NSF International A Global Leader in Public Health and Safety Food Defense/Food Fraud December 2014
About NSF International NSF International is a global, independent, public health and safety organization. Our mission and focus has always been protecting and improving human health! 2
Bringing Industry, Regulatory and Consumers Together Consumers Industry Media, Educators, Aerospace, Automotive, Building and Consumer Groups Construction, Food, Chemical, Consumer Products, Pharmaceutical, Medical Device, Dietary Supplement, Water Distribution and Treatment, Sustainability. Regula ulator ors USDA, EPA, FDA, CPHC, HC, and International, National, State, Local Government Agencies 3
Our Discussion Today • Food Defense and How it started • What you must do • Current Practices • Food Frauds : Expanding the Umbrella of Coverage • How is it different and Similar to Food Defense • Future Model
Origin of Food Defense • In 2002 : WHO published Terrorists Threat to food which provided guidance on intentional adulteration. • In 2008 : WHO published Guidelines for Strengthening Response systems. • In 2010 : US Congress passed FSMA which requires in Section 106 for establishments to conduct Vulnerability assessment studies for protection against Intentional Adulteration. • FDA has recently issued proposed regulations to satisfy the FSMA statutory Mandates
Food Defense vs Food Safety • Food Safety assessments are based on unintentional introduction of Hazards • Food Defense assessments are based on how vulnerable you are: Are your frontiers open ? – Suppliers – Operations – Teams/Management – Facility • VACCP -Vulnerability Assessment Critical Control Points • TACCP -Threat Assessment Critical Control Points
Food Defense vs Food Safety • Food Defense is used to asses unknown risks - when the fight is with unknown such as willful adulteration / contamination Vs • Food Safety is managing risks due to accidental contamination( due to lapses ) • Food Safety lapses may have a severity of impact on health and occasional loss of life Vs • Food Defense lapses will lead to large losses of lives
Food Defense Assessment--Role of Management • Develop a Product Defense plan and Mechanism – A team should evaluate the risk and implement controls on identified risks – Put in control measure • Raw material Isolation for non conforming products • Computer back ups/authorized usage • Off site warehouses and other locations assessments • Reporting unusual occurrences • Annual Review must suggested-Quarterly • Compliance checks
Food Defense Assessment - Human Element • Documented policies for visitors and contractors • Effective training and screening of new hires and suppliers • Defined responsibility matrices • Access controls and Area Controls • No Bypassing the system
Food Defense Assessment - Facility • Data loggers and time sheet for product movements • Fencing,Gates,Lights • Secured equipment and resources • Off site facilities security • Suspicious activity investigated
Food Defense Assessment - Operations • All aspects of facility operations evaluated for vulnerability to tampering and sabotage. • Identified sensitive production and storage areas/conditions must have control measures addressing each potential risk. • Public storage warehousing and shipping companies should be required to verify product Defense measures.
International Case Studies Press coverage can be related to the scale of the customer and not any real health risks
Brand Value and Investment • Major global branded businesses invest heavily in their brands • Advertising and marketing spend is only part of the total investment • Time and effort spent by management and staff doing things right over many years is also investment in the brand • The true value of the brand can outweigh capital investment in plant and machinery
UK Horse Meat in Burgers – pushing suppliers too far? Now Asda and Co-op are dragged into horsemeat-contaminated beef burger scandal as they admit to DNA discoveries in products London, Jan 30: Tesco, Britain’s biggest supermarket chain, today announced that it has dropped the supplier at the centre of its horse burger scandal over a “breach of trust“. The retailer has dropped Silvercrest, part of the ABP Food Group, as a supplier, saying the “breach of trust [was] simply too great“. The supermarket giant’s technical director Tim Smith said new DNA testing would be introduced for all of its meat products to avoid similar mistakes happening again.
China Milk Industry – Long Term Impact Tourist gift shop in Hong Kong catering to Mainland China customers ….. And restrictions on how much milk formula travelers can take into China
OSI Meat Shanghai – too much trust in suppliers? Experts say the fallout with OSI has taught companies to take a more proactive role in operational management. "Key lesson here is if you're a foreign company and you set up operations in China, you have to manage the operations," said Ben Cavender, a senior analyst at China Market Research Group. Food companies have to play close attention to what their operations and partners are doing to maintain standards, Mr. Cavender said.
Current Trends • Today the more worried trend is of Food Fraud. • Food fraud is used to describe a range of deliberate and intentional activity of : adulteration or tampering of food • Economically motivated adulteration (EMA) is the most commonly used term as adulteration is the primary fraud.
• Food Fraud and Food Defense measures are similar as they both seek to prevent intentional food adulteration • Defense focuses on terrorists and Fraud concentrates on people motivated by economic gain. • Food Fraudsters intend to make higher profit and not cause willful harm but like terrorists end up causing harm
Future • Consider risks from fraud and deliberate contamination • Extend „upstream‟ to pack houses, farms • Consider inspection at source • Remote auditing • Self audits
The NSF „Outsmart‟ Model An outline framework and model has been developed to identify key areas of risk within any company‟s product base and supply chain. For those products and raw materials identified to be high risk, mitigation plans need to be developed with the commercial and technical teams at both strategic and tactical levels. High Profit 6 Ease 5 4 High Low Likelihood Likelihood 3 of Detection of Detection 2 1 Low Profit 21 1 2 3 4 5 6
Food Fraud Awareness, Detection & Prevention Solution is a complex commercial & supply chain issue and is not something that can be solved by “Technical teams” in isolation. Assess Culture Use ‘Outsmart’ to across commercial identify high risk & technical product areas & functions likely forms of fraud Buying Understanding Behaviour ‘Product’ commercial exposure Work with supplier base drivers & KPIs to develop long term sustainable trusted relationships Supply Chain controls & management Risk Assessment Detailed specifications sampling, testing with testing criteria and forensic accounting 22
Managing Fraud and Defense with Food Safety Take Customer Complaints Seriously Commercial Plus Food Safety Audit Supplier audits Sampling & Testing Food Safety Plan to include Food Defense Food Fraud
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