Food Defence System in Food Industry: Perspective of the EU Countries

J. Verbr. Lebensm. Journal fu¨ r Verbraucherschutz und Lebensmittelsicherheit DOI 10.1007/s00003-016-1022-8 Journal of Consumer Protection and Food Safety

REVIEW ARTICLE

Food defence system in food industry: perspective of the EU countries

1 2 3 Nina Puhacˇ Bogadi • Mara Banovic´ • Ivona Babic´

Received: 19 November 2015 / Accepted: 11 March 2016 Ó Bundesamt fu¨r Verbraucherschutz und Lebensmittelsicherheit (BVL) 2016

Abstract Nowadays, incidents related to intentional Keywords Food defence Á Food safety Á contamination of food products are a huge problem Risk assessment Á Intentional contamination Á in the whole food supply chain. Therefore, it is nec- Food industry essary to raise awareness of food defence at every level of the food chain, from farm to fork, from 1 Introduction government and academic institutions to retail chains, the media and consumers. The principles of Food defence in the European food industry is a food defence can be implemented at every level of rather new concept in many EU countries as opposed the food chain. Food defence contributes to the to the USA where the concept of food defence origi- mitigation of potential risks in intentional contaminated. It was officially defined by the Public Health nation and food fraud, which can have a harmful Security and Bioterrorism Preparedness and effect on humans and public health, business, econ- Response Act of 2002 (Bioterrorism Act 2002), which omy, etc. The requirement for the implementation of was adopted after the terrorist attack on September food defence comes from retail chains. They require 11th 2001. The primary objective of the Bioterrorism food companies to be certified according to the act is the protection of food supply from intentional standards of the food safety system such as those contamination. There are several definitions of food supported by the Global Food Safety Initiative. defence. In this article, food defence is explained by Although food defence is an inevitable step in using following definitions: enhancing and strengthening the whole food safety 1. According to the Food and Drug Administration system, on a global scale, an insufficient number of (FDA), the term food defence is the effort to protect countries have incorporated food defence principles food from intentional acts of adulteration in cases into their legal frameworks. The intention of this where there is an intention to cause large-scale review article is to increase awareness of food public health harm and economic disruption. defence in food industry. Acts of intentional adulteration may take several forms like: acts of terrorism, acts of disgruntled employees, consumers, or competitors as well as & Nina Puhacˇ Bogadi economically motivated adulteration. The term [email protected] food defence applies to the sum of actions and activities including Food defence measures taken 1 Podravka Inc., Food Industry, A.Starcˇevicá 32, to protect food from intentional acts of adulter- Koprivnica, Croatia ation related to terrorism (GPO 2013). 2 Faculty of Food Technology and Biotechnology, 2. In the year 2014, The British Standards Institution University of Zagreb, Pijerotijeva 6, Zagreb, Croatia (BSI) published ‘‘The guide to protecting and 3 Ministry of Agriculture, Ulica grada Vukovara 78, defending food and drink from deliberate attack’’ Zagreb, Croatia 123 N. P. Bogadi et al.

