Do any employees have reason to feel disgruntled or 
show signs of dissatisfaction?
•	Are internal audit arrangements independent?
•	Have key roles been occupied by staff for many years 
with little supervision?
For the organization:

•	Are we under foreign ownership by nations involved 
in international conflict?
•	Do we have a celebrity or high profile chief executive 
or proprietor?

•	Do we have a reputation for having significant links, 
customers, suppliers, etc. with unstable regions of the world? 
•	Are our brands regarded as controversial by some? •	Do we or our customers supply high profile customers 
or events?
•	Is the organization involved with controversial trade? •	Have business competitors been accused of espionage 
or sabotage? 
For the information systems:

•	Does social media chatter suggest that we might be 
the target of digital intrusion?
•	Are our Supervisory Control and Data Acquisition 
(SCADA) and other control systems also used by other organizations which could be prime targets? 
Consideration of responses to these questions can give an understanding of the impact of a successful attack and the likelihood of it taking place. This informs a judgement on the proportionate level of protection required.

## 6.2 Identifying Vulnerabilities

NOTE In this section EMA, malicious contamination and cyber attack are used as examples of approaches to vulnerability assessment.

## 6.2.1 General

Individual organizations have different business needs and operate in different contexts. The TACCP team can judge which approach and questions are appropriate and proportionate to the threats they identify.

## 6.2.2 Economically Motivated Adulteration (Ema)

•	Do any employees bear a grudge against the 
organization?
•	Is staff boredom, discipline, recruitment a problem?

## 6.2.4 Cyber Attack

Questions which the TACCP team may ask include:

•	Has the Board adopted the NCSC's 10 Steps to cyber 
security [27] and established appropriate procedures? (See Annex D)
A typical feature of EMA (see 3.2) is the substitution of a low cost item in place of a relatively high cost component/ingredient. The TACCP team needs to be alert to the availability of such alternatives. An example where this may happen is when added value is claimed, e.g. organic, non-GM, locally grown, free range or with protected designations of origin. The attacker is likely to have ready access to lower value equivalents, which are almost indistinguishable.

•	Are all IT/IS projects subject to an assessment of the 
risk of electronic intrusion?
•	Are colleagues likely to be aware of and to report 
NOTE Further guidance on sources of information and intelligence on the likelihood of food fraud is provided in Annex B.

suspicious electronic communications (e.g. emails, 
SMS)?
•	Is highly sensitive material held on separate, stand 
alone computer systems?
The TACCP team needs to be confident that its own operations and those of its suppliers are in trustworthy hands. This can be achieved using official advice on personnel security.26)

•	Are passwords used securely, and in compliance with 
NCSC guidance?27)
Questions which the TACCP team could ask include:

•	Are policies relating to the handling of electronic 
•	Do you trust your suppliers' managers, and their 
suppliers' managers?
accounts when a member of staff joins, moves or leaves employment effective?
•	Do key suppliers use personnel security practices?
•	Are any locality Wi-Fi links unencrypted or accessible 
•	Do suppliers think that we monitor their operation 
by external users?
and analyse their products?
•	Are manufacturing or other operational systems 
•	Which suppliers are not routinely audited?
interconnected with information technology systems?
•	Are we supplied through remote, obscure chains?
•	Are internet enabled processes secure?  For example, 
•	How do suppliers dispose of excessive amounts of 
could process parameters be changed without proper authority? Could cloud based records be corrupted?
waste materials?
•	Are we aware of shortcuts to the process which could 
•	Are data backup procedures effective?
affect us?
•	Are operators notified and aware of changes to 
•	Are our staff and those of suppliers encouraged to 
production or other operational configuration, for example, to product formulations? 
report concerns (whistleblowing)? 
•	Are accreditation records, certificates of conformance 
•	Can production systems be remotely accessed?
and analyses reports independent?
•	Are essential operations systems segregated from the 
company's corporate network and from the internet? 

## 6.2.3 Malicious Contamination

•	Is externally sourced data (from email, internet or 
Questions which the TACCP team could ask of both its own operations and that of its suppliers include:

removable media) checked for malware before being imported? 
•	Are food safety audits rigorous and up-to-date?
•	Does remote access to company systems require 
•	Are personnel security procedures in use?
multi-factor authentication and is the extent of access limited? 
•	Is access to product restricted to those with a business 
•	Do essential computerised systems have tested, offline 
need?
backups? 
•	Do storage containers have tamper-evident seals?
•	Are business continuity and disaster recovery plans for 
•	Is there opportunity for access by sympathizers of 
IT and production systems in place and effective? 
single issue groups?

## 6.3 Assessment Of Risk

Organizations need to understand the threats that they face, but should focus attention on the priority ones. For each identified threat the TACCP team considers and gives a score for the likelihood of each threat happening and for its impact (see Table 1). 

| Score              |   Impact | Likelihood of threat    |
|--------------------|----------|-------------------------|
| happening          |          |                         |
| Very high chance   |        5 | Catastrophic            |
| High chance        |        4 | Major                   |
| Some chance        |        3 | Significant             |
| May happen         |        2 | Some                    |
| Unlikely to happen |        1 | Minor                   |

NOTE 1 This is an example scoring matrix, organizations may choose their own ranking scheme.

NOTE 2 Likelihood of a threat happening could be judged, for example, over a period of 5 years.

NOTE 3 Impact could consider death or injury, cost, damage to reputation and/or public and media perceptions of these consequences.

NOTE This is an example risk scoring matrix, organizations may choose different criteria for the different risk categories.

The likelihood of a threat happening can be judged by considering:

•	whether an attacker would achieve their aims if 
successful;
•	whether an attacker could have access to the product 
or process;
•	whether an attacker would be deterred by protective 
measures;
•	whether an attacker would prefer other targets; and •	whether an attack would be detected before it had 
any impact.
The impact might be assessed in financial terms or in terms of the seniority of staff needed to deal with it.

The risk score presented by each threat can be shown on a simple chart. An example risk scoring matrix is presented in Figure 3.

## 6.4 Taccp Reporting

Four fictional case studies showing how the TACCP process may be applied and adapted to best meet an individual company's needs are given in Annex A. They are presented as formal records of the TACCP investigation and may be used to demonstrate that the business has taken all reasonable precautions should they be victims of an attack.  

## 7 Critical Controls

NOTE Tables 2, 3 and 4 are not intended to be exhaustive of all controls that may be considered relevant or proportionate to reduce a risk. 

12
Chip & PIN access control

## 7.1 Controlling Access

| 13                          |
|-----------------------------|
| personal clothing from work |
| wear                        |

If a prospective attacker has no access to their target, then that attack cannot take place. It is not possible or desirable to prevent all access, but physical measures may limit access to certain individuals and those with a legitimate need. Some approaches to risk reduction that the TACCP team may feel are proportionate and relevant to their business are listed in Table 2. 

| 14                     |
|------------------------|
| implementation of NCSC |
| guidance [28]          |
| 15                     |
|------------------------|
| external professionals |
| 16                              | Routine training in cyber    |
|---------------------------------|------------------------------|
| security principles (e.g. Cyber |                              |
| Essentials [29] or BS ISO       |                              |
| 27000 series)                   |                              |
| 1                               | Access to people on business |
| only                            |                              |
| 2         |
|-----------|
| perimeter |
By appointment only Proof of identity required
| 3                            | Premises zoned to restrict       |
|------------------------------|----------------------------------|
| access to those with a       |                                  |
| business need                |                                  |
| 19                           | Accompanied throughout           |
| 4                            | Visible and comprehensive        |
| perimeter fencing            |                                  |
| 20                           | Positive identification of staff |
| and visitors                 |                                  |
| 5                            | Perimeter alarm system           |
| 21                           | CCTV monitoring/recording        |
| of sensitive areas           |                                  |
| 6                            | CCTV monitoring/recording        |
| of perimeter vulnerabilities |                                  |
Secure handling of mail
| 7                     | Monitored access points        |
|-----------------------|--------------------------------|
| 8                     | Approach roads traffic-        |
| calmed                |                                |
| 23                    | Restrictions on portable       |
| electronic and camera |                                |
| equipment             |                                |
| 9                     | Scheduled deliveries           |
| 24                    | Limitations on access to       |
| mains services        |                                |
| 10                    | Documentation checked          |
| before admittance     |                                |
| 11                    | Missed deliveries investigated |

## 7.2 Tamper Detection

Much raw material storage, some product storage, most distribution vehicles and all packaged foods can be tamper evident. Should an attacker gain access, tamper evidence gives some chance that the attack may be detected in time to avoid the impact. Some approaches to aspects of tamper evidence that the TACCP team may feel are proportionate and relevant to their business are listed in Table 3. 

