Home' FMCG Business : FMCG DEC 2015 Contents [Q&A]
conversations and ensure consumers, both here and
overseas, continue to have confidence in the safety of
New Zealand food.
Dr Larkin, what does your role at
the FPDI entail?
As the Research Director at the Food Protection
and Defense Institute (FPDI), I manage the research
programme, which includes research conducted at
FPDI and projects funded by the US Department of
Homeland Security (DHS) through FPDI. Our research
projects are directed at finding solutions to prevent
food defence incidents, identifying potential incidents, methods of
agent detection, supply chain risk reduction, information sharing, risk
analysis, and economically motivated adulteration. In addition to our
research programme I work with our education team to teach the next
generation of food defence experts.
How important is food defence in the US?
The best way to understand the importance of food defence in the US
is the passage of the Food Safety Modernization Act (FSMA). This is
the very first law that establishes a requirement that food companies
implement methods to prevent the intentional adulteration of foods
regulated by the US Food and Drug Administration (FDA).
All of us understand that food companies have used good
manufacturing practices (GMP’s) for many years to prevent the adulteration
of foods. With FSMA, food processors will not only need to have control
measures to prevent food adulteration from a food safety perspective, but
also a food defence possibility (final rule is due June 2016).
Food processors that are regulated by the United States Department
of Agriculture (USDA) have been allowed to voluntarily incorporate
food defence measures into their existing processing operations, with
the understanding that if as an industry they ignore food defence
mitigation steps there will be a USDA regulation making it mandatory.
The short answer to this question is – Very Important! The
United States no longer considers the incorporation of food defence
mitigation steps into the food processing operation an option.
What is your advice for New Zealanders?
Considering the 1080 threat, I believe collectively (government,
industry, trade association, and consumer) New Zealand must
establish a food defence policy for the food industry. The question
isn’t if New Zealand needs a food defence policy, but what is the best
method by which to implement the policy.
Prior to coming to work for FPDI, I worked 27 years for the
US Food and Drug Administration, so I understand the value and
limitations of what regulations can do for an industry. Based on what
I consider a unique collaborative government-industry environment
within New Zealand, the best plan would be for New Zealand to adopt
a voluntary food defence programme.
The voluntary programme cannot be a suggestion of what should be
done, but “voluntary” in that there isn’t a need for the government to
enact legislation and/or issue a Regulation, Notice, Order, Specification
or Standard. What I mean by this is for the whole food industry to
adopt a voluntary practice that is so effective and pervasive that the
government has no need to force the adoption of a standard.
I see this working because neither the consumer nor the food industry
can ideally allow someone to hold the country hostage with another
1080 type of incident. The best “food defence” is a “food offense.”
When I watched the World Cup it was clear that the All Blacks were not
going to assume they would win because of their past
experience – they planned to dominate and not allow
their opponents any thought of winning. The same needs
to hold true for the New Zealand food industry; your past
experience of limited food defence related incidents is no
forecast of what may happen in the future.
As an industry you need to plan on adopting a
policy that gives the terrorist no chance of winning,
i.e ., meeting their objective. One of the things that
must be characteristic of this new food defence policy
is sustainability. Often measures are adopted because
of the current risk, or past event, only to find that with
time the measures atrophy to the point of ineffectiveness.
Regulations, by their very nature, prevent the atrophy of a policy.
Thus, it is important for whatever policy the food industry adopts
that it is something that will still be in practice for a long time and
able to adapt to the food defence needs of the industry – otherwise
the government will need to come in and publish a food defence
regulation for the food processing community.
In addition to having the food industry establishing a sustainable
policy for food defence, the New Zealand government should start the
process of identifying how it will quickly and thoroughly process all
of the information that comes from both a food adulteration incident
and the criminal act. Consideration should be given to formation of a
permanent dedicated team that deals with criminal acts involving food.
This group may be cross-ministry in nature, having a working
relationship with the people within multiple ministries/departments.
The group needs to have food as its focus, but it may be primarily
composed of individuals knowing how to deal with criminal acts.
This is the group that will probably be responsible for the majority of
the investigation of the incident, working with all of the other subject
matter experts that will be needed for the incident. Relationships
between the necessary ministries/departments are key for this group to
be able to respond quickly and identify the perpetrator(s).
How can we further improve food protection in NZ?
The only thing that I want to add to the comments above is – education.
Each company needs to have a knowledgeable person who can
identify areas of vulnerability, steps that can be taken to mitigate these
vulnerabilities and how to make sure that the mitigation steps are enforced.
Most might say that I am biased, but I see the value of investing in a
University-based research/education/outreach programme in food defence
it is a great way to get research done that is needed for the industry and
to develop the future food defence scientists needed for the industry.
Dr John Larkin
ALL PLAYERS IN THE SUPPLY CHAIN
HAVE A ROLE TO PLAY IN
ENSURING WE HAVE ROBUST
SYSTEMS TO PROTECT
THE INTEGRITY OF
FMCG BUSINESS - DEC/JAN 2016 37
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