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.”
Intentional Adulteration
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.
For many industry experts, the proposed rule doesn’t go far enough because it ties intentional adulteration only to acts of terrorism, which may be relatively rare, and not to economically motivated adulteration (EMA), such as food fraud, counterfeiting, or acts of disgruntled employees, all of which are more likely to occur and may also result in injury or death. For example, in 2008 dairy processors in China added melamine to milk and infant formula to artificially inflate laboratory protein measurements and conceal dilution. The adulteration killed several children and sickened thousands more. Disgruntled employees can also adulterate foods during production and shipping while malicious consumers can tamper with foods on shelves.
The FDA does not consider intentional adulteration by disgruntled employees, competitors, or consumers to be of “high risk” because, it says, such acts are not intended to cause widespread public health harm. The agency does plan to address EMA in a preventive controls framework where it is “reasonably likely to occur.” Not everyone agrees. “Each of these motivations, regardless of intent, takes advantage of a vulnerable point in our food supply and can cause catastrophic health effects,” argues Amy Kircher, DrPH, director of the National Center for Food Protection and Defense. She recommends a supply chain focus for food defense that identifies and closes gaps wherever they exist, such as during transportation. “Using a supply chain approach allows companies to cost effectively target their food defense efforts,” Dr. Kircher says.
On the other hand, the Association of Food and Drug Officials (AFDO) supports the exclusion of economically motivated adulteration from the rule because “it is fundamentally different than intentionally introduced contamination that is intended to produce great public health harm.” But AFDO believes that seafood and juice facilities, which carry their own Hazard Analysis and Critical Control Points (HACCP) imposed restrictions, should not be exempt from economically motivated adulteration, as the agency currently proposes. AFDO is also concerned that imported food products will not be held to the same standards as domestic products, and that the domestic industry will be thus placed at an unfair disadvantage. “Import rules and inspection and compliance programs must ensure parity and consistency between domestic and foreign facilities,” it argued in its submitted comments.
Fighting Fraud in the U.K.
The U.K., which last year was rocked by revelations of widespread adulteration of beef with horsemeat, may be adopting a different approach to combatting intentional adulteration—creating a national crime unit. Last year, up to half the samples of packaged ground beef sold in U.K. supermarkets were found to contain horsemeat. In a comprehensive report released in September 2014, Chris Elliott, professor of food safety and director of the Institute for Global Food Security at Queen’s University Belfast, concluded that while the U.K. has one of the world’s safest food systems, organized criminal gangs were “adulterating, tampering, stealing, and counterfeiting” food. Among the report’s recommendations: creation of Food Crime Unit within the Food Standards Agency (Britain’s counterpart to the FDA) to counter the growing problem of food fraud.
“Food fraud becomes food crime when it no longer involves a few random acts by ‘rogues’ within the food industry but becomes an organized activity perpetrated by groups who knowingly set out to deceive and/or injure those purchasing a food product,” the Elliott report says. “Food crime is a global problem, growing in scale,” the report explains. While the extent of the fraud is unknown, “what we do know is that it can be a cause of major food safety risks which severely undermines consumer trust in the food industry,” says David Richardson, a vice president at NSF International. A food crime unit could cost upwards of $6 million, and the British government is evaluating the recommendation.
Criminology is useful for examining events and perpetrators but is only one prong of a multidisciplinary approach needed to counter food fraud, says Doug Moyer, PhD, a food packaging expert at Michigan State University. Other strategies should include food science, packaging science, and supply chain management or logistics. Packaging science can provide anti-counterfeiting security features and enable track-and-trace pedigrees in addition to protecting food and conveying product information. Knowing the source and history of foods is important because “fraudsters perpetuate their crimes through vulnerabilities in food supply chains,” Moyer told the Food Safety Summit in Baltimore earlier this year. “End-to-end visibility and supply chain transparency are critical management tools for brand owners,” he added.
If food exporting countries had comprehensive food traceability systems in place, it would be easier to track points where adulteration and fraud entered the food chain. A study published in the September 2014 Comprehensive Reviews in Food Science and Food Safety compared food traceability regulations and requirements of 21 OECD (Organization for Economic Cooperation and Development) countries. Conducted by the Global Food Traceability Center at the Institute of Food Technologists, the study examined whether mandatory traceability regulations existed at each country’s national level; whether regulations included imported products and the nature of the regulations; whether electronic databases for traceability existed and if so, their accessibility; and whether labeling regulations allowed consumer access to and an understanding of traceability.
The study found that European Union countries including the U.K. had overall “superior” scores for food and feed traceability regulations while the U.S., Canada, Australia, Japan, Brazil, and New Zealand had overall “average” scores. Unsurprisingly, China received a “poor” overall score, and there were insufficient data to grade Russia. The authors said the study highlights the importance of harmonizing traceability requirements to minimize delays, strengthen interoperability, “and to improve traceability of food products globally.”
Packaging science can provide anti-counterfeiting security features and enable track-and-trace pedigrees in addition to protecting food and conveying product information.
GFSI Tackles Food Fraud
The Global Food Safety Initiative (GFSI) last year directed its Guidance Document Working Group and Food Fraud Think Tank to develop recommendations in response to the growing prevalence of food fraud. In July 2014, GFSI released a guidance document carrying the following two major recommendations.