Detecting tampering
| 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                         | Reporting of unauthorized       |
| access by cyber systems   |                                 |

## 7.3 Assuring Personnel Security

Personnel security guidance is used to mitigate the insider threat to the organization. Its principles can also be used by food businesses to judge whether key staff within the organizations that supply goods and services can be trusted to comply with specifications and procedures, and to work in the best interest of both the supplier and customer. Some approaches to assuring personnel security that the TACCP team may feel are proportionate and relevant to their business are listed in Table 4. 

NOTE Further guidance on personnel and people 
security is available from: http://www.cpni.gov.uk/
advice/Personnel-security1/ [26]. In particular, food 
businesses may make use of CPNI's publication, Holistic 
Management of Employee Risk (HoMER) [30].

Pre-employment checks
| 1                           | Proof of identity           |
|-----------------------------|-----------------------------|
| 2                           | Proof of qualifications     |
| 3                           | Verification of contractors |
| 4                           | More sensitive roles        |
| identified with appropriate |                             |
| recruitment                 |                             |
| 5                       | Staff in critical roles     |
|-------------------------|-----------------------------|
| motivated and monitored |                             |
| 6                       | Whistleblowing              |
| arrangements            |                             |
| 7                       | Temporary staff supervised  |
| 8                       | Individuals able to work    |
| alone                   |                             |
| 9                       | Favourable security culture |
| 28)                     |                             |
| 10                             |                             |
|--------------------------------|-----------------------------|
| recovered                      |                             |
| 11                             | Computer accounts closed or |
| suspended                      |                             |
| 12                             | Termination interview       |
| assesses security implications |                             |

28) Further information on security culture is available from: 

## 8 Response To An Incident 8.1 Management Of A Food Protection Crisis

Generally, the best time to learn how to manage a crisis is not in the crisis, so advanced planning and rehearsal of procedures is essential.

## 8.2 Management Of A Cyber-Attack

Food protection and defence procedures aim to reduce the risk of an attack but cannot eliminate it, so emergency response and business continuity protocols are essential.

Food protection may sit within a business' crisis management system (see BS 11200), and is likely to share its general objectives:

•	to minimize physical and financial harm to consumers, 
Speed of response can greatly influence the damage caused by a cyber-attack so the maintenance of colleague awareness can be crucial. The complexity and variety of attacks can be so great that selection of a specialist contractor (in advance of the incident) may benefit many organizations.

customers, employees and others;
•	to collaborate with investigatory and enforcement 
authorities (e.g. National Food Crime Unit in the UK);
•	to gain public support for the organization; •	to minimize the cost - financial, reputational and 
Thoughts about cyber incident response are available from CREST (Council of Registered Ethical Security Testers) [32].  Support may also be available from membership of Cyber Security Information Sharing Partnership (CiSP) [33].

personal - of the incident;
•	to prevent re-occurrence; and •	to identify offenders.

## 8.3 Contingency Planning For Recovery From Attack

Where contamination is implicit, quarantine and maybe withdrawal and recall of product might be expected. In cases involving criminal action, police officers from serious crime units should be involved at the earliest opportunity to avoid any loss of evidence.

Business continuity management principles give good resilience to react to and recover from an attack. Advice on how best to develop and implement your organization's recovery in response to a disruptive incident is provided in BS ISO 22313.

NOTE Some examples of police contacts are the National Crime Agency and the Anti-Kidnap and Extortion unit; others are also provided in Annex B.

## 9 Review Of Food Protection Arrangements

Any changes which could affect the TACCP assessment, such as breaches and suspected breaches of security or authenticity, should immediately be reported to the TACCP team leader who decides if a full review is needed. The TACCP team should monitor official websites for updates in national threat assessments and for information on emerging risks (see Annex B). The local situation may be reviewed frequently and briefly against changes to conditions pertaining at the premises. 

A concise report of the review should have only limited circulation. The TACCP team should regularly review food protection arrangements in line with other corporate policies.

NOTE The TACCP report and any review documents are 
commercially sensitive and confidential. Trusted senior 
managers with a 'need to know' and enforcement 
officials require access. Organizations may consider 
publication of a generic overview for internal use and/
or to present to external auditors.  Such an overview 
avoids detail which could be of value to an attacker. 
External auditors are to respect the sensitive nature of 
the TACCP process.

## Annex A (Informative) Taccp Case Studies

•	the Head of Internal Audit holds delegated 
NOTE These case studies are entirely fictitious and any resemblance to real organizations is coincidental.

responsibility for security and fraud prevention;
•	the TACCP team also received contributions from 
other managers on specialist topics; and

## A.1 General

•	this case study makes use of information in the expert 
advisory group report: The lessons to be learned from the 2013 horsemeat incident [34]. 
This annex presents four case studies to illustrate how the TACCP process may be adapted, operated and reported by different organizations to reflect their business situation. They are written as formal records of the risk assessment exercise and do not attempt any background company context. Case study A is a national fast food chain, and case study B is a small enterprise with an owner/manager who handles all strategic and operational matters personally. Case study C and case study D are intended to highlight cyber security issues faced by innovative food businesses. Case study C is a food initiative by an established internet, but not food, operator.  Case study D is a professional food business aiming to exploit digital opportunities. In all cases the TACCP process has been deliberately changed from that described in Clause 5 to encourage users of this PAS to take an open-minded approach.

## A.2 Case Study A

Case study A presents an example report following the investigative work of the TACCP team at Burgers4U, a national fast food chain. The assumptions made are as follows:

•	Burgers4U is a fictitious fast food chain with the 
unique selling proposition (USP) that it makes its own burgers. Nationally it is a major operator but it has no international business;
•	the standard burger is considered to be typical of the 
range: standard, jumbo, veggie, cheese, and chilli;
•	the Operations Director of Burgers4U leads the 
company's Emergency Planning and Business Continuity Committee;

## Taccp Case Study A

Company:	
BURGERS4U
Location:	
All high street retail outlets

Product:	
Standard takeaway burger
TACCP team:	
Operations Director (Chairman)