(BSI 2014). It defines food defence as a set of Following the EU horsemeat scandal in 2013, the 5- measures and actions regulated through proce- point Action Plan of The European Commission started dures to ensure the security of food and drink promoting the involvement of Europol in investiga- and their supply chains from malicious and tions (EC 2014). The cooperation between all the ideologically motivated attack leading to con- parties involved in investigations ensuring the rapid tamination or supply disruption. exchange of information related to fraud and food threats (BSI 2014) are also encouraged. Food defence Food defence concept includes activities associated and product recall procedures are an integral part of with the protection of the nation’s food supply from the crisis management. When it comes to recall pro- deliberate or intentional acts of contamination or cedure in food defence, the ways of communicating tampering. This term encompasses other similar risks are different. Attention shifts from the food sys- expressions such as bioterrorism and counter-terror- tem to the government, primarily involving national ism. The basic difference between food defence and security agencies and not necessarily the food agen- food safety is the fact that food defence deals with cies (McEnttire and Boateng 2012). intentional contamination of food products while food safety deals with unintentional contamination. The World Health Organization identified inten- 2 Main types of deliberate acts against food tional food contamination as one of the main global and food supply chain public health threats of the 21st century (WHO 2007). Food has become an instrument for terrorist acts The British Standards Institution presented in ‘‘Guide (WHO 2008). Threats and frauds can have a harmful to protecting and defending food and drink from effect on the health of consumers, society, economy, deliberate attack’’ (BSI 2014) the main types of delib- politics and national security. The potential threats in erate acts against food and food supply chain. The the food chain can include intentional contamina- concepts are: tion with toxic materials that cause poisoning and death, sabotage of the supply chain that can lead to • Economically motivated adulteration (EMA) as a food shortages, misuse of food for terrorist or crimi- subcategory of food fraud nal purposes. When considering the concept of food fraud, it is Trade disruption, interruption of food exports or evident that, depending on the authors, there are tourism could cause vigorous economic conse- a number of definitions circulating. According to quences for the majority of countries. All that can Spink and Moyer, food fraud represents inten- lead to political destabilisation as well as social and tional activity with the purpose of gaining public health problems, which is a reason why there economic or financial benefit as opposed to food has to be a multidisciplinary approach to food defence whose goal is to inflict damage with evil defence. All subjects that cooperate with food intentions. Food fraud includes the subcategory of industry should be included, from the national to economically motivated adulteration (Spink and the local institutions (WHO 2008). In cases of Moyer 2011; Everstine et al. 2013). However, eco- intentional contamination such as threats or food nomically motivated adulteration can also cause fraud, the investigation should involve different harm to consumers’ health. Unfortunately, the institutions than those involved in unintentional scandal with melamine poisoning in China has contamination. This implies fast action and cooper- proven this: More than 300,000 children fell ill ation of the national and local institutions like The after consuming milk products tainted with Ministry of Home Affairs and national security melamine. At least six children died and over agencies as well as European and international 50,000 were hospitalized due to the adulteration institutions like the European Commission, Europol, of infant formula and other milk products Food and Agriculture Organization of the United (Sharma and Paradakar 2010). After the melamine Nations (FAO), FDA, Federal Bureau of Investigation adulteration scandal, melamine has received (FBI), etc. The coordination of the investigation much more attention from the public. should be conducted by the security and intelli- The FDA uses the term ‘‘economically motivated gence agencies [FBI, Department of Homeland adulteration’’ (EMA) instead of the more general Security (DHS)], etc. In such they can take charge concept of food fraud and it defines it as ‘‘the and the roles of people responsible for food safety fraudulent, intentional substitution or addition of change (McEnttire and Boateng 2012). a substance in a product for the purpose of

