Creating effective Food Defense and Food Fraud programs is crucial for maintaining the safety and integrity of the food supply. These programs are designed to prevent intentional adulteration, whether for malicious purposes like terrorism (Food Defense) or economic gain (Food Fraud).
The SQF Code requires under element 2.7 that food operations develop and implement Food Defense and Food Fraud programs that outline the methods and responsibilities to prevent the intentional adulteration of food.
In this article, we provide a guide to the development of food defense and food fraud programs.
Food Defense Program
- Management Responsibility: Assign a member of the site management as the responsible authority for the Food Defense Program. Since you have to also meet the regulatory requirements for the FSMA Intentional Adulteration Rule, you should assign a person that has the competencies to undertake these responsibilities as this role will be appointed as the Food Defense Qualified Individual. This person should have decision-making authority and be a clear communicator.
- Conduct a Threat Analysis: It is highly recommended that a Food Defense Team is assembled with representatives from each department of the operation. This will allow proper brainstorming to identify possible threats and analyze the significance (likelihood and severity) of these. During the threat analysis, vulnerabilities in the supply chain (external) and at the site (internal) are identified, and mitigation strategies are implemented to ensure the food safety of ingredients, materials and finished products.
- Implement Mitigation Strategies: Mitigation strategies must be implemented. Below are some suggested mitigation strategies:
- Physical Measures: Implement controlled and surveilled access. Also, implement tamper evident measures of incoming materials and finished goods.
- Personnel Security Measures: Conduct background checks for new hires and temporary employees. Conduct training on mitigation strategies and create a culture of food defense.
- Operational Practices: Regularly review and update operational procedures, ensure traceability of ingredients, and establish protocols for responding to security threats or suspicious activities.
- Monitor the Plan: Monitor the implemented mitigation strategies.
- Implement Corrective Actions: If there is a deviation from the plan or an incident happens, identify the root cause, and implement a corrective action.
Food Fraud Program
- Management Responsibility: Assign a member of the site management as the responsible authority for the Food Fraud Program. This person should have decision-making authority and be a clear communicator.
- Conduct a Vulnerability Assessment: Conduct assessment on ingredients to evaluate the risk of economically motivated adulteration, drawing historical incidents. Ensure to develop criteria and methods for this assessment, focusing on supply chain, economic factors, and historical data.
- Implement Prevention Strategies: Outline methods and assign responsibilities for preventing economically motivated adulteration. Implement verification procedures for ingredient sources, conduct random testing, and maintain strong supplier relationships.
- Train Personnel: Educate staff about the types of food fraud and their roles in prevention. Regularly update training to reflect the latest trends and findings in food fraud.
Establish record keeping procedures to ensure all documentation associated with the programs is kept secure.
Conduct an annual review for both programs involving key stakeholders.
Regular audits, both internal and external, can help ensure that these programs are effectively implemented and maintained. Remember, the goal of these programs is not just to comply with regulations but to proactively protect consumers and the integrity of the food supply chain.
FAQs
Beyond decision-making and communication skills, they should have training in risk assessment, security management, and the specific requirements of the FSMA Intentional Adulteration Rule.
It is recommended to review and update these analyses annually or whenever there is a significant change in the operation or supply chain that could introduce new vulnerabilities.
Indicators can include sudden price drops, inconsistent product availability, and unusual shipping routes. Regular audits and maintaining strong communication with suppliers can help identify such red flags.
Technology such as blockchain for traceability, AI for monitoring supply chain anomalies, and advanced analytics for risk assessment can significantly enhance the integrity and responsiveness of these programs.
SMEs can focus on critical control points, leverage sector partnerships for shared resources and intelligence, and prioritize high-risk areas to optimize resource allocation.