	
Human Resources Manager

	
Procurement Manager

	
Technical Manager

	
Head of Internal Audit

| Possible method of operation    | Comments                       | No                                   | Threats to company and info-   |
|---------------------------------|--------------------------------|--------------------------------------|--------------------------------|
| systems from:                   |                                |                                      |                                |
| A                               | Animal rights activists        | Vandalism or sabotage                | Little evidence of current     |
| activity                        |                                |                                      |                                |
| B                               | Hacktivists                    | Distributed denial of service (DDOS) |                                |
| attack on website               |                                |                                      |                                |
| C                               | Company buyers                 | Fraud; collusion with suppliers      | Established team working       |
| autonomously                    |                                |                                      |                                |
| D                               | Criminals                      | Counterfeiting; misappropriation     |                                |
| of packaging                    |                                |                                      |                                |
| No                              | Threats to locations from:     | Possible method of operation         | Comments                       |
| E                               | Supporters of local businesses | Adverse publicity; 'Guilt by         |                                |
| association' with fast food     |                                |                                      |                                |
| Petty contamination; possible   |                                |                                      |                                |
| serious malicious contamination |                                |                                      |                                |
| F                               | Overworked company staff,      |                                      |                                |
| disenchantment could lead to    |                                |                                      |                                |
| alliance with extremists (e.g.  |                                |                                      |                                |
| terrorists)                     |                                |                                      |                                |
| G                               | Single issue groups            | Deliberate infestation of premises   | Some recent precedent          |
| H                               | Front line staff               | Theft; collusion with customers      | Rigorous audit in place;       |
| Outlet managers trustworthy     |                                |                                      |                                |
| (personnel security checks)     |                                |                                      |                                |
| No                              | Threats to product from:       | Possible method of operation         | Comments                       |
| I                          | Suppliers of meat             | EMA - non-animal protein, or non-   |
|----------------------------|-------------------------------|-------------------------------------|
| beef meats, replacing meat |                               |                                     |
| J                          | Front line staff              | Deliberate undercooking of patty    |
| collusion                  |                               |                                     |
| K                          | Front line staff              | Selling burger too long after       |
| wrapping                   |                               |                                     |
| L                          | Ideologically motivated group | Malicious contamination of          |
| component                  |                               |                                     |

NOTE Press reports of concerns about food authenticity are pertinent.

Developing company profile may provoke attack
Increasing risk as brand strengthens
Some locations report high levels of press interest
Some staff shortage where there is little post-18 education;
and in locations with an 
extremist reputation
Beef is specified and expected, even though not claimed in publicity
Official threat level unchanged
1 1
May fail 
sensory 
tests
QA/QC
Likelihood
Impact
yeast; may 
affect 
dough 
handling
Impact of 
process
Soluble toxins
May inhibit 
Contamination
- — - — —
Effective 
control of 
access
Contracts 
require 
personnel 
security 
protocols
As above As above
As above As above As above
1 1
Services 
engineers
staff
Bulk storage 
reservoirs
As above
Batch storage 
contamination
Process step
Threat
Vulnerability
Access
Mitigation
Adulterant; 
03
Store water; 
02
Mains water
Malicious 
Step 
no
01A
Select bakery
Various
Casual staff
Production 
01B
Select bakery
Fraud
Collusion
Buyers
Little
- — —
2 3
1 1
May fail 
sensory 
tests
May inhibit 
yeast; may 
affect 
dough 
handling
Powdered 
toxin
Trained 
experienced 
staff
- — - — - — —
Skilled mixer 
operative
Little cost 
advantage to 
fraudster
Batch mixing 
operation
reservoirs
- — - — - — - — —
Fraudulent 
substitution
Malicious 
contamination
- — - — - — - — —
pack buns
+ minor 
ingredients
prove, bake 
buns
adjust 
temperature
Burgers4U
06
Cool, freeze, 
04
Source flour 
05
Mix, divide, 
07
Palletize
- — - — - — - — —
08
Cold storage
- — - — - — - — —
09
Deliver to 
2 3
4 3
2 3
tests may 
detect 
tests may 
detect 
unless 
collusion
tests may 
detect 
unless 
collusion
QA/QC
Likelihood
Impact
Negligible
Random 
Negligible
Random 
Negligible
Random 
Impact of 
process
Meat from 
cheaper 
sources
Meat from 
cheaper 
sources
Meat  from 
cheaper 
sources
Contamination
Unique animal 
identification 
recorded
Process 
management 
& staff
Process 
management 
and staff
Delivery 
drivers; 
process staff
Poor 
segregation 
of species
Poor 
segregation 
of species
Poor 
segregation 
of species
substitution
substitution
Fraudulent 
substitution
Fraud
Collusion
Buyers
Little
- — —
3 5
cutting plant
Process step
Threat
Vulnerability
Access
Mitigation
Adulterant; 
cutting plant
12
Butchery
Fraudulent 
11
Source meat
Fraudulent 
10B
Select abattoir / 
Step 
no
10A
Select abattoir / 
| above          |
|----------------|
| 1              |
| 3              |
| unless         |
| collusion      |
| sensory        |
| tests          |
| Negligible     |
| May fail       |
| Powdered       |
| toxins         |
| Rigorous       |
| hygiene        |
| standards      |
| -              |
| -              |
| -              |
| -              |
| -              |
| -              |
| -              |
| Process        |
| management     |
| & staff        |
| Supplier       |
| responsibility |
| Manual         |
| operation      |
| Hijacking of   |
| consignment    |
| Malicious      |
| contamination  |
| As above       |
| As above       |
| As above       |
| As above       |
| As above       |
| As above       |
| As above       |
| As above       |
| As             |
| As above       |
| As above       |
| As above       |
| As above       |
| As above       |
| As above       |
| As above       |
| As above       |
| As             |
| Burgers4U      |
| seasonings etc |
| mince          |
| batches        |
| 13             |
| Deliver to     |
| 14             |
| Chill storage  |
| -              |
| -              |
| -              |
| -              |
| -              |
| -              |
| -              |
| -              |
| -              |
| 15             |
| Weigh          |
| 16             |
| Weigh meat for |
| 17             |
| Mince patty    |
above
QA/QC
Likelihood
Impact
Impact of 
process
Contamination
Little
- — —
2 4
Agency 
delivery 
drivers
Supplier 
warehouse 
security 
- — - — - — - — —
Misappropriation;
Counterfeiting
Process step
Threat
Vulnerability
Access
Mitigation
Adulterant; 
packaging
24
Source 
Step 
no
18
Form pattys
As above As above
As above As above
As above As above As above As above
As 
19
Freeze pattys
- — - — - — - — —
20
Pack to cases
- — - — - — - — —
21
Palletize
- — - — - — - — —
22
Cold storage
- — - — - — - — —
23
Source 
- — - — —
'Spiked' pattys
Little
None
1 3
brands; 
reliable 
contracts
Tamper 
evident cases
Night storestaff
- —
Established 
Out of hours; 
unsupervised
Ingredient 
substitution
- — - — - — - — —
- — - — - — - — —
- — - — - — - — —
substitution
consumables
garnish
Burgers4U
restaurant
restaurant
25
Source pickle + 
26
Deliver to 
27
Ambient storage
- — - — - — - — —
28
Deliver to 
29
Pick orders
- — - — - — - — —
30
Deliver to 
31
Cold storage
- — - — - — - — —
32
Move to kitchen
Malicious 
QA/QC
Likelihood
Impact
Impact of 
process
- — —
4 1
- — —
2 2
Contamination
- —
None
1 2
cash tills; 
security 
procedures
Rigorous 
food safety 
manufacture
Counter staff
Automated 
—
Personnel 
staff
staff
Restaurant 
manager 
under 
wastage 
pressure
Lone worker
Restaurant 
after wrapping
undercooking
Process step
Threat
Vulnerability
Access
Mitigation
Adulterant; 
38
Receive cash
Theft
Restaurant 
34
Wrap burger
- — - — - — - — —
35
Hot storage
- — - — - — - — —
36
Receive order
- — - — - — - — —
37
Supply order
Selling too long 
33
Prepare burger
Deliberate 
rigorous audit
Public
Daily removal
- — —
1 2
Unlocked 
external bins
Counterfeiting
NOTE The symbol '—' indicates 'not applicable' or 'not significant'.
39
Dispose of waste
Misappropriation;
Internal audit
C:10A
Select abattoir/cutting plant
3 5
C:01B
Fraud; collusion with suppliers
Select bakery
2 3
Job rotation <5 years
DDOS attack on website
Marketing
3
Ensure cyber security good practice 
Description
Vulnerable step
Likelihood
Impact
Protective action
Vandalism or sabotage
All locations
1 2
Maintain vigilance
manager
improvement in security after 6 months
Move to kitchen
1 3
Part used cases to be security sealed by 
Corporate
2 1
Review PR strategy
Source packaging
2 4
Formal notice to supplier; new supplier if no 
Possible serious malicious 
contamination
association' with 'fast food'
packaging
H:38
Theft: collusion with customers
Receive cash
4 1
No further action
G
Deliberate infestation of premises
Restaurants
1 2
Maintain vigilance
F:32
Petty contamination; 
E
Adverse publicity: 'Guilt by 
D:39
Dispose of waste
1 2
No further action
Threat
Description
Vulnerable step
Likelihood
Impact
Protective action
D:23
Counterfeiting; misappropriation of 
standards
audit, regular sampling/ad hoc testing, 
Mains water
1 1
No further action
Supply order
2 2
No further action
Select abattoir/cutting plant
2 3
Stronger management of vendor: technical 
component
wrapping
beef meats, replacing meat
L:15
Weigh seasonings etc.
1 3
Key staff to meet personnel security 
L:05
Mix, divide, prove, bake buns
1 1
L:03
Store water; adjust temperature
1 1
L:02
Malicious contamination of 
K:37
Selling burgers too long after 
J:33
Deliberate undercooking of patty
Prepare burger
1 2
No further action
I:12
Butchery
2 3
facilitate whistleblowing
I:11
Source meat
4 3
I:10B
EMA - non-animal protein, or non-