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increasing the apparent value of the product or consumers’ health is concerned. Malicious con- reducing the cost of its production, i.e., for tamination may cause localized or widespread economic gain’’. EMA includes dilution of prod- illness or death and become a tool for terrorism. ucts with increased quantities of a substance that What is worse, food terrorism is impossible to is already present (e.g., increasing inactive ingre- predict. Food terrorism includes threats such as dients of a drug with a resulting reduction in malicious contamination with toxic materials strength of the finished product, or watering juice which cause disease and even death, sabotage of down) to the extent that such dilution poses a supply chain which leads to lack of food, abuses of known or possible health risk to consumers. EMA food for terrorist or criminal purposes (BSI 2014; also includes the addition or substitution of USDA 2014). substances in order to mask dilution (FDA 2009). The World Health Organization (WHO) presents a The EU legislation has not defined the concept of guide for member states in its edition ‘‘Terrorist food defence yet. European Parliamentary Threat to Food: Guidance for Establishing and Research Service has issued a briefing paper Strengthening Prevention and Response Systems’’ ‘‘Fighting food fraud’’ which defines food fraud where issues related to possible threats from terror- as ‘‘an intentional action carried out for financial ists, criminals and other anti-social groups who gain’’. Different types of fraud include food adul- target the safety of the food supply are explained. teration, counterfeiting, substitution and This guide defines food terrorism as ‘‘an act or threat deliberate mislabelling of goods’’ (EPRS 2014). In of deliberate contamination of food for human the article published by Van der Meulen (2015), consumption with chemical, biological or radionu- there is a good overview of EU food law from the clear agents with the purpose of causing injury or viewpoint of food fraud. It is necessary that the death to civilian population and/or disrupting social, discussion on food defence is continued and economic or political stability’’ (WHO 2008). expanded as the EU has no clear requirements • Espionage for food defence while the EU legislation inter- The main motive of espionage is gaining com- prets food fraud in different ways. Food law petitive advantage through access to intellectual should clearly define the requirements in the property. In most cases employees (insiders) dis- field of food defence. close information through information While food fraud is economically motivated, food technology systems. For instance, two employees defence is ideologically motivated by individuals of DuPont Industrial Biosciences stole the infor- or certain organizations. The list of potential mation related to DuPont’s process for consequences includes diseases or death, negative manufacturing titanium dioxide, used as a white- impact on the economy and trade, negative ner in Oreo cookies and other products. The impact on public health services and negative information was sold to a Chinese chemical social and political implications. company (O’Halloran 2014). Food defence is a joint concern of the food • Counterfeiting industry and government institutions as it repre- The motivation for counterfeiting is financial sents a threat to public health (Spink and Moyer gain. Organized crime and petty crime can cause 2011). Depending on the situation, different fac- financial loss of companies and harm their repu- tors can increase the risk of intentional tation. For instance, ‘‘thousands of tonnes of fake contamination and potential threats. These and sub-standard food and drink have been seized include national, political, business, personal in 47 countries around the world as part of an and other differences, changes in the corporate INTERPOL-Europol coordinated operation. Opera- culture of a company, economic recession or tion Opson IV, conducted during December 2014 financial gain of a company, a mentally disor- and January 2015, resulted in the seizure of more dered person or dissatisfied employees. than 2500 tonnes of counterfeit and illicit food, • Malicious contamination including mozzarella, strawberries, eggs, cooking Malicious contamination implies the realization oil and dried fruit. Involving police, customs, of the attack with the purpose of gaining public- national food regulatory bodies and partners ity or money as well as causing widespread harm. from the private sector, checks were carried out Malicious contamination is more likely in retail at shops, markets, airports, seaports and indus- chains than in food production and the conse- trial estates’’ (Europol 2015). This is an excellent quences are more serious as far as harm to the example of good coordination between all the 123 N. P. Bogadi et al.

institutions that should be involved in food such as IFS, BRC, SQF, HACCP, GLOBALG.A.P., FSSC defence and counterfeiting, in this case. 22000, NSF and other. • Cybercrime The most significant food safety standards in Modern technology provides new opportunities Europe are the British Retail Consortium (BRC) and for malpractice. The most common reasons for the International Featured Standards (IFS). They hacking companies are attempts to lower busi- have recognised the importance of food defence. ness efficiency of food companies as well as data According to these standards, food defence theft. The possible consequences are commercial requirements are mandatory and they include the harm and an increasing threat to food safety. implementation of hazard analysis, the assessment of related risks and the identification of critical areas within the subject assessment (BRC 2012). In the year 2.1 Food industry 2005, the International Organisation for Standard- ization (ISO) developed a standard for the managing The food industry most commonly integrates a food food safety system ISO 22000:2005. In practice, this defence into an existing food safety system of the standard is valid only together with the technical company. Food defence involves documentation and standard ISO 22002-1:2009, which specifies require- written procedures of an already existing food safety ments for establishing, implementing and system. This refers to the documentation of the food maintaining prerequisite programmes (PRP) (certi- safety system, traceability, documentation and fication scheme FSSC 22000). According to this records of the management system, corrective and standard, food defence is one of the prerequisite preventive measures, internal audits, employee programmes indicating that each organisation has training, etc. to perform the hazard analysis and to assess related The GFSI food safety program covers most of FDA’s risks. The hazard analysis and the risk assessment ‘‘Food Safety Modernization Act’’ (FSMA) require- estimate potential risks depending on the type of ments but the issue of the program’s intentional sabotage, vandalism or terrorism. In its standard SQF adulteration still needs to be addressed. The concepts Code, The Safe Quality Food Institute (SQFI) also are very similar whereby the threat and vulnerability indicates the need to define the methods, responsi- of the systems and facilities must be evaluated using bilities and criteria for the prevention of intentional the HACCP concepts in order to guard against contamination caused by sabotage or a terrorist act intentional adulteration. The GFSI has defined the (SQF 2014). following two concepts: VACCP (vulnerability/food Regardless of the food safety standards, they all fraud) and TACCP (threat/food defence) (GFSI FORUM imply that it is necessary to implement corrective 2014). The GFSI has defined the Food Safety Man- measures in accordance with the assessments of agement as an ‘‘umbrella’’ that includes HACCP related risks. If a food company has partnership (hazard/Food Safety), TACCP (threat/Food Defence) agreements or exports products to certain countries, and VACCP (vulnerability/Food Fraud).1 These three it is obliged to apply the requirements for food separate scopes should be addressed individually defence defined by the food safety standards and the (Fig. 1). legislation of certain countries. Food defence is a From the perspective of food companies, the main concern in almost all business areas in the food initiators of the food defence implementation are the industry, where intentional contamination and food retail chains, who condition the producer’s certifi- fraud can pose a serious threat to the consumers’ and cations in accordance with one of the system public health as well as damage company business standards in food safety. The same conditions also (BSI 2014). apply in case of a cooperation between various The food industry implements food defence business partners who participate in the food supply mainly in agricultural production, processing, stor- chain, such as retail chains, outsourcing or logistics age and transport, wholesale and retail distribution services. Standards supported by the GFSI Initiative and tracing systems and recalls (traceability being are the prerequisite for business cooperation. These one of the obligatory requirements). include globally recognised certification schemes Depending on the size of a food company, food defence can be implemented on the level of its management, human resources, purchasing depart- 1 http://foodfraud.msu.edu/2014/05/08/gfsi-direction-on-food- ment, receipt and storage of raw materials, fraud-and-vulnerability-assessment-vaccp/. production, quality control, packaging and labelling, 123 Food defence system in food industry: perspective of the EU countries

