28 replies to this topic

[tsmith7858]

I figured I would help kick off the new forum as I was somewhat involved in the request for it.

To my knowledge there is no existing stand alone standard but Food Defense has made its way into most of the existing Food Safety Standards.

We were audited at the end of 2008 to a customer standard on Food Defense so I figured it would be interesting to see if anyone else has been audited for food defense.

[V.R. Reddy]

Dear TS,

I have a feeling that in next 3 – 5 years time international bodies such as ISO or FAO may come out with a stand alone standard for the organizations to implement Food Defence management system which could be based on HACCP principles.

Regards

Venkat

[BoomBoom]

Hello TS,

This could possibly be one of the most popular subjects on the forums in very short order, IMO.

The SQF 2000 code 4.7.1.1 states:
"The methods, responsibility, and criteria for preventing adulteration caused by a deliberate act of sabotage or terrorist like incident shall be documented, implemented, and maintained."

If it is in the SQF code, the other GFSI schemes either have something like it or may possibly be adding it in the future.

Also, the FDA in the US is using something called the A.L.E.R.T. method of food defense and pushing it on all of the victims establishments they inspect. More info here

I think it's a great topic!

I look forward to seeing others input.

Best regards,
Tom

[Simon]

I have a few questions:

1. Can you just tell me what a typical food defense audit covers?

2. I would also like to know who is driving this, is it the big retailers or governement led or what?

3. Are any Food Defense standards serioulsy under discussion or development?

Regards,
Simon

[pawilliams1]

Simon, in another forum topic we have discussed Tesco's PIU (Product Integrity Unit) Audits.

For those who are not from the UK, Tesco is a major supermarket chain with probably the biggest market share in the UK. They have a Product Integrity Unit which has the main aims of ensuring that nothing can be done to damage the supermarket's brand or image. This especially applies to ensuring that incidents of sabotage are prevented.

However, in submission to the House Of Commons Science Committee (at least I think it was but it was a committee of the House Of Commons anyway), Tesco said that their PIU is a major part of the fight against the "threat of food terrorism". Part of this fight, apparently, is to undertake unannounced audits of suppliers to the supermarket.

However there is no co-ordinated approach to "food terrorism" in the UK at the moment other than general food safety regulations or industry specific regulation. Whether or not this is because there is no great threat perceived by the UK government is a matter for debate - in my opinion I hope they realise that the threat of food terrorism is realistically minimal and hence don't bring out more regulations for us to comply with because we are already over burdened.

The reason I say this is because incidents of food sabotage in the UK historically have always been about extorting money from a retailer or producer and therefore not really terrorism. The business model of the major retailers is such that they source from all over the place so there is no single focus for food terrorists to cause mass panic.

However should one of the major retailers go down the route of producing their own products for distribution through their stores on a nationwide scale then that focus would come into being and the production plant would then be a target for food terrorists.

[cazyncymru]

However there is no co-ordinated approach to "food terrorism" in the UK at the moment other than general food safety regulations or industry specific regulation. Whether or not this is because there is no great threat perceived by the UK government is a matter for debate - in my opinion I hope they realise that the threat of food terrorism is realistically minimal and hence don't bring out more regulations for us to comply with because we are already over burdened.

I'm not sure i'd agree with you.

BSI in co-junction with the Centre for the Protection of National Infrastructure released a guidance document last March entitled "Defending Food and Drink" also known as PAS96

Unfortunately it is copyrighted so i can't post here, but it is publically available as a freebie (from either CPNI or BSI)

Caz x

[Cathy]

In the US, food defense is showing up on audits more often as well. Also, FSIS is pushing to meet the goal that at least 90% of all FSIS regulated plants have a food defense plan. If that goal is met soon (a new survey will be done this fall), they will not push for mandatory plans. If the goal is not met, rule making may be the next step. To assist in these efforts, I helped develop a generic plan. The plan requires minimal effort. I wish it was better, but it does get plants at least started in a good direction. I tried to upload the plan here, but had some trouble. It's just a word document but I got a message saying I'm not permitted to upload the file. The new plan should be on the FSIS web site with a week or two.

[Simon]

In the US, food defense is showing up on audits more often as well. Also, FSIS is pushing to meet the goal that at least 90% of all FSIS regulated plants have a food defense plan. If that goal is met soon (a new survey will be done this fall), they will not push for mandatory plans. If the goal is not met, rule making may be the next step. To assist in these efforts, I helped develop a generic plan. The plan requires minimal effort. I wish it was better, but it does get plants at least started in a good direction. I tried to upload the plan here, but had some trouble. It's just a word document but I got a message saying I'm not permitted to upload the file. The new plan should be on the FSIS web site with a week or two.