## A.3 Conclusions

TACCP gave a threat register of 19 threats, of which 9 are under satisfactory control.

The Burgers4U website is not a primary selling instrument but does play a significant marketing role. The Head of Internal Audit is assigned to liaise with the Business Systems Department to ensure proper resourcing of cyber security procedures generally and against denial of service attacks in particular. Advice and tenders for cyber response services may be sought (e.g. from CREST approved suppliers). No reduction in the assessment (3,3) is anticipated.

Fraud in the selection of abattoir/cutting plant is the greatest threat to Burgers4U. On-going cost penalties and significant reputational damage could result. Closely linked are the threats of species or non-meat protein substitution. Within the TACCP team, the Technical Manager is charged with the implementation of protective action with the objective of reducing the threat to (2,3) within 12 months. This action is likely to also mitigate other sourcing threats.

The Technical Manager is to monitor official and industry sources of information and intelligence on emerging risks and decide with the TACCP team chairman whether to reconvene the group in advance of its scheduled 6 monthly routine meeting.

## A.4 Case Study B

As a brand with an increasing reputation for quality and integrity, the threat of counterfeited goods increases. The traditional supplier of printed packaging material does not recognize this and has inadequate physical security procedures in place. As an otherwise reliable partner, the Procurement Manager is tasked with challenging the supplier to remedy the situation or to find an alternative. This threat should be assessed as (1,3) or better within 6 months.

Case study B presents an example threat assessment report of Bridgeshire Cheese Company. It was prepared, alone in the absence of other executive colleagues, by A. Bridgeshire the Managing Partner, and summarizes their individual assessment of the threats it faces. Bridgeshire Cheese Company is a fictitious small familyfarm owned and operated organic cheese producer selling to speciality retailers and food service businesses. Table A.4 represents an example threat assessment report. Figure A.3 represents a vulnerability assessment flowchart.

effluent discharge when 
wind from the SW
conformance for all ad hoc 
purchases
2 1
No further action
3 2
Install reservoir to avoid 
5 2
Require certificate of 
Localized illness 
possible
Loss of herd and/
or insurance 
cover
Loss of organic 
status
All staff 
are family 
members or 
long term 
trusted 
partners;
Biosecurity 
meets best 
practice
All goods from 
accredited 
suppliers
Manual operations, 
unsupervised
(process largely selfcontrolling)
Rights of way 
through farm
'Top-up' milk;
Bought-in calves;
semen B)
contamination
Widespread 
livestock disease
supply
over-reacting 
to 'effluent 
nuisance'
From
Threat
Vulnerability A) 
Mitigation
Consequence
Impact 
Likelihood
Protective action
3
BCC staff
Malicious 
2
Neighbours 
Threat 
no
1
Suppliers
Non-organic 
analysis
Take NCSC advice
modern vehicle at earliest 
opportunity
trade association to lobby 
elected officials
5 1
Maintain separate QC 
2 3
Replace with more 
4 3
Cooperative action with 
Hazardous 
product from 
under-processing 
Loss of 
reputation for 
reliability
Loss of organic 
status
Supplier is reassuring
Little
Value of goods;
Accreditation 
organization 
campaign
All batches are 
taste tested 
Tampering with the 
'Off the Peg' SCADA 
system to reduce 
pasteurization time/
temperature
often unmanned and 
unlocked
Perimeter pasture 
land
on Cloud 
controlled 
production 
process
Theft of product
Distribution, vehicle 
crops
criminals
6
Cyber criminals
Remote attack 
5
Opportunist 
4
Adjacent farms
Trials of GM 

A)  See Figure A.3 for the full vulnerability process assessment.

B)  Other goods are routinely sourced from long-standing accredited companies.

## A.5 Case Study C

FryByNite is a new venture, the national hot food delivery service of a major internet-based general trading company. The company is a world leader in its software and logistics management field, but is new into food business operations. It recognizes its weakness in food and has a consultant food specialist on contract for the duration of the launch and consolidation phases of FryByNite.

FryByNite aims to deliver freshly cooked hot food to customers' doorsteps within 30 minutes of receiving a web or telephone order. The standard product is fish and chips, with each delivery vehicle carrying programmable deep fat fryers. Raw product is ordered over the internet from a network of contracted fast food outlets.  These prepare the food and load it into the frying baskets used by the delivery vehicle. A global positioning system (GPS) estimates the time to customers' premises and initiates the frying process. When ready, the frying baskets withdraw automatically and the food is packaged and kept hot so that the customer receives hot freshly cooked food in better condition than if they had visited the outlet themselves. 

(See Figure A.4)
Example product: Fried fish and chips for home delivery (as typical of the menu)

TACCP Team: Director of Human Resources 
(Chairman) Director of Information Systems Consultant food technologist

Head of security

## Threat Information

NOTE As a new 'brand' FryByNite is covered by holding company risk management and contingency planning procedures. The TACCP therefore addresses operational aspects of the new venture.

