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- Herausgeber: John Wiley & Sons
- Kategorie: Fachliteratur
- Serie: Institute of Food Technologists Series
- Sprache: Englisch
Food safety has been a global concern for many years. While global sourcing of foods and ingredients provides great opportunity for variety and diversity of cultural products, there are significant risks. Programs that regulate food safety and quality in countries around the world vary in their scope and effectiveness, with many being underfunded. Rapidly developing countries may lack the expertise, laboratory resources for testing, and established inspection programs to adequately promote the safety of foods. Rather, these countries may be more focused on providing enough food for their citizens. Lack of documentation or traceability in the exporting country can further exacerbate the situation. Of course, safety problems in food imported from more developed countries also occur, and the source of food borne disease outbreaks are found regularly within the United States.
Improving Import Food Safety gathers together vital information on the food safety programs of national governments, the food industry, and the testing industry. Chapters have been contributed by authors from the United States, Latin America, Europe, and Asia. Readers will learn about a variety of regulatory approaches to food safety at the federal and state levels in the United States, as well as in selected countries and within the food industry itself. They will also gain insights into the nature and source of safety problems, in addition to approaches to food safety around the world.
The book is divided into three sections:
- Highlighting Key Issues: authors illustrate the millions of permutations for the origin of ingredients, discussing the difficulty if policing imports, providing a unique perspective on the economic situation in China and insight into development of support for small farm producers in Mexico.
- Legal and Regulatory Issues/Structures in the USA and Abroad: describes the legal and regulatory system in the European Union, the United States, and China, plus a chapter addressing global approaches to fraud.
- Potential Strategies to Improve Import Safety: presents strategies to deal with what are ultimately global issues, but on multiple levels. Perspectives are provided by authors from Industry, and industry trade association, academia, and a recently semi-retired, global ambassador or food safety.
Readers will find this book noteworthy because of the diverse topics and perspectives offered on the challenges of keeping food safe in a global economy. Authors come from a variety of backgrounds, and each has provided a unique perspective on this critical topic. The volume is aimed at importers and exporters of food and ingredients; food microbiologists, food safety and QC/QA personnel; regulatory and legal personnel in food manufacturing companies; food policy makers and regulatory officials and facility and graduate students in food science.
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Seitenzahl: 548
Veröffentlichungsjahr: 2012
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Contents
Contributors
Preface
Acknowledgment
Part I Highlighting Key Issues
Chapter 1 Emerging Global Food System Risks and Potential Solutions
Overview
Supply Chain Complexity
Increasing Role of Imports
Unusual Sources for Imports
Other Emerging Food Safety Risks
Economically Motivated Adulteration
Other Emerging Intentional Threats
Potential Solutions
Conclusions
Chapter 2 A Cooperative Federal–State Approach for Monitoring Imported Foods: Reviewing the New York State Model
Introduction
State and Local Government Strengths
The New York Model for a Cooperative Federal–State Approach for Monitoring the Safety of Imported Food
Examples of Violative Imported Food Products Found in the Pilot Cooperative Project
Discussion
Conclusions
Chapter 3 The Impact of the Chinese Development Model on Food Safety
Introduction
China’s Explosive Economic Growth and its Impact
China as a Growing Food Superpower
China’s Food Safety Regimes
China’s Food Safety Challenges
Conclusions
Chapter 4 The Role of Public–Private Partnerships on the Access of Smallholder Producers of Mexican Cantaloupe to Fresh Produce Export Markets
Foodborne Outbreaks and the Increasing Demand for Food Safety in Fruit and Vegetables
Production Trends of the Cantaloupe Industry in Mexico
Responses to Food Safety Problems Associated with Cantaloupe Outbreaks
Major Barriers to Market Access for Small Mexican Producers in the Cantaloupe Supply Chain
The Role of Private–Public Partnerships in Facilitating Smallholders to Overcome Barriers to Export Market Entry