Fig. 1 Umbrella of the GFSI food safety management Food Safety Management system by GFSI

Food Safety Food Defence Food Fraud

HACCP TACCP VACCP

Hazards Threats Vulnerabilities

Prevention of unintentional Prevention of Prevention of accidental adulteration intentional adulteration intentional adulteration - Science based - Behaviourally or - Economically motivated - Food borne illness ideologically motivated

storage of finished products, transport and distribu- the production process. In production, the HACCP tion (BSI 2014; USDA 2014). team often carries out the activities related to food defence. In addition, the HACCP team should com- plement with experts from other areas such as the 3 Materials and methods corporate security of the company. The team members are chosen based on their 3.1 Risk assessment—threat assessment knowledge and professional skills in the following areas: of critical areas in the food supply chain security, human resources, food technology, production and operations, purchasing department and supply, When assessing critical areas in the food supply distribution, communications and marketing. Along chain, it is required to define the criteria for risk with indisputable knowledge and professionalism, the analysis. Mostly, the criteria are based on the impact team members need to be reliable, discrete and aware of of the threat on the consumers’ health as well as on the implications of the process (BSI 2014). potential social, economic and political conse- At present, several food defence approaches can be quences. Therefore, food manufacturers, suppliers applied in practice. One of them is provided by the British and retail chains should reinforce safety measures Standards Institution in PAS 96:2014. This standard during the production process and assess the weak- allows organizations to avoid and mitigate food threats nesses in their scope of work and responsibility. in the entire food supply chain. Its refers to a TACCP The first step in the implementation of food defence approach. The term Threat Assessment Critical Control systems in the food industry is determining the scope. Point (TACCP) includes ‘‘systematic management of risk So far, existing literature is based on production facil- through the evaluation of threats, identification of vul- ities because risk assessment has shown that the level nerabilities, and implementation of controls to materials of risk has been at its highest there. However, larger and products, purchasing, processes, premises, distri- food companies with more production facilities and bution networks and business systems’’. In the context of management functions should extend the scope to the food defence, threat is something that can cause loss or entire company (management board, human resour- harm which arises from the ill-intentioned people (BSI ces, purchasing department, etc.). 2014). Threat is based on the motivation, method, and The team for the implementation of the food capability of an attack. defence system should be multidisciplinary and The Food Defence Plan is the main document of consist of technical staff who specialized in a relevant the food defence system in food industry (FDA 2014; field of activity. People that are responsible for food USDA 2014; GPO 2013). It defines the principles and defence implementation should be appointed in all the implementation of food defence. It includes facilities because food defence does not refer only to activities that can change depending on country,