## Table A.5 - Threat Information

| No                         | Threat actors           | Threats to company from:   | Possible method of     |
|----------------------------|-------------------------|----------------------------|------------------------|
| operation                  |                         |                            |                        |
| 1                          | Hacktivists             | Failure of web based       |                        |
| ordering system            |                         |                            |                        |
| DDOS attack                | Protected by company-   |                            |                        |
| wide systems and expertise |                         |                            |                        |
| 2                          | Nation states           | Loss of GPS-based          |                        |
| navigation                 |                         |                            |                        |
| Over-commitment and/or     |                         |                            |                        |
| inadequate maintenance by  |                         |                            |                        |
| satellite operators.       |                         |                            |                        |
| 3                          | Extortionists           | Exfiltration of sensitive  |                        |
| data                       |                         |                            |                        |
| Phishing emails to staff   | Ransomware readily      |                            |                        |
| available                  |                         |                            |                        |
| 4                          | Insiders                | Theft of IP                | Unauthorised access to |
| administrative privileges  |                         |                            |                        |
| Threats to product:        |                         |                            |                        |
| 5                          | Aggrieved               |                            |                        |
| suppliers                  |                         |                            |                        |
| Food poisoning             | Inadequate handling of  |                            |                        |
| product                    |                         |                            |                        |
| 6                          | Competitors             | Food poisoning             | Failure of van cooking |
| regime                     |                         |                            |                        |
| 7                          | Aggrieved               |                            |                        |
| staff                      |                         |                            |                        |
| Food poisoning             | Malicious contamination | Personnel security         |                        |
| screening in place         |                         |                            |                        |
| Threats to operations:     |                         |                            |                        |
| 8                          | Criminals               | Attack on vehicle/driver   | Mugging for cash       |
| vehicle" in place          |                         |                            |                        |
| 9                       | Vandals    | Petty damage to vehicle   | Random unplanned            |
|-------------------------|------------|---------------------------|-----------------------------|
| opportunism             |            |                           |                             |
| 10                      | Fraudsters | Loss of income            | Use of stolen personal data |
| to create false account |            |                           |                             |
Comments No control over threat actors but strong contractual protection with operators From power failure, or 
subversion of process controls Riskier areas noted on satnav system 
4 2
2 4
sales; annoyed 
customers
Comment
Likelihood
Impact
loss
—
Nuisance; loss of 
Contaminant
—
Small chance of major 
—
Time waster
1 1
—
1 1
systems give early 
warning
Maintaining close 
links with system 
operators
Check new 
accounts on setup
Close partnership 
with suppliers
Vulnerability
Mitigation
Adulterant/
transfer system is a 
prime cyber target, 
but well protected
point
date
No.
A2
Electronic funds 
B1
Fictitious delivery 
C1
Databases out of 
(2)
account (10)
available
A
DDOS (1)
A1
High - public site
Corporate 
Step
Threat
Threat 
A
Inter-bank failure 
B
Fraudulent 
C
Supplier not 
3 5
1 4
3 2
1 1
food possible
Supplier does not 
know customer 
identity, unless 
collaboration
regulation
place
—
Fire or undercooked 
Toxic chemicals; sporeforming bacteria
—
Contingency plans in 
Trials show 
resilience
Suppliers vetted 
for HACCP 
operation
As C2
Exchange of species
Reputation and 
telecoms 
providers
target
fraud
snags likely
C2
Batter may be 
C3
Opportunistic food 
F1
New technology: 
contamination (5) 
(6) (7)
substitution (5)
control system 
with malware (1) 
(4)
G
Undercooking
G1
Oversized fillets
Size limits
—
Product inedible
1 1
C
Product 
C
Product 
D
GPS failure
D1
Poor signal
Liaison with 
F
Corruption of 
2 4
3 1
2 5
Comment
Likelihood
Impact
inedible
some areas
Toxic chemicals; sporeforming bacteria
Contaminant
—
Compensation if food 
—
A key concern in 
—
Largely nuisance
1 2
—
Reputation damage
1 2
Personnel 
screening
Automatic 
updates of satnav
Staff training in 
conflict avoidance
Riskier areas 
noted on satnav 
system
Replacement 'new 
for old' 
manual operation
Vulnerability
Mitigation
Adulterant/
or roadworks
customers and 
areas.
unsupervised 
during delivery
pressure seeking 
shortcuts
G2
Unsupervised 
No.
H3
Vehicle 
J1
Staff under 
contamination (4)
(9)
disposal of waste 
oil (7)
G
Product 
Step
Threat
Threat 
H
Delays on route
H1
Unexpected traffic 
H
Assault on staff (8)
H2
Some difficult 
H
Damage to vehicle 
J
Inappropriate 
1 4
Issues: labelling; 
allergy; integrity; 
toxicity; fire safety
Other edible oils
Mineral oils
Toxic organic chemicals
Replacement 'new 
for old' 
pressure seeking 
shortcuts or 
covering mistakes
J
Use of wrong oil
J2
Staff under 
| Threat                | Rating    |
|-----------------------|-----------|
| (L,I)                 |           |
| Description           | Further   |
| defensive             |           |
| action                |           |
| F1                    | (3,5)     |
| process control       |           |
| system for fryers     |           |
| Daily review          |           |
| through               |           |
| roll-out and          |           |
| consolidation         |           |
| phases.               |           |
| Build contact         |           |
| with software         |           |
| provider.             |           |
| A1                    | (4,2)     |
| contact.              |           |
| Track social          |           |
| media chatter.        |           |
| H2                    | (2,5)     |
| use of body           |           |
| cameras               |           |
| C3                    | (3,2)     |
| substitution          |           |
| Introduce             |           |
| low level             |           |
| overt product         |           |
| sampling              |           |
| A2                    | (2,4)     |
| transfer failure      |           |
| Continue              |           |
| current               |           |
| protocols.            |           |
| G2                    | (2,4)     |
| contamination         |           |
| Introduce             |           |
| ongoing               |           |
| personnel             |           |
| security              |           |
| routines.             |           |
| H1                    | (3,1)     |
| current               |           |
| protocols.            |           |
| J1                    | (1,2)     |
| disposal of waste oil |           |
| Review and            |           |
| promote 'new          |           |
| for old' model.       |           |
| H3         |
|------------|
| current    |
| protocols. |
| Responsibility            | Comment           |
|---------------------------|-------------------|
| Director of               |                   |
| InfoTech                  |                   |
| Target (2,3) within one   |                   |
| year.                     |                   |
| On-going.                 | Director of       |
| InfoTech                  |                   |
| Threat rating unlikely to |                   |
| change.                   |                   |
| Director of               |                   |
| InfoTech                  |                   |
| With Director of Human    |                   |
| Resources                 |                   |
| Target (1,2)              | Consultant food   |
| technologist              |                   |
| Insurance cover adequate. | Director of       |
| InfoTech                  |                   |
| Target (1,4)              | Director of Human |
| Resources                 |                   |
| Under proportionate       |                   |
| control.                  |                   |
| Director of Human         |                   |
| Resources                 |                   |
| Target (1,1) within one   |                   |
| year.                     |                   |
| Under proportionate       |                   |
| control.                  |                   |
| Threat         | Rating    |
|----------------|-----------|
| (L,I)          |           |
| Description    | Further   |
| defensive      |           |
| action         |           |
| C2             | (1,4)     |
| contamination  |           |
| Include        |           |
| handling of    |           |
| non-food       |           |
| chemicals      |           |
| in supplier    |           |
| accreditation. |           |
| J2             | (1,4)     |
| technology     |           |
| into induction |           |
| training.      |           |
| B1             | (1,1)     |
| account        |           |
| No further     |           |
| action         |           |
| required.      |           |
| C1             | (1,1)     |
| available      |           |
| Review         |           |
| training of    |           |
| database       |           |
| admin.         |           |
| D1             | (1,1)     |
| action         |           |
| required.      |           |
| G1             | (1,1)     |
| product        |           |
| No further     |           |
| action         |           |
| required.      |           |

Commentary
1. 
As a new development the TACCP Team plans to 
meet monthly to review developments.
2. 
In all the Team has identified 15 threats of which seven require substantive protective action.
3. 
Remote control of the frying operation creates the opportunity for new threats (F1) which would receive senior attention and organizational priority.
4. 
Precautions, i.e. appropriate training, from launch of the initiative have kept the likelihood of assault on staff low, but further work is needed.
5. 
The parent company's senior managers continue its policy of avoiding a high profile public image which helps reduce the chance of FbN being a target.

| Responsibility            | Comment             |
|---------------------------|---------------------|
| Consultant food           |                     |
| technologist              |                     |
| Threat rating unlikely to |                     |
| change.                   |                     |
| Director of Human         |                     |
| Resources                 |                     |
| Threat rating unlikely to |                     |
| change.                   |                     |
| -                         | Under proportionate |
| control.                  |                     |
| -                         | Director of Human   |
| Resources                 |                     |
| -                         | Under proportionate |
| control.                  |                     |
| -                         | Under proportionate |
| control.                  |                     |

## A.6 Case Study D

The company has now undertaken a massive move into automation and remote control of both farming and pack-house operations. It is committed to the use of unmanned aerial vehicle (UAV) surveillance of crops to better manage irrigation, application of pesticides, fertilizers and other treatments, and harvesting. It intends to fully integrate chilling, cleaning, trimming and packing of produce. It aims to significantly reduce further the time from field to despatch.