Hi Cathy, What type / version of document is it? Maybe I can take alook why it is not allowing you to do it - in the meantime email it to me at team---@---ifsqn---.com and I will post it for you.

Regards,
Simon

[Simon]

Hi Cathy, What type / version of document is it? Maybe I can take alook why it is not allowing you to do it - in the meantime email it to me at team---@---ifsqn---.com and I will post it for you.

Regards,
Simon

The problem was related to the version of word. I need to include Word 2007.

Anyway I added the file in a new thread:

Generic Food Defense Plan

Regards,
Simon

[Biss]

HI,

we have implemented CTPAT (Customs-Trade Partnership Against Terrorism) as it is a requirement of US customers. Our facility was inspected by US Customs to check the compliance. Now food defence is a mojor check piont in customer audits

http://www.cbp.gov/x...security/ctpat/

[Simon]

Simon, in another forum topic we have discussed Tesco's PIU (Product Integrity Unit) Audits.

For those who are not from the UK, Tesco is a major supermarket chain with probably the biggest market share in the UK. They have a Product Integrity Unit which has the main aims of ensuring that nothing can be done to damage the supermarket's brand or image. This especially applies to ensuring that incidents of sabotage are prevented.

However, in submission to the House Of Commons Science Committee (at least I think it was but it was a committee of the House Of Commons anyway), Tesco said that their PIU is a major part of the fight against the "threat of food terrorism". Part of this fight, apparently, is to undertake unannounced audits of suppliers to the supermarket.

However there is no co-ordinated approach to "food terrorism" in the UK at the moment other than general food safety regulations or industry specific regulation. Whether or not this is because there is no great threat perceived by the UK government is a matter for debate - in my opinion I hope they realise that the threat of food terrorism is realistically minimal and hence don't bring out more regulations for us to comply with because we are already over burdened.

The reason I say this is because incidents of food sabotage in the UK historically have always been about extorting money from a retailer or producer and therefore not really terrorism. The business model of the major retailers is such that they source from all over the place so there is no single focus for food terrorists to cause mass panic.

However should one of the major retailers go down the route of producing their own products for distribution through their stores on a nationwide scale then that focus would come into being and the production plant would then be a target for food terrorists.

Has there ever been a case of food terrorism from the current al qaeda threat? Maybe it will take a crisis to make some countries spring into action.

Regards,
Simon

[Abdul Qudoos]

I am interesting to know more about the food defense, clearly in simple English...

[Cathy]

I don't think there has been an act of food related terrorism associated with al queida. In 2002 the World health organization stated that contamination of food for terrorist putposes was a real and current threat. We have no way of knowing how they arrived at that conclusion but it is wise to be prepared.

There have been contamination events over the years, but more often it seems related to a disgruntled employee or person rather than a group.

1978 - Israel - citrus contaminated intentionally with mercury by a terrorist group stating they were targeting the economy

1984 - Oregon - a cult contaminated food with Salmonella to keep voters away from the polls and change the results of an election.

1996 - Shigella added to food by a U.S. lab employee

2002- rat poison added to a breakfast food in China

2003- nicotine added to ground beef in Michigan

2005 - a candy bar contaminated and a threat that there were more caused millions in loss.

One of the challenges with food defense is that the events that occur are not discussed. This is in part to maintain consumer confidence but also to avoid giving ideas to the wrong people. Exercises do take place on how to handle an event - but these too are only discussed among those who need to know and prepare.

[YongYM]

Dear Cathy:

Useful info. Thank you very much....

[Simon]

As consumers we have to rely on the food chain to take the necessary precautions and as food industry members we have to ensure we do our own bit.

However it will happen. Not if but when and where and who.

[Jon5]

All:

A few points regarding food defense as I see it, based on very limited exposure to the topic. Please feel free to comment.

• Food defense and food safety standards are mutually dependent, not independent, in any farm-to-fork process.
• Any GFSI-accepted food safety standard includes elements of food defense, and will likley continue to become more robust in this area with future revisions.
• It seems to me that a stand-alone "food defense plan" or food defense standard would only be appropriate in settings in which a full food safety/HACCP style plan is not appropriate to use (i.e. some primary producers, like fruit ranchers).

Thoughts?

Jon

[BoomBoom]

Hi Jon -

Thanks for your input. Here's my opinion on your points one by one...

1. Food defense and food safety standards are mutually dependent, not independent, in any farm-to-fork process.

I disagree. You can have a very successful Food Defense Plan in place and keep the bad guys out while at the same time contaminating your product with chemicals used or monitored incorrectly or cross contaminating allergens through not having a plan in place for containment for example.

2. Any GFSI-accepted food safety standard includes elements of food defense, and will likley continue to become more robust in this area with future revisions.

