The Value of Food Defence
Sadly, the importance of having a food defence plan was first reinforced after the 9/11 terrorist attacks in the USA. It was considered that food businesses were one of the most vulnerable access points with regard to intentional adulteration. It is a common mistake to consider food defence as a synonym of food safety. The two are just co-dependent.
The food safety term was first used in 1974 at the World Food Summit to make reference to access of food in sufficient quality and at a stable cost. The nutritional value of food products and their safety for human consumption was not formally endorsed until 1996 when the term food safety clearly defined as follows:
“Food Safety exists when all people, at all times, have physical and economical access to sufficient safe and nutritious food that meets their dietary needs and food preference for an active and healthy life” (World Food Summit, 1996)
The difference between food defence and food safety lies in the intentionality act. In 2001 the USDA (United States Agriculture Department) Food Safety and Inspection Service defined food defence as “the protection of food products from contamination or adulteration intended to cause public health harm or economic disruption”.
When talking about food defence we refer to activities of sabotage, bioterrorism or vandalism, however food fraud, must be also taken into account within this term.
The concept “Food Defence” completes the “Food Safety” term to provide confidence to the public about the safety of the products consumed as well as the measures implemented within food industries to prevent, control, identify, evaluate, reduce and eliminate possible hazards associated to intentional or unintentional contamination throughout the food supply chain.
Is a HACCP plan enough to protect a business?
The implementation of a HACCP plan does not involve the prevention of intentional contamination within the food supply chain. HACCP is based on the identification of unintentional physical, chemical and biological hazards that are important for the production of safe food.
Therefore, the food defence plan complements the HACCP plan, as one of them prevents the unintentional hazards and the other controls the intentional acts.
Is there any regulation that mandates having a plan to avoid food terrorism?
Nowadays, only companies in the food and beverage industry that wants to import and/or export their products to the USA, will have to comply with the requirements set-forth in the Food Safety Modernization Act signed into law in 2011 and the Bioterrorism Act of 2002.
In any other country, there is not a specific regulation for food defence. This was exactly the reason why at the 2016 Food Defence Conference, presented by the Food Protection and Defence Institute (FPDI), it was clearly highlighted the need for further investigation on this subject and the importance of increasing awareness within the food industry and of the consumers.
Only private food defence requirements have been recently added to some private food standards such as IFS and BRC in their latest versions, issues 6 and 7 respectively.
The food defence requirements are considered in chapter 6 of the IFS standard. This section specifies elements such as its evaluation, safety of the facility safety of staff and visitors and all essential aspects to ensure the prevention of intentional contamination.
This standard gives importance to training of staff, identification of critical areas for safety, checking the effectiveness of alerts on a regular basis, access control of suppliers, visitors and external personnel and also measures to prevent unauthorized access.
BRC issue 7 includes the requirements of food defence in chapter 4 “site standards”. The standard requires the evaluation of the implemented safety measures, related with the potential risks of intentional food contamination. Likewise, it specifies that these measures must be related to the risks that occur in each area, as well as restricting access to unauthorized personnel to certain identified as sensitive areas, and establishing preventive actions to block access to pipes and external storage.
The latest version 4 of FSSC 22000 has also aligned its specifications with other GFSI (Global Food Safety Initiative) approved standards. The requirements for controlling intentional hazards have been reinforced and added to different sections. The additional requirements have been extended and include now the following specifications with regard to food defence and food fraud:
184.108.40.206 Food defence
220.127.116.11.1 Threat assessment
1) The organization shall document, establish and maintain a documented procedure for food defence threat assessment that:
- a) identifies potential threats,
- b) develops preventive measures, and
- c) prioritises them against the threats.
2) In order to identify the threats, the organization shall assess the susceptibility of its products to potential acts of:
- a) sabotage,
- b) vandalism, and/or
- c) terrorism
18.104.22.168 Food Fraud prevention
22.214.171.124.1 Vulnerability assessment
1) The organization shall document, establish and maintain a documented procedure for food fraud vulnerability assessment that:
- a) identifies potential vulnerabilities,
- b) develops preventive measures, and
- c) prioritises them against the vulnerabilities.
2) In order to identify the vulnerabilities, the organization shall assess the susceptibility of its products to potential acts of food fraud.”
Section 5.7 of ISO 22000 and chapter 18 of the technical specification ISO/TS 22002-1, indicate also the need to establish a procedure or as many procedures as needed to manage emergency situations that have an impact in food safety.
Unlike other food safety standards, FSSC 22000 (I think is better to leave unifies, cause I want to say this standard checks all the hazards together whereas others check every hazard individually) identifies the requirements to prevent sabotage, vandalism and terrorism, but in other systems we can see them treated independently.
What are the benefits of implementation?
The implementation of a food defence plan will bring a number of improvements to the company:
- The risk of contamination from any source, intentional and unintentional, is reduced
- Assure safe food to customers and improving our position within the market
- Protect the integrity of the employees and products
- Cost savings and increase the opportunity of short/medium term investment
- An emergency action plan will be in place and therefore an immediate response would be offered
How to create a food defence plan?
Apart from the specific requirements that some food safety standards require to put in place, every business will gain a number of benefits when implementing a food defence plan within the company:
Step 1 - Assess the vulnerability of the business. Evaluate what may impact each of the steps of the production process from outside the company and also within the premises. The severity and probability must be assessed to confirm the impact that the identified hazard may have on consumer health.
Step 2 - Determine the control measures that will be established to reduce the risk of intentional hazards.
Step 3 - Ensure that the implementation of controls and continuous checks to verify their effectiveness.
In order to verify the effectiveness of this programme, there should be a designated person or team to control all the implemented measures within the business. You will need to plan an annual review and also check the implemented programme every time there is a change within the process (including new clients, suppliers, equipment, etc.), carry out an annual mock activity and adequate review of personnel training.
To sum up, it shows that the food and beverage sector is vulnerable to intentional adulteration, so food businesses should establish risks management procedures through the implementation of a food defence programme integrated into the food safety management system.