123 N. P. Bogadi et al. organisation, regulatory requirements, responsibility, plan that addresses vulnerabilities associated with management commitment and awareness of the food defence and food fraud, the same as HACCP employees. Planning food defence activities in the plan addresses the hazards associated with uninten- production process has to according to the existing tional contamination. food safety system. This implies the integration of the The FDA proposes a group of activities to be food defence system with food safety with the food included in the food defence plan. First is the Iden- safety prerequisite programmes, written procedures tification of actionable process steps and the for traceability in the food supply chain and proce- implementation of Focused mitigation strategies, i.e. dures for recall/withdrawal of products from measures that are necessary to reduce the likelihood markets. However, it should be emphasized that the of intentional contamination caused by an act of food defence strategies intend to address threats and terrorism. This measure is based on the risk-assess- not to be used in an existing food safety plan. ment tool CARVER ? Shock. A further variable to Food companies need to decide on the risk man- measure is Monitoring. Next, there are Corrective agement methodology used in conducting risk actions of the food safety system that ensure the assessment. Several efficient methods are published performance of the entire system. The same princi- and every organisation needs to decide which ples apply to food defence. Verification activities for methodology meets their requirements most. The food safety can also be used for food defence. The methods should be user-friendly so it is necessary to final step is Training which requires the employees upgrade them constantly. Risk assessment is con- and supervisors working in the field of food defence ducted with the purpose of defining control and to become aware of food defence and their respon- preventive measures. The Food Defence Plan obliges sibilities. The last mentioned measure refers to food companies to implement internal audits and the keeping records about food protection confidential analysis of the food defence system, which enables and safe from intentional adulteration caused by acts continuous improvements of the system. This defined of terrorism (GPO 2013). plan should undergo a testing at least once a year. As mentioned above, the FDA and USDA adapted a The test examines the effectiveness of the defined tool called CARVER, originally used for military pur- control and preventive measures and, if necessary, poses, for vulnerability assessment in the food sector. regulates new preventive measures (FDA 2014; USDA CARVER is an acronym for the following six attri- 2014; Spink and Moyer 2011). butes used to evaluate the attractiveness of a target for an attack: 3.2 Food defence process as defined by PAS • Criticality—refers to the impact of an attack on 96:2014 of The British Standards Institution public health and the economy. • Accessibility—refers to the ability to physically In order to apply and manage all prescribed activities access and egress from the target. in the area of food defence, it is necessary to define • Recuperability—refers to the ability of a system to the TACCP team. The TACCP teams implement all recover from an attack. activities prescribed when conducting food defence • Vulnerability—refers to the ease of accomplishing (Fig. 2). an attack. Figure 2 specifies the most important steps of the • Effect—refers to the amount of direct loss from an TACCP food defence process which are: assessment, attack as measured by loss in production. identification, implementation, revision and moni- • Recognizability—refers to the ease of identifying a toring. Food defence assessment is based on 3 basic target. types (BSI 2014): The 7th attribute is shock. It assesses health, eco- • threat assessment, nomic, and psychological impacts of an attack on the • vulnerability assessment and food industry. These adapted methodologies • likelihood of the threat assessment and its impact. improved vulnerability assessment and allowed for the identification and estimation of economic and 3.3 Food defence assessment defined by the FDA psychological impacts throughout the food system (GPO 2013). The FDA proposed food defence measures in the Risk management according to ISO 31000 was Federal Register/Vol. 78, No. 24721 CFR Parts 16 and applied in safety risk assessments ahead of food 121 (Fig. 3). These measures require a food defence defence assessment. It has been recognized that, 123 Food defence system in food industry: perspective of the EU countries

Fig. 2 Flowchart of the food defence process (BSI 2014) TACCP team

1. 15. 14. 13. Assess Monitor horizon scans Review and revise Decide and implement new information and emerging risks necessary controls

2. 11. 12. Identify and assess Likelihood v Impact → Identify who could threats to organization Priority carry it out?

