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!

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Bringing Industry, Regulatory and Consumers Together

USDA, EPA, FDA, CPHC,

HC, and International,

National, State, Local

Government Agencies

Aerospace, Automotive, Building and

Construction, Food, Chemical,

Consumer Products, Pharmaceutical,

Medical Device, Dietary Supplement,

Water Distribution and Treatment,

Sustainability.

Media, Educators,

Consumer Groups

Consumers

Regulators

Industry

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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?

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.

Now Asda and Co-op are dragged into horsemeat-contaminated beef burger scandal as they admit to DNA discoveries in products

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.

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Ease

Low

Likelihood

of Detection

High

Likelihood

of Detection

Low Profit

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6

5

4

3

2

1

High Profit

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.

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Buying Behaviour

commercial drivers & KPIs

Supply Chain controls & management

Understanding ‘Product’ exposure

Assess Culture across commercial

& technical functions

Use ‘Outsmart’ to identify high risk product areas & likely forms of

fraud

Risk Assessment sampling, testing

and forensic accounting

Work with supplier base to develop long term sustainable trusted

relationships

Detailed specifications with testing criteria

Managing Fraud and Defense with Food Safety

Food Safety Plan to include

Food Defense

Food Fraud

Sampling & Testing

Supplier audits

Commercial Plus Food Safety Audit

Take Customer Complaints Seriously