- The food industry should carry out a “food fraud vulnerability assessment” in which information is collected at appropriate points along the supply chain (including raw materials, ingredients, products, and packaging) and evaluated to identify and prioritize significant vulnerabilities for food fraud.
- Appropriate control measures should be put in place to reduce the risks of these vulnerabilities. Control measures can include strategies for monitoring, testing, origin verification, specification management, supplier audits, and anti-counterfeiting technologies. “A clearly documented control plan outlines when, where, and how to mitigate fraudulent activities,” the GFSI document says.
The new requirements will be included in the next full revision of GFSI’s Guidance Document 7th Edition, to be released in early 2016. “This represents yet another example of global collaboration and standards setting” that is essential for ensuring food security, says Melanie Neumann, vice president and chief financial officer, The Acheson Group.
The Role of Climate Change
While the science behind and implications of climate change continue to be debated, numerous U.S. and international agencies, public organizations, and private companies are exploring the ramifications of climate change on food security, meaning the adequate supply of and access to food. “Climate change poses a major challenge to U.S. agriculture because of the critical dependence of the agricultural system on climate and because of the complex role agriculture plays in social and economic systems,” concludes the federal government’s latest National Climate Assessment report, released in May 2014. Climate change will alter the stability of food supplies and create new food security challenges for the U.S. as the world seeks to feed nine billion people by 2050, the report says.
Agricultural productivity is vulnerable to direct impacts on crop and livestock development and yield from changing climate conditions and extreme weather events, and indirect impacts through increasing pressures from pests and pathogens, the report says. Rising temperatures also affect food safety; for every degree the ambient temperature rises above 43 degrees Fahrenheit in an area, the occurrence of foodborne Salmonella increases by 12 percent. Rising air temperatures also result in corresponding increases in insects, weeds, and fungal pests due to milder winter temperatures. One possible result is growers may need to increase pesticide use to maintain production levels.
In a recently published study of pesticide applications of commercial soybeans grown in a band from Minnesota to Louisiana since 1999, scientists at the USDA’s Agricultural Research Service (ARS) concluded that increases in total pesticide applications were positively correlated with increases in minimum winter temperatures. In temperate regions, low winter temperatures often keep the distribution and survival of agricultural pests in check. “One of our most crucial challenges is finding ways to maintain and increase crop production levels in the face of climate change,” says ARS administrator Chavonda Jacobs-Young.
Until now, the U.S. agricultural sector has managed to adapt to climate change through a variety of strategies, the federal report says. “However, the magnitude of climate change projected for this century and beyond, particularly under higher emissions scenarios, will challenge the ability of the agriculture sector to continue to successfully adapt,” it warns. As part of its Climate Action Plan, the Obama administration in July 2014 unveiled a program aimed at strengthening the resilience of the global food system in a changing climate. The White House called upon the private sector “to leverage open government data and other resources to build tools that will make the U.S. and global food systems more resilient against the impacts of climate change.” In response, a number of federal agencies and private companies will be collaborating on “data-driven innovations.” Some examples include the following.
AFDO is also concerned that imported food products will not be held to the same standards as domestic products, and that the domestic industry will be thus placed at an unfair disadvantage.
Microsoft and USDA will jointly launch a climate-change-focused “Innovation Challenge” to inspire the development of new tools and services that harness data available via the federal website www.data.gov, as well as an initial collection of USDA datasets that will be made available through Microsoft’s Azure Marketplace.
The Coca-Cola Company will use data-driven tools to quantify its use of water, fertilizer, and energy, and monitor its greenhouse emissions. By the end of 2014, Coca-Cola will implement this initiative with two of its four leading suppliers; by the end of 2015, it will engage the initiative with farmers representing 250,000 acres; and by 2020, with farmers representing up to 1 million acres—equating to roughly half of the company’s global corn supply.
Nestlé will set greenhouse-gas reduction targets based upon science, incorporating both absolute-carbon and carbon-intensity aspects. The company will also incorporate climate change provisions into its responsible sourcing and traceability program, engage in further water stewardship programs, and extend education and training within its Farmer Connect initiative for good farming practices and water stewardship.
Monsanto will donate a multi-site/multi-year maize breeding trial dataset to open data portals maintained by the International Center for Tropical Agriculture and the Agricultural Model Intercomparison & Improvement Project. Opening these data will make it possible for public- and private-sector scientists to improve models being used to understand how climate and water-availability changes will impact crop productivity and food security.
Kellogg Company will use the University of Minnesota’s Institute on the Environment agricultural data and climate-related maps to foster geographically relevant implementation in its global sourcing to help create efficient, adaptable, and sustainable supply chains as well as identify information gaps and needs to improve the resilience of the agricultural sector to climate change.
What Companies Should Do Now
In regards to the matter of U.S. food safety and security, companies should not wait until the FDA issues the final intentional adulteration rule before acting because many control measures can be put in place now. “Look at your vulnerabilities and assess where the gaps are,” Hsieh recommends. “For instance, mixing areas have been identified as places needing access controls. Start to create your food defense plans now, ahead of the final regulations. In the end, it’s not about regulations but about protecting the consumer and your company’s reputation. You don’t want to be the one that’s been closed down because of a tragedy,” Hsieh says.
Agres is a freelance writer based in Laurel, Md. Reach him at [email protected].
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