From intentional contamination and economic fraud to terrorism and global climate change, the world’s food supply appears to becoming increasingly insecure. This is despite record-high levels of food production in many countries and heightened levels of international cooperation to keep production and distribution chains secure. Many experts believe the situation is unlikely to improve anytime soon, as the global food chain becomes longer and more complex and threats—both man-made and natural—continue.
“The potential of food-based pandemics or the spread of toxic elements in an increasingly globally integrated food chain raises major concerns,” concludes the World Economic Forum’s latest report on global risks, which places “food crises” as among the 10 highest concern risks in 2014. “The global food supply is only as strong as its weakest link, and you’ve got a lot of food products coming into the U.S. from overseas,” adds Don Hsieh, director of commercial and industrial marketing, Tyco Integrated Security. “There is a heightened awareness within the food industry of the need to put controls in place before something happens. It is more important to prevent problems than to react to them afterwards.”
In years past, “food security” referred primarily to the adequate supply of and access to food. The concept has since been expanded to preventing intentional contamination or adulteration from such illegal actions as economic fraud, sabotage, and, especially since 9-11, terrorism. “The goal is to protect the food supply from those who may attempt to cause large-scale public health harm,” says Michael R. Taylor, JD, FDA deputy commissioner for foods and veterinary medicine. “Such events, while unlikely to occur, must be taken seriously because they have the potential to cause serious public health and economic consequences.”
Currently front and center of the nation’s food defense efforts is FDA’s proposed rule on protecting food from intentional adulteration by acts of terrorism—one of half the dozen major regulations required by the Food Safety Modernization Act (FSMA). The proposed rule, “Focused Mitigation Strategies to Protect Food Against Intentional Adulteration,” was published on Dec. 24, 2013. The public comment period was extended to June 30, 2014 and FDA is required to post the final rule by May 31, 2016.
The regulation would require all domestic and foreign food facilities that register under Section 415 of the FD&C Act to review their production systems for any of four activities considered most vulnerable to intentional adulteration: bulk liquid receiving and loading; liquid storage and handling; secondary ingredient handling; and mixing and similar activities. Companies must identify actionable steps or procedures that require mitigation strategies and prepare and implement a written food defense plan. They would also need to conduct training, take and monitor corrective actions, and keep records documenting their activities. Large companies would need to comply within one year after final publication while small businesses (fewer than 500 employees) would have two years. Very small business (less than $10 million in total annual sales) would have three years to comply or could be exempt along with farms, transportation carriers, facilities that hold food (except in liquid storage tanks), and facilities that pack, repackage, or label food products.
While one might think that it would be more challenging for larger companies to comply, the opposite is more likely. “The vulnerability is especially for small- to mid-sized producers because they may not have the discipline or the resources that the larger companies have to put the necessary plans and processes in place,” says Tyco’s Hsieh. Typically, larger companies have been more concerned about protecting consumers and therefore their brands. “For the most part they are probably better-equipped to address the regulatory requirements and probably will exceed them,” Hsieh says. “The smaller companies may not be as rigorous in preventive controls and, thus, they may be the ones putting the whole supply chain at risk,” he tells Food Quality & Safety.
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