Summary and Conclusions
Part II Legal and Regulatory Issues/Structures in the United States and Abroad
Chapter 5 Improving US Regulation of Imported Foods
Introduction
The Major Federal Agencies
The FDA Import Process
Prior Notice of Import
USDA’s Import System
Other Import Controls
Country-of-origin Labeling
Challenges Facing Import Regulation
International Standards – Codex
Conclusions
Chapter 6 EU Food Safety Regulation and Trust-enhancing Principles
Introduction
Food Regulation: Between Market and Safety
The EU’s Failings in Ensuring Food Safety
The EU’s New Regime on Food Safety Regulation
Restoring Trust in EU Decision-making on Foods
Concluding Remarks
Acknowledgment
Chapter 7 Experience of Food Safety Authorities in Europe and the Rapid Alert System
Introduction
The EU Approach to Legislation in the Food Sector
Food Crises
Risk Assessment and Risk Management and the EFSA
The Rapid Alert System for Food and Feed
Chapter 8 The Development of and Challenges Facing Food Safety Law in the People’s Republic of China
Introduction
From “Food Hygiene” to “Food Safety”: A Brief History of the Development of China’s Food Safeguard System (1978–2009)
China’s Food Safeguard System Today
The Challenges China Faces in Food Safeguard Improvement
Conclusions
Acknowledgments
Chapter 9 Defining Food Fraud and the Chemistry of the Crime
Introduction
Food Fraud
Diversion, Parallel Trade, and Gray Market
Criminology and the Chemistry of the Crime
Improving Import Food Safety
Conclusions
Part III Potential Strategies to Improve Import Safety
Chapter 10 Tracking and Managing the Next Crisis
Introduction
Tracking the Next Crisis
Issue Management Tools
Conclusion
Chapter 11 Food Product Tracing
Introduction
Current US Recordkeeping Requirements
Global Recordkeeping Guidance and Practices
Commercial Product Tracing Standards
Food Industry Factors Affecting Traceability
Recommendations for Product Tracing
Commingling – A Special Case for Product Tracing
Traceability Versus Recall Ability
Product Tracing as a Food Safety Tool for Imports
Chapter 12 Improving the Safety of Imported Foods with Intelligent Systems: The Case of United States–Mexico Fresh Produce Supply Chain
Introduction
Assessment of Threat and Vulnerability
Data and Procedure
Optimal Control Procedure
Results and Discussion
Appendix
Chapter 13 Testing with Confidence in the Pursuit of Global Food Safety
Introduction
AOAC® International: Official Methods of Analysissm
Evolution of Method Development and Validation
AOAC Research Institute
Initial Step in AOAC Harmonization of Rapid Microbiological Test Kits
The AOAC Guidelines Under Revision
Chapter 14 Global Food Protection: A New Organization is Needed
Introduction
Background
Proposal
Conclusion
Chapter 15 Summary and Recommendations for the Safety of Imported Foods
Introduction
Summary of Current Concerns
Recommendations to Improve the Safety of Imported Foods
Concluding Recommendations
Conclusion
Acknowledgments
Index
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The IFT Press series reflects the mission of the Institute of Food Technologists — to advance the science of food contributing to healthier people everywhere. Developed in partnership with Wiley-Blackwell, IFT Press books serve as leading-edge handbooks for industrial application and reference and as essential texts for academic programs. Crafted through rigorous peer review and meticulous research, IFT Press publications represent the latest, most significant resources available to food scientists and related agriculture professionals worldwide. Founded in 1939, the Institute of Food Technologists is a nonprofit scientific society with 18,000 individual members working in food science, food technology, and related professions in industry, academia, and government. IFT serves as a conduit for multidisciplinary science thought leadership, championing the use of sound science across the food value chain through knowledge sharing, education, and advocacy.
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Library of Congress Cataloging-in-Publication Data
Improving import food safety / editors Lorna Zach, Wayne Ellefson, Darryl Sullivan.p. cm. – (Institute of Food Technologists Series)Includes bibliographical references and index.
ISBN 978-0-8138-0877-2 (hardback)1. Food–Safety measures. 2. Food–Safety regulations. 3. Food industry and trade–Safety measures. 4. Food–Standards. I. Zach, Lorna. II. Ellefson, Wayne. III. Sullivan, Darryl M.TX537.I47 2013363.19′26–dc23
2012028573
A catalogue record for this book is available from the British Library.
Wiley also publishes its books in a variety of electronic formats. Some content that appears in print may not be available in electronic books.