I totally agree with this. The "Standards" will continue to beef up the food defense portion of their schemes as the likelihood of food terrorism rises. Here in the US it looks more likely that it can and will happen, IMO.

It seems to me that a stand-alone "food defense plan" or food defense standard would only be appropriate in settings in which a full food safety/HACCP style plan is not appropriate to use (i.e. some primary producers, like fruit ranchers).

Food Safety plans for primary producers are becoming more important as more retailers sign on to GFSI mandates for their suppliers. The best example I can give you is SQF 1000. Below is the scope statement from SQF 1000 level 1:

The SQF 1000 Code Level 1 outlines the general
food safety system requirements applied by a
Primary Producer for:
1. Field packing of fresh produce; and
2. Pre-farm gate production, harvesting and
preparation of primary products intended for
further processing.
The scope of SQF 1000 is intended to be primary
agricultural producers. Included in this scope for
application in produce is the grower/shipper/packer
who is packing self-grown product.

Looks like I had some thoughts today .

Feedback anyone?

Tom

[Jon5]

Tom-

That's right, I forgot about the SQF standard for primary producers. Thanks for your input.

Regarding the mutually dependent comment, you'll notice I used the term "farm to fork." I guess what I mean is that if you look at the entire process from the farm to the fork as a single process, if you're putting a food safety plan into place it's necessary to have food defense built into that plan, or you're not seeing the "big picture" and not adequately protecting the consumer or your company. By the same token, having a food defense plan in place without HACCP doesn't make much sense to me either.

Thanks.
Jon

Hi Jon -

Thanks for your input. Here's my opinion on your points one by one...


I disagree. You can have a very successful Food Defense Plan in place and keep the bad guys out while at the same time contaminating your product with chemicals used or monitored incorrectly or cross contaminating allergens through not having a plan in place for containment for example.


I totally agree with this. The "Standards" will continue to beef up the food defense portion of their schemes as the likelihood of food terrorism rises. Here in the US it looks more likely that it can and will happen, IMO.


Food Safety plans for primary producers are becoming more important as more retailers sign on to GFSI mandates for their suppliers. The best example I can give you is SQF 1000. Below is the scope statement from SQF 1000 level 1:

The SQF 1000 Code Level 1 outlines the general
food safety system requirements applied by a
Primary Producer for:
1. Field packing of fresh produce; and
2. Pre-farm gate production, harvesting and
preparation of primary products intended for
further processing.
The scope of SQF 1000 is intended to be primary
agricultural producers. Included in this scope for
application in produce is the grower/shipper/packer
who is packing self-grown product.

Looks like I had some thoughts today .

Feedback anyone?

Tom

[Mr. Incognito]

Hi Jon -

Thanks for your input. Here's my opinion on your points one by one...


I disagree. You can have a very successful Food Defense Plan in place and keep the bad guys out while at the same time contaminating your product with chemicals used or monitored incorrectly or cross contaminating allergens through not having a plan in place for containment for example.

Feedback anyone?

Tom

 

Tom I think the point he was trying to make about Food Defense and Food Safety Standards being mutually depenandt not independant was more that for a complete robust system one would need to have them together to completely protect their product rather than ignoring one or the other and being able to make safe food.

 

Such as having great GMP's, a robust HACCP system, Policies, Procedures, and the doors to the plant wide open for anyone to walk into.  Or having the entire plant secured but having operators not wash hands and spit in the product... lol

 

ok so those examples may be a bit off the deep end but I think that's why he was saying that in order to have a well protected product it must include both elements not just a focus on one side.

 

I agree with you on the point Jon.

[nancyhoffman]

Food defense is very hot law implemented by different government all over the world. Time will only tell that this scheme benefits the people or not.

[Mr. Incognito]

I think having a good security system in place is a good thing to keep people who don't belong inside the building outside but you'll never be able to stop a disgruntled employee from adulterating the food.  The best you can hope for is to see the signs that an employee is going to do something to damage the company and try to keep tabs on any such activity.

[cazyncymru]

This is the whole idea regarding carrying out a vulnerability study. Of course it won't be 100% guaranteed that nothing will ever happen, but at least it makes you think about what potentially could happen.

Yep, it's my favourite thing, a risk assessment!!

[syju28380]

PAS 96 guide is publicly available- http://www.food.gov....ction-guide.pdf

[SamBat]

I don't believe a separate food defence standard will come to being/popularity.  The majority of current major brands and standards (UK) already cover this off within there current policies / standards.

 

There has been an increased focus around it when being audited/site visits, but personally don't believe it warrants a separate standard.

[fepuhe]

We are implementing ISO 22K: 2018, in which the food defense plan is not mandatory.
However, management sees this as an important matter that must be addressed as well. Anyone has an idea, how can we start?