3. 10. 9. Identify and assess Determine if control Identify which supply threats to operation procedures will detect points are most critical the threat

4. 8. Select product Concider impact of threats identified

5. 6. 7. Identify and assess Devise flow chart of Identify key staff and threats to product product supply chain vulnerable points

compared to risk, vulnerability is more a state of emphasis on food defence. The education pro- being that could lead to an incident (Spink 2014). gramme should consist of acquiring the basic level of While conducting threat analysis and assessing awareness on t food defence, the implementation of vulnerability with the purpose of the implementation, prescribed procedures and assessment methods for maintenance and improvement of food defence, one the identification and mitigation of potential risks can use risk assessment methods based on the ISO (ICH Q9 2005). standards Risk Management ISO 31000:2009 and ICH Q9 Quality Risk Management. The majority of food 4 Results and discussion companies are familiar with these methods because they are used for conducting risk assessment in food In many countries and food companies, the security safety management systems. These are methods such of the food supply chain has taken on a significant as Risk matrix, Checklists, Failure Mode and Effect importance due to terrorist attacks and cases of food Analysis—FMEA, etc. Risk assessment techniques are fraud. These incidents have contributed to the described in the supporting standard ISO 31010:2009 development and implementation of the food Risk Management—Risk assessment techniques. It pro- defence system. To avoid serious consequences, it is vides the guidelines for the selection and application essential to recognise the hazards early before they of systematic techniques in risk assessment. become real risks. In order to survive on the market, food companies have to follow market demands and, 3.4 Education and raising employee awareness in accordance with them, constantly introduce different food safety and quality systems. The company’s efficiency is in the implementation of new methods, tools and systems depends on the level 4.1 Global overview of education of its employees. A new implementation of a food defence system in a country requires not Food defence is relatively new in both the EU and only raising the employees’ awareness on a company non-EU countries. Therefore, it is necessary to work level, but also on the level of government institutions. on raising awareness on food defence and to apply Education programmes should focus on the connec- risk management methods. The integration of food tion of the public and private food sector with an defence into legislation is required. Therefore, the

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Food Defense Measures (by FR-2013-12-24 Federal Register-Vol.78, No. 247)

Food Defense Plan 1. Identification Actionable Process Steps A. Written Food Defense Plan includes: option 1 option 2 1. Actionable Process Steps 2. Focused Mitigation Strategies Assess whether your facility has one or more of Perform a vulnerability assessment using 3. Monitoring * these FDA identified key activity types : appropriate methods and qualified individual(s) 4. Corrective Actions 1. Bulk liquid receiving and loading 5. Verification 2. Liquid storage and handling Perform a vulnerability assessment using 3. Secondary ingredient handling B. Training of supervisors and personnel appropriate methods and qualified individual(s) 4. Mixing and similar activities working at actionable process steps

Identify actionable process steps for significant Identify actionable process steps for each C. Records to be prepared and kept vulnerabilities applicable key activity type

5. Verification

* FDA identified 2. Focused Mitigation Strategies these key activity Verify that monitoring is conducted types using findings Identify and implement focused mitigation strategies at actionable of vulnerability assessments of over process steps 50 food products Verify that appropriate decisions about and process. These activity types corrective actions are made 3. Monitoring commonly rand high in vulnerability Establish and implement procedures for monitoring focused based on various Verify that focused mitigation strategies are factors, including mitigation strategies the ability to consistently implemented and are effective physically access the food or process 4. Corrective Actions and the potential to Conduct reanalysis of the food defense plan, as adulterate a Establish and implement procedures for corrective actions if sufficient quantity of appropriate product in order to focused mitigation strategies are not properly implemented cause massive public health harm.

Fig. 3 Food defence measures (GPO 2013)

European Commission carries out risk assessment intentional contamination prescribed in their legis- through the European Food Safety Authority (EFSA) lation have to develop their national strategies for and ensures that any actions taken in the event of a the whole food supply chain, agriculture and food crisis are scientifically proven as well as politically defence. On the national level, it is required to define responsible and legitimate (Beńoliel 2007). Food a food defence programme determining preventive fraud and food threat should be taken very seriously. measures for potential threats and food sabotage. General requirements of the EU law primarily focus These programmes should be joint initiations. Toge- on food safety. Nowadays, food fraud is on the rise ther with the food industry, the governments of and, as a result, The European Commission put for- different countries need to work on strengthening ward measures to strengthen the global food chain, the national security of food and, therefore, on food specifically to identify fraudulent activity (EPRS 2014). defence during production, processing and distribu- The GFSI Board decided to issue a position paper tion (WHO 2008). expressing their belief that the mitigation of food fraud is an integral part of a company’s management system for food safety. Therefore, they will include 4.2 Food defence—subject integrating a wider new requirements specific to food fraud mitigation community in the next full revision of the GFSI Guidance Docu- ment 7th Edition, which is due to be published early In order to obtain a comprehensive function of food in 2016 (GFSI 2014). Countries not having food defence, it is essential to raise the awareness in the defence requirements and measures against whole food supply chain, from farm to fork, from

