Happy New Year and welcome to 2019 — a year when we will all improve our lots in life and continue to provide the best in food safety services to our employers and consumers.
Brought to us by FDA and FSMA, the Intentional Adulteration Rule is upon us. This new rule took effect in May 2016 and requires a Food Defense Plan that identifies actionable process steps for your operation and focused mitigation strategies for any actionable process steps that you identify. The program is along the lines of HACCP, requiring monitoring, corrective actions, and verifications.
Sounds easy, right? We’ve all completed HACCP and other risk assessments before — we’re good at it now. Simply complete a vulnerability assessment and set up your programs based on what you determine is reasonably likely to occur.
But, aren’t all of your process steps, from the farm to the package and distribution, vulnerable to some sort of tampering if you are not there watching all the time? How will you define what is a vulnerability; and then, how will you provide some sort of mitigation? Difficult questions, eh?
Luckily for us, FDA has helped out by providing a database of potential mitigation strategies for most steps of food handling processes, and we can all find that on the FDA website.
So, what happens when you suspect a tampering event — whether it be an intentional poisoning or an economically motivated adulteration (EMA), as covered in the Preventive Controls Rule? Or worse, you’ve been told of an event but don’t know what the product is or what it has been tampered with? What potential poison was added? What economically motivated adulterant was added or substituted? I’m starting to see a need for food sleuths — or as the police might call it: food forensics.
Who is your food forensics expert? Is it someone internal to your company, a consultant, FDA maybe? How do you know what to look for? Is there a test for that? What level of detection are you looking for? Maybe your food forensics expert can help.
According to Wikipedia, forensic science is defined as “the application of science to criminal and civil laws, mainly — on the criminal side — during criminal investigation, as governed by the legal standards of admissible evidence and criminal procedure.”
This new field for food scientists will involve collecting, preserving, and analyzing scientific evidence as part of an investigation to determine what food has been tampered with and how. This will mean trying to determine what has happened to the food (typically something added — a poison or economic hazard), what this means to the safety of the food, and what to do about it.
Not too long ago, milk powders were adulterated with melamine to make the protein levels look higher than actual. And now, we also know that many honeys are adulterated with other, less expensive, syrups. Our new food forensics specialists will need to understand the foods and how they are manufactured and routinely tested to know what could be done to them from a poisoning or EMA standpoint. There are good people out there sleuthing to help prevent the next incident.
I don’t have an answer to food defense concerns but hope each of you has a good food sleuth on staff (or retainer) so that you are ahead of the criminals. If you don’t have one, I’m hoping that some of our educational institutions will take this opportunity to create some graduate degrees in food forensics so that we can all have access to these newly minted specialists.