Cover design by Meaden Creative
Titles in the IFT Press series
Accelerating New Food Product Design and Development
(Jacqueline H. Beckley, Elizabeth J. Topp, M. Michele Foley, J.C. Huang, and Witoon Prinyawiwatkul)
Advances in Dairy Ingredients
(Geoffrey W. Smithers and Mary Ann Augustin)
Bioactive Proteins and Peptides as Functional Foods and Nutraceuticals
(Yoshinori Mine, Eunice Li-Chan, and Bo Jiang)
Biofilms in the Food Environment
(Hans P. Blaschek, Hua H. Wang, and Meredith E. Agle)
Calorimetry in Food Processing: Analysis and Design of Food Systems
(Gönül Kaletunç)
Coffee: Emerging Health Effects and Disease Prevention
(YiFang Chu)
Food Carbohydrate Chemistry
(Ronald E. Wrolstad)
Food Ingredients for the Global Market
(Yao-Wen Huang and Claire L. Kruger)
Food Irradiation Research and Technology
(Christopher H. Sommers and Xuetong Fan)
Foodborne Pathogens in the Food Processing Environment: Sources, Detection and Control
(Sadhana Ravishankar, Vijay K. Juneja, and Divya Jaroni)
High Pressure Processing of Foods
(Christopher J. Doona and Florence E. Feeherry)
Hydrocolloids in Food Processing
(Thomas R. Laaman)
Improving Import Food Safety
(Wayne C. Ellefson, Lorna Zach, and Darryl Sullivan)
Innovative Food Processing Technologies: Advances in Multiphysics Simulation
(Kai Knoerzer, Pablo Juliano, Peter Roupas, and Cornelis Versteeg)
Microbial Safety of Fresh Produce
(Xuetong Fan, Brendan A. Niemira, Christopher J. Doona, Florence E. Feeherry, and Robert B. Gravani)
Microbiology and Technology of Fermented Foods
(Robert W. Hutkins)
Multiphysics Simulation of Emerging Food Processing Technologies
(Kai Knoerzer, Pablo Juliano, Peter Roupas, and Cornelis Versteeg)
Multivariate and Probabilistic Analyses of Sensory Science Problems
(Jean-François Meullenet, Rui Xiong, and Christopher J. Findlay
Nanoscience and Nanotechnology in Food Systems
(Hongda Chen)
Natural Food Flavors and Colorants
(Mathew Attokaran)
Nondestructive Testing of Food Quality
(Joseph Irudayaraj and Christoph Reh)
Nondigestible Carbohydrates and Digestive Health
(Teresa M. Paeschke and William R. Aimutis)
Nonthermal Processing Technologies for Food
(Howard Q. Zhang, Gustavo V. Barbosa-Cánovas, V.M. Balasubramaniam, C. Patrick Dunne, Daniel F. Farkas, and James T.C. Yuan)
Nutraceuticals, Glycemic Health and Type 2 Diabetes
(Vijai K. Pasupuleti and James W. Anderson)
Organic Meat Production and Processing
(Steven C. Ricke, Ellen J. Van Loo, Michael G. Johnson, and Corliss A. O’Bryan)
Packaging for Nonthermal Processing of Food
(Jung H. Han)
Preharvest and Postharvest Food Safety: Contemporary Issues and Future Directions
(Ross C. Beier, Suresh D. Pillai, and Timothy D. Phillips, Editors; Richard L. Ziprin, Associate Editor)
Processing and Nutrition of Fats and Oils
(Ernesto M. Hernandez and Afaf Kamal-Eldin)
Processing Organic Foods for the Global Market
(Gwendolyn V. Wyard, Anne Plotto, Jessica Walden, and Kathryn Schuett)
Regulation of Functional Foods and Nutraceuticals: A Global Perspective
(Clare M. Hasler)
Resistant Starch: Sources, Applications and Health Benefits
(Yong-Cheng Shi and Clodualdo Maningat)
Sensory and Consumer Research in Food Product Design and Development
(Howard R. Moskowitz, Jacqueline H. Beckley, and Anna V.A. Resurreccion)
Sustainability in the Food Industry
(Cheryl J. Baldwin)
Thermal Processing of Foods: Control and Automation
(K.P. Sandeep)
Trait-