F. Armer & Daughters Ltd is an established agricultural company with an enviable reputation for 'good practice'. The business has evolved and grown from its origins as a mixed family farm supplying its local population with seasonal produce through to its present broad horticultural tariff. The core business is 'fresh as fresh can be' supply of vegetables for retail sale. Some fruit and specialist cereals complement vegetable production. There is increasing interest in supply to food service operations.

As part of this initiative and as it rolls out, the Directors have contracted a consulting information security specialist to conduct a TACCP exercise related specifically to the new information systems. 

Risk management of the conventional business is well established. The intention is that they have proportionate controls in place.

The business is managed on a day-to-day basis by the granddaughters of the farm's founder, the father of the F. Armer who named the company and remains its Chairman. It employs a small team to run the highly mechanised cleaning and packing factory but relies heavily on agricultural contractors for farming work, using temporary staff to cover peak periods. It is committed to external verification of its processes and procedures and receives exemplary reports from accreditation bodies and multiple customers alike. These procedures include an effective approach to risk management.

| Greatest threat from:            | Moderate threat from:      | Lowest threat from:    |
|----------------------------------|----------------------------|------------------------|
| Hacktivists                      | Alienated former employees |                        |
| seeking vengeance                |                            |                        |
| Terrorists seeking publicity     | Environmental campaigners  | Sabotage of IT support |
| infrastructure                   |                            |                        |
| Extortionists                    | Contractors                |                        |
| Criminals stealing innovative IP |                            |                        |
Competitors
Manual entry will 
delay the packing 
operation to an 
unacceptable 
degree
Strong personal 
arrangements with 
buyers so mobile call 
is an expedient
Big variances from 
planned volumes will 
prompt confirmation
Secure, tamperevident housing for 
equipment
Operation can be slow but 
has not failed in 5 years
Intervention by 
unauthorised parties
Disruption to the cleaning/
packing operation leading 
to major waste, product 
shortages and downtime
Failure of telephone 
lines (weather, 
accident, sabotage, 
incompetence)
Data corruption 
during transfer
Malfunction of data 
transfer
System
Threat
Vulnerability
Mitigation
Comment
Likelihood
Impact
ordering from 
customers
ordering from 
customers
processing 
orders for 
pack-house
Threat 
No.
TN1
Electronic 
TN2
Electronic 
TN3
Raising 
Contracted 
hauliers 
unlikely to note 
discrepancies
Both harm caused 
and theft of the 
device could be 
incentives for 
malpractice
Key to 
operational 
practice and 
external 
accreditation
Contracted 
service engineer 
on call 24/7
Routine software 
updates installed
Independent back-up 
daily would reduce 
losses
Updating and 
maintenance is 
rigorous
rejected consignments
Remote control of device 
can be taken over by 
malicious actors
Remote access by Directors 
over the Internet provides 
opportunity for criminals
High cost highly 
sophisticated instruments 
cannot be duplicated, 
so non-operation = nonproduction
Data corruption
Major cost penalties from 
Cameras and 
sensors fail to spot 
emerging problems
Takeover for ransom 
by criminals
Sabotage of 
electronic controls 
loading and 
delivery 
papers 
monitoring of 
crops
farm record 
system
control 
systems
TN4
Raising vehicle 
TN5
UAV 
TN6
Computer 
TN7
Industrial 

## Commentary

1. The company has fully embraced 'totally integrated manufacture' as its path to efficiency and customer service but is not yet fully aware of the vulnerabilities which are implied. The consulting information security specialist has been further contracted to complete the threat assessment and recommend proportionate controls. 2. So far as is practicable, duplicate systems are to be operated until completion of the assessment.

3. Support and advice from ncsc.gov.uk is used to raise awareness among key contractors and trusted staff. 4. Review to take place in one month.

## Annex B (Informative) Sources Of Information And Intelligence About Emerging Risks To Food Supply B.1 General

The World Health Organisation (through INFOSAN) and the Food and Agriculture Organisation (through EMPRES and GIEWS) of the United Nations coordinate global efforts to identify new risks and enact control measures to minimize their impact. 

They disseminate information to national food organizations like the Food Standards Agency in the United Kingdom. These national food organizations can then make it available to food businesses, typically through trade associations, but it really is a 2-way process. NOTE Subscription services which provide helpful information also include:

•	HorizonScan which monitors global food integrity 
issues, see: https://horizon-scan.fera.co.uk/ ; 
•	Food Fraud Database from the US Pharmacopeial 
Convention, see: https://www.foodfraud.org/;
•	US-CERT - United States Computer Readiness Team see 
 
https://www.us-cert.gov/.  

## B.2 Information And Intelligence Levels

Figure B.1 illustrates the global dissemination and exchange of information and intelligence about emerging risks to food which may be used to update TACCP assessments. Five levels may be used to describe different levels of information sharing, 1 being the lowest and 5 being the highest:
Level 1 - Food organization;
Level 2 - Local; Level 3 - National; Level 4 - European; Level 5 - International. 

NOTE Further information on these international sources can be found at the following: INFOSAN http://www.

who.int/foodsafety/areas_work/infosan/en/ [35], EMPRES http://www.fao.org/foodchain/empres-prevention-andearly-warning/en/ [36] and GIEWS http://www.fao.org/giews/english/index.htm [37].

## Annex C (Informative) Complementary Approaches To Food And Drink Protection C.1 Carver+Shock C.2 Eu 5-Point Action Plan

In response to the horse meat fraud in 2013, the European Commission set in place the following 5 point plan [39].

1) 	 Develop synergies between enforcement 
CARVER+Shock is an offensive prioritization tool that has been adapted for use in the American food sector. Like TACCP, CARVER+Shock involves an organization playing 'Red Team', where the team members put themselves in the place of the prospective attacker and ask:

authorities, ensure rapid exchange of information on intentional violations of food chain rules, 
promote the involvement of Europol in 
investigations. 
2) 	 Ensure that rules on horse passports are enforced 
If I wanted to cause harm, or make more money, or gain publicity, or take advantage of the situation in some other way:

•	What would I do? •	Where would I do it?
correctly, that passports are delivered only by competent authorities and that national databases are created. 
•	When would I do it?
3) 	 Require that financial penalties for intentional 
In effect they use the military targeting tool to judge weaknesses by assessing their:

violations of food chain rules be established at sufficiently dissuasive levels, and that control plans in the Member States include unannounced controls. 

Criticality

4) 	 Adopt rules on mandatory origin labelling of meat 

| A   | ccessibility   |
|-----|----------------|
| R   | ecognizability |
| V   | ulnerability   |
| E   | ffect          |

(sheep, goat, pig, poultry, horse, rabbit, etc.) and deliver a report in autumn 2013 on the possible extension of mandatory origin labelling to all types of meat used as ingredient in foods. 

Recoverability

5) 	 Present and assess the results of the controls 
currently carried out in the EU countries. 
More information on CARVER + Shock is available from Carver + Shock Primer [38]. 

## C.3 Uk Food And Drink Federation

The UK Food and Drink Federation's (FDF) Guide on 'Food authenticity: Five steps to help protect your business from food fraud [40], follows on from FDF's guide 'Sustainable Sourcing: Five steps towards managing supply chain risk' [32] and provides information on:

1) 	 mapping your supply chain; 2) 	 identifying impacts, risks and opportunities; 3) 	 assessing and prioritizing your findings; 4) 	 creating a plan of action; and 5) 	 implementing, tracking, reviewing and 
communicating. 

## Annex D (Informative) 10 Steps To Cyber Security: A Board Level Responsibility29)

D.1.3 Pro-active management of the cyber risk at Board level is critical NOTE This annex was developed from source material provided by the National Cyber Security Centre (NCSC).