123 Food defence system in food industry: perspective of the EU countries government, state and academic institutions to retail org/index.php/41-european-affairs/summer-2007/97-eu- chains, media and consumers. To incorporate food defending-food-chain-against-bio-attack. Accessed 1st Mar 2016 defence into all stages of the food supply chain BRC Global Standard (2012) BRC global standard for food safety. requires a lot of work (Applebaum 2014). Raising the http://www.brcglobalstandards.com/Knowledgecentre/Food awareness and purpose of food defence can help to Safety-AGlobalView.aspx#.VtWwZ0ZCfPE. Accessed 1st Mar establish effective measures. This will instigate joint 2016 British Standards Institution (2014) PAS 96:2014 Guide to activities in all areas necessary to improve food safety protecting and defending food and drink deliberate on a global level. attack. http://www.food.gov.uk/sites/default/files/pas96- 2014-food-drink-protection-guide.pdf. Accessed 2nd Mar 2016 5 Conclusion European Commission (2014) MEMO/14/113 Horsemeat: one year after - [ actions announced and delivered! http://ec. europa.eu/food/safety/docs/official-controls_food-fraud_ On one hand, the awareness of the food defence is five-point-action-plan_en.pdf. Accessed 1st Mar 2016 not the same in all parts of the world. On the other European Parliament Research Service (EPRS) Briefing (2014) hand, the world is a global village with food on its Fighting food fraud. http://www.europarl.europa.eu/ global market. This increases the risk of spreading RegData/bibliotheque/briefing/2014/130679/LDM_BRI% 282014%29130679_REV1_EN.pdf. Accessed 1st Mar 2016 contaminated and adulterated food. Other potential Europol (2015) Record seizures of fake food and drink in factors of risk are national, political, economic, INTERPOL-Europol operation 16. https://www.europol. business and personal differences. Food industry has europa.eu/content/record-seizures-fake-food-and-drink-inter been facing many risks. They can have negative pol-europol-operation. Accessed 1st Mar 2016 Everstine K, Spink J, Kennedy S (2013) Economically motivated influence on product safety and, eventually, on the adulteration (EMA) of food: common characteristics of business activities of a company. Intentional con- EMA incidents. J Food Prot 76(4):723–735 tamination of food products and food fraud are some Global Food Safety Initiative (2014) GFSI position paper on of the possible risks. Implications are not limited only mitigating the public health risk of food fraud. http:// www.mygfsi.com/news-resources/news/295-gfsi-position- to food producers but also more widely. Therefore, paper-on-mitigating-the-public-health-risk-of-food-fraud. one of the basic steps is to raise awareness of food html. Accessed 2nd Mar 2016 defence through the whole food chain, from the food Global Food Safety Initiative FORUM (2014) SGS—food safety sector to government institutions. Educational insti- modernization act (FSMA) updates and how Global Food Safety Initiative (GFSI) audits can help with compliance. tutions should incorporate food defence in their http://www.mygfsi.com/news-resources/news/275-sgs-food- curricula. There are critical factors at all levels of the safety-modernization-act-fsma-updates-and-how-global- food chain so one cannot prevent intentional con- food-safety-initiative-gfsi-audits-can-help-with-compliance. tamination and food fraud without regulated legal html. Accessed 2nd Mar 2016 GPO (2013) Proposed rules, part III, Food and drug administra- provisions and effectively written procedures. tion, focused mitigation strategies to protect food against Food companies and other stakeholders who have intentional adulteration. Fed Regist 78(247):78013–78061 not incorporated food defence principles in their (FR Doc No: 2013-30373). http://www.gpo.gov/. Accessed 24 regulations can find help in prepared materials and Dec 2013 International Conference on Harmonisation of Technical tools such as CARVER ? Shock Vulnerability Assess- Requirements For Registration of Pharmaceuticals For ment Software (FDA) or from the PAS 96:2014 Guide Human Use (2005) Q9 Quality risk management version 4. to protect and defend food and drink from deliberate http://www.ich.org/fileadmin/Public_Web_Site/ICH_Products/ attack by BSI. Guidelines/Quality/Q9/Step4/Q9_Guideline.pdf. Accessed 2nd Mar 2016 Compliance with ethical standards International Organization for Standardization (2005) Food safety management systems—requirements for any orga- Conflict of interest The authors declare that they have no nization in the food chain. ISO 22000:2005. http://www. conflict of interest. iso.org/iso/catalogue_detail?csnumber=35466 Accessed 2nd Mar 2016 International Organization for Standardization (2009) Prereq- uisite programmes on food safety—part 1: food References manufacturing. ISO 22002-1:2009. http://www.iso.org/iso/ iso_catalogue/catalogue_tc/catalogue_detail.htm?csnumber Applebaum RS (2014) Terrorism and the nation’s food supply =44001. Accessed 2nd Mar 2016 perspectives of the food industry: where we are, what we International Organization for Standardization (2009) Risk have, and what we need. J Food Sci. doi:10.1111/j.1365-2621. management—risk assessment techniques. ISO/IEC 2004.tb15493.x 31010:2009. http://www.iso.org/iso/home/store/catalogue_ Beńoliel I (2007) EU defending food chain against bio-attack. tc/catalogue_detail.htm?csnumber=51073. Accessed 2nd Eur Aff 8(1):70–74. http://www.europeaninstitute. Mar 2016

