FMSA rule 21 CFR Part 121 (IA Rule): Mitigation Strategies to Protect Food Against Intentional Adulteration requires facilities to create and enact a food defense plan that protects from acts of intentional adulteration intended to cause harm to consumers. Food defense activities are often confused with food fraud mitigation, but the two topics are mutually exclusive. How can you tell the difference and prepare for both?
Motivation makes the difference.
Food Defense is the need to protect against food adulteration within the manufacturing site. Although Food Defense has always been a requirement of GFSI-benchmarked standards, it has come back into focus with the final IA Rule and is commonly confused with Food Fraud.
“The process to ensure the security of food and drink from all forms of intentional malicious attack including ideologically motivated attack leading to contamination.” (GFSI 2017)
The purpose of a food defense plan is to protect against acts intended to cause harm to the public, consumers or companies from within the manufacturing site. Potential threats range from relatively common tamper hoaxes to less probable terrorist attacks. Common controls include fences, security cameras, plant sign-in procedures and manned security.
According to the IA Rule, “individuals assigned to work at actionable process steps and their supervisors, are required to receive training in food defense awareness.”
The FDA created an Intentional Adulteration Subcommittee with the Food Safety Preventive Controls Alliance (FSPCA) to develop food defense resources to prepare your company to develop and implement a food defense plan. The free online course takes only 20-30 minutes and those who complete the training receive a certificate from FSPCA.
Access the training here: FSPCA Food Defense Awareness for the IA Rule
Food Fraud happens at the supplier level. It is the need to protect against adulteration and verify that the ingredients you are buying are truly what they should be and not altered accidentally or intentionally.
The intentional adulteration, substitution or mislabeling of food ingredients can pose serious health risks for consumers and permanently damage the reputation of producers and suppliers around the globe. In response to this threat, regulators and the Global Food Safety Initiative have set new requirements for food fraud vulnerability assessments and mitigation strategies as part of the food safety management system.
“Food Fraud is the collective term encompassing the intentional substitution, addition, tampering or misrepresentation of food/feed, food/feed ingredients or food/feed packaging, labelling, product information or false or misleading statements made about a product for economic gain that could impact consumer health.” (GFSI BRv7 2017)
The new food fraud requirements with GFSI benchmarked standards (SQF, BRC, FSSC 22000) are aimed at minimizing the risk for food fraud by reducing opportunities for fraudsters to reach consumers through monitoring, corrective actions, training and recordkeeping, and evaluation.
Eurofins offers a comprehensive catalog of food fraud services.
Digital imagery created by Monika Sharma.