1) 	 The cyber security risk impacts share value, 

## D.1 Key Questions For Ceos And Boards D.1.1 Protection Of Key Information Assets Is Critical

1) 	 How confident are we that our company's most 
important information is being properly managed 
and is safe from cyber threats?
2) 	 Are we clear that the Board are likely to be key 
targets? 
3) 	 Do we have a full and accurate picture of: 
•	the impact on our company's reputation, share 
price or existence if sensitive internal or customer information held by the company were to be lost or stolen?
•	the impact on the business if our online services 
were disrupted for a short or sustained period?

## D.1.2 Exploring Who Might Compromise Our Information And Why

1) 	 Do we receive regular intelligence from the Chief 
Information Officer/Head of Security on who may be targeting our company, their methods and their motivations?
2) 	 Do we encourage our technical staff to enter 
into information-sharing exchanges with other companies in our sector and/or across the economy 
in order to benchmark, learn from others and help identify emerging threats?
mergers, pricing, reputation, culture, staff, information, process control, brand, technology, and finance. Are we confident that: 
•	we have identified our key information assets 
and thoroughly assessed their vulnerability to 
attack?
•	responsibility for the cyber risk has been allocated 
appropriately? Is it on the risk register?
•	we have a written information security policy in 
place, which is championed by us and supported through regular staff training? Are we confident the entire workforce understands and follows it?

## Bibliography Standards Publications

BS ISO/IEC 27001, Information technology - Security techniques - Information security management systems 
- Requirements For dated references, only the edition cited applies. For undated references, the latest edition of the referenced document (including any amendments) applies.

## Other Standards Risk Management

BS 10501, Guide to implementing procurement fraud controls BIP 2153, Managing risk the ISO 31000 way BS EN ISO 22000, Food safety management systems - 
Requirements for any organization in the food chain BS 31100, Risk management - Code of practice and guidance for the implementation of BS ISO 31000 

## Other Publications And Websites

BS EN 31010, Risk management - Risk assessment techniques BS ISO 31000, Risk management - Principles and guidelines
[1] CODEX ALIMENTARIUS. *CODEX CAC/RCP 1-1969:* 
General principles of food hygiene. Rome: CODEX Alimentarius, 2003.

PD ISO/TR 31004, Risk management - Guidance for the implementation of ISO 31000
[2] NATIONAL CYBER SECURITY CENTRE. Glossary. Available from: https://www.ncsc.gov.uk/glossary [viewed July 2017].

## Crisis Management

BS 11200, Crisis management - Guidance and good practice
[3] FOOD STANDARDS AGENCY. Available from: https:// www.food.gov.uk/enforcement/the-national-foodcrime-unit/what-is-food-crime-and-food-fraud [viewed July 2017].

## Business Continuity Management

BS ISO 22301, Business continuity management systems 
- Requirements and guidance
[4] US Pharmacopeial Convention's Food Fraud Database. Available from: http://www.foodfraud.org/ [viewed July 2017].

BS ISO 22313, Societal security - Business continuity management systems - Guidance
[5] BBC. '*Plastic rice' seized in Nigeria*. BBC, 2016. Available from: http://www.bbc.co.uk/news/worldafrica-38391998 [viewed July 2017].

## Supply Chain Security

BS ISO 28000, Specification for security management systems for the supply chain 
[6] OLIVE OIL TIMES. Italy arrests 33 accused of olive oil fraud. Olive Oil Times, 2017. Available from: https:// www.oliveoiltimes.com/olive-oil-business/italy-arrests- 33-accused-olive-oil-fraud/55364 [viewed July 2017].

BS ISO 28002, Security management systems for the supply chain - Development of resilience in the supply chain - Requirements with guidance for use PD CEN/TR 16412, Supply chain security (SCS) - Good practice guide for small and medium sized operators
[7] OLIVE OIL TIMES. Brazil reveals widespread olive oil fraud. Olive Oil Times, 2017. Available from: https:// www.oliveoiltimes.com/olive-oil-business/brazil-revealswidespread-olive-oil-fraud/56395 [viewed July 2017].

## Information Security

BS ISO/IEC 27000, Information technology - Security techniques - Information security management systems - Overview and vocabulary
[8] EURO WEEKLY NEWS. Police uncover major beef food fraud in Spain. Euro Weekly News, 2017. Available from: https://www.euroweeklynews.com/3.0.15/news/ on-euro-weekly-news/spain-news-in-english/144405-
police-uncover-major-beef-food-fraud-in-spain [viewed July 2017]. 

[17] GILLAM, CAREY. Chinese woman arrested in plot to steal U.S corn technology. Kansas City: Grainews. Available from: http://www.grainews.ca/daily/chinesewoman-arrested-in-plot-to-steal-u-s-corn-technology 
[viewed July 2017].

[9] ANTONY GITONGA. Naivasha Hawkers using formalin to preserve milk. Standard Media. Available from: http://www.standardmedia.co.ke/ article/2000107380/naivasha-hawkers-using-formalin-topreserve-milk [viewed July 2017]. 

[18] THE COUNTERFEIT REPORT. How to identify counterfeit Glen's vodkas. Alexandria, 2014. Available from: http://thecounterfeitreport.com/product/322/ [viewed July 2017]. [19] NEWSCORE. Offshore raids turn up fake Aussie Jacob's Creek wines. Australia, 2011. Available from: http://www.news.com.au/finance/offshoreraids-turn-up-fake-aussie-jacobs-creek-wines/storye6frfm1i-1226029399148 [viewed July 2017].

[10] WORLD HEALTH ORGANIZATION and FOOD AND AGRICULTURE ORGANIZATION OF THE UNITED NATIONS. Toxicological aspects of melamine and cyanuric acid: Report of a WHO expert meeting in collaboration with FAO. WHO and FAO, 2009. Available from: http://www.who.int/foodsafety/fs_management/
Exec_Summary_melamine.pdf, [viewed July 2017]. [11] U.S. PHARMACOPEIAL CONVENTION. Food fraud database version 2.0. Available by subscription from: http://www.foodfraud.org/#/food-fraud-databaseversion-20 , [viewed July 2017].

[20] FINANCIAL FRAUD ACTION UK. Restaurants and diners targeted in new scam. London. Available from: http://www.financialfraudaction.org.uk/cms/assets/1/ scam%20alert%20-%20restaurants%20web%20 link%20doc.pdf [viewed July 2017]. [21] NATIONAL FRAUD AUTHORITY. Annual fraud indicator. National Fraud Authority, 2013. Available from: https://www.gov.uk/government/uploads/system/ uploads/attachment_data/file/206552/nfa-annual-fraudindicator-2013.pdf [viewed July 2017].

[12] FOOD STANDARDS AGENCY. Update on malicious tampering with Kingsmill bread. Food Standards Agency, 2006. Available from: http://webarchive. nationalarchives.gov.uk/20120206100416/http://food. gov.uk/news/newsarchive/2006/dec/kingsmill [viewed July 2017].

[22] SMITH, MATT. Cyber criminals use hacked Deliveroo accounts to order food on victims' cards. DAILY TELEGRAPH, 2016. Available from: https://businessreporter.co.uk/2016/11/23/cyber-criminals-use-hackeddeliveroo-accounts-order-food-victims-cards/ [July 2017].

[13] TOROK, THOMAS J. MD, TAUXE, ROBERT V. MD, MPH, WISE, ROBERT P. MD, MPH; LIVENGOOD, JOHN R MD, SOKOLOW, ROBERT, MAUVAIS, STEVEN, BIRKNESS, KRISTEN A,SKEELS, MICHAEL R PhD, MPH, HORAN, JOHN M MD MPH, FOSTER, LAURENCE R, MD, MPH. 

A large community outbreak of Salmonellosis caused by intentional contamination of restaurant salad bars. 