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McEnttire J, Boateng A (2012) Industry challenge to best US Food and Drug Administration (2009) Economically moti- practice risk communication. J Food Sci. doi:10.1111/j.1750- vated adulteration. 74 Fed Regist 64:15497–15499. http:// 3841.2012.02630.x www.federalregister.com/Browse/Document/usa/na/fr/2009/ O’Halloran S (2014) DuPont industrial espionage case ends with 4/6/e9-7843. Accessed 1st Mar 2016 convictions. Food Eng. http://www.foodengineeringmag. US Food and Drug Administration (2014) Food defence. http:// com/articles/92018-dupont-industrial-espionage-case-ends- www.fda.gov/food/fooddefense/. Accessed 1st Mar 2016 with-convictions. Accessed 6 Mar 2014 Van der Meulen B (2015) Is current EU food safety law geared Safe Quality Food Institute (2014) SQF code a HACCP-based up for fighting food fraud? J Verbr Lebensm 10(S1):S19–S23 supplier assurance code for the food industry, edition 7.2. World Health Organization (2007) The world health report—a https://www.sqfi.com/wp-content/uploads/SQF-Code_Ed-7. safer future: global public health security in the 21st 2-July.pdf. Accessed 2nd Mar 2016 century. http://www.who.int/whr/2007/whr07_en.pdf?ua= Sharma K, Paradakar M (2010) The melamine adulteration 1. Accessed 2nd Mar 2016 scandal. Food Sec 2(1):97–107. doi:10.1007/s12571-010-0057-4 World Health Organization (2008) Terrorist threats to food Spink J (2014) GFSI direction on food fraud and vulnerability guidance for establishing and strengthening prevention assessment (VACCP). http://foodfraud.msu.edu/2014/05/08/ and response systems, revision. http://seafood.oregonstate. gfsi-direction-on-food-fraud-and-vulnerability-assessment- edu/.pdf%20Links/WHO%20Food%20Safety%20Issues%20-% vaccp. Accessed 8 May 2014 20Terrorist%20Threats%20to%20Food.pdf. Accessed 2nd Spink J, Moyer DC (2011) Defining the public health threat of Mar 2016 food fraud. J Food Sci. doi:10.1111/j.1750-3841.2011.02417.x US Food and Drug Administration (2002) Bioterrorism act. http://www.fda.gov/RegulatoryInformation/Legislation/ ucm148797.htm. Accessed 1st Mar 2016

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