American Medical Association, 1997. Available from: http://www.cdc.gov/phlp/docs/forensic_epidemiology/ Additional%20Materials/Articles/Torok%20et%20al.pdf [viewed July 2017].

[23] ASSOCIATED PRESS. Michigan-based Biggby Coffee reports database breach, possible theft of customer information. CANADIAN BUSINESS, 2015. Available from: http://www.canadianbusiness.com/business-news/ michigan-based-biggby-coffee-reports-databasebreach-possible-theft-of-customer-information [viewed July 2017].

[14] Q FOOD. Food Tampering: [1989] Glass in baby food. Germany. Available from: http://www.qfood. eu/2014/03/1989-glass-in-baby-food/ [viewed July 2017]. [15] ORR, JAMES. Blackmailer jailed over Tesco bomb threats. The Guardian, 2008. Available from: http:// www.theguardian.com/uk/2008/jan/28/ukcrime [viewed July 2017].

[24] FEDERAL BUREAU OF INVESTIGATION CYBER DIVISION. PIN Number 160331-001 Smart Farming May Increase Cyber Targeting Against US Food and Agriculture Sector 31. March 2016. Available from: https://info.publicintelligence.net/FBI- SmartFarmHacking.pdf [viewed July 2017].

[16] MURRAY, KEVIN D. Electronic eavesdropping & Industrial espionage. New York: Murray Associates. Available from: https://counterespionage. worldsecuresystems.com/tscm-the-missing-businessschool-course.html [viewed July 2017].

[25] NATIONAL CYBER SECURITY CENTRE and NATIONAL CRIME AGENCY. The Cyber Threat to UK Business. Available from: https://www.ncsc.gov.uk/news/ ncsc-and-nca-threat-report-provides-depth-analysisevolving-threat [viewed July 2017].

[26] CENTRE FOR THE PROTECTION OF NATIONAL INFRASTRUCTURE. *Personnel security*. London: CPNI. Available from: http://www.cpni.gov.uk/advice/ Personnel-security1/ [viewed July 2017].

[27] NATIONAL CYBER SECURITY CENTRE. 10 Steps to Cyber Security. NCSC, 2016. Available from: https:// www.ncsc.gov.uk/guidance/10-steps-cyber-security [viewed July 2017]. [28] NATIONAL CYBER SECURITY CENTRE. Password Guidance: Simplifying your approach. Available from: https://www.ncsc.gov.uk/guidance/password-guidancesimplifying-your-approach [viewed July 2017]. [29] HM GOVERNMENT. Cyber Essentials - Protect your business against cyber threats. Available from: https:// www.cyberaware.gov.uk/cyberessentials/ [viewed July 2017]. [30] CENTRE FOR THE PROTECTION OF NATIONAL INFRASTRUCTURE. Holistic management of employment risk (HoMER). London: CPNI, 2012. Available from: http://www.cpni.gov.uk/advice/Personnel-security1/ homer/ [viewed July 2017]. [31] CENTRE FOR THE PROTECTION OF NATIONAL INFRASTRUCTURE. Developing a Security Culture London: CPNI https://www.cpni.gov.uk/developingsecurity-culture [viewed July 2017]. [32] CREST. Available from: http://www.crest-approved. org/ [viewed July 2017]. [33] Cyber Security Information Sharing Partnership (CiSP) Available from https://www.ncsc.gov.uk/cisp [viewed August 2017].

[34] SCOTTISH GOVERNMENT and FOOD STANDARDS AGENCY. Expert advisory group report the lessons to be learned from the 2013 horsemeat incident. 2013. Available from: http://www.scotland.gov.uk/ Resource/0043/00437268.pdf [viewed July 2017]. [35] WORLD HEALTH ORGANIZATION. International Food Safety Authorities Network (INFOSAN). Available from: http://www.who.int/foodsafety/areas_work/ infosan/en/ [viewed July 2017]. [36] FOOD AND AGRICULTURE ORGANIZATION OF THE UNITED NATIONS. *Emergency prevention system* (*EMPRES)*. Available from: http://www.fao.org/ foodchain/empres-prevention-and-early-warning/en/ [viewed July 2017].

[37] GLOBAL INFORMATION AND EARLY WARNING SYSTEM (GIEWS). Available from: http://www.fao.org/ giews/english/index.htm [viewed July 2017].

[38] FOOD AND DRUG ADMINISTRATION. Carver + 
Shock Primer - An overview of the Carver plus Shock 
method for food sector vulnerability assessments. FDA, 2009. Available from: http://www.fda.gov/downloads/ Food/FoodDefense/FoodDefensePrograms/UCM376929. pdf [viewed July 2017].
[39] FOOD AND DRINK FEDERATION. Food authenticity: 
Five steps to help protect your business from food fraud. London: FDF, 2013. Available from: https://www.

fdf.org.uk/food-authenticity.aspx [viewed July 2017].

[40] FOOD AND DRINK FEDERATION. Sustainable 
sourcing: Five steps towards managing supply chain 
risk. London: London: FDF, 2014. Available from: http:// www.fdf.org.uk/sustainable-sourcing.aspx [viewed July 2017].
[41] NATIONAL CYBER SECURITY CENTRE.10 Steps: A board level responsibility. Available from: https://www. ncsc.gov.uk/guidance/10-steps-board-level-responsibility [viewed July 2017]. [42] NATIONAL CYBER SECURITY CENTRE. 10 Steps: A Board Level Responsibility. NCSC, 2016. Available from: https://www.ncsc.gov.uk/guidance/10-steps-board-levelresponsibility [viewed July 2017].

## Further Reading

BRC Global Standard for Food Safety. British Retail Consortium.

BRITISH RETAIL CONSORTIUM (BRC). Cyber Security Toolkit: A Guide for Retailers. Available from: https:// brc.org.uk/media/120731/brc-cyber-security-toolkit_ final.pdf [viewed July 2017]. CENTRE FOR THE PROTECTION OF NATIONAL INFRASTRUCTURE. *Products and services*. Available from: http://www.cpni.gov.uk/advice/ [viewed July 2017]. EUROPEAN COMMISSION. http://ec.europa.eu/ dgs/health_consumer/dyna/consumervoice/create_ cv.cfm?cv_id=891 FOOD STANDARDS AGENCY. Principles for preventing and responding to food incident. FSA, 2007. Available from: http://multimedia.food.gov.uk/multimedia/pdfs/ taskforcefactsheet23mar07.pdf [viewed July 2017]. 

INSTITUTE OF FOOD SCIENCE AND TECHNOLOGY. Good manufacturing practice: A guide to its responsible management. Wiley-Blackwell, 2013.

MI5 THE SECURITY SERVICE. Current threat level in the UK. Available from: www.mi5.gov.uk [viewed July 2017]. NATIONAL CYBER SECURITY CENTRE. *Guidance*. Available from: https://www.ncsc.gov.uk/guidance [viewed July 2017]. WORLD HEALTH ORGANIZATION. Terrorist threats to food. Guidelines for establishing and strengthening prevention and response systems. Food Safety Issues 
(WHO), 2008. INTERPOL. *Operation Opson*. Available from: http:// www.interpol.int/Crime-areas/Trafficking-in-illicitgoods-and-counterfeiting/Operations/Operations/ Operation-Opson [viewed July 2017]. EUROPAL and INTERPOL. Operation Opson III 2013: Targeting counterfeit and substandard foodstuff. Available from: http://www.ipo.gov.uk/ipenforce-opson. pdf [viewed July 2017]. CIO from IDG (International Data Group - Global) 5 steps to respond to a security breach. Available from: https://www.cio.com.au/article/580908/5-steps-respondsecurity-breach/  [viewed August 2017]. CampdenBRI  Guideline 72 TACCP (Threat Assessment and Critical Control Point) - A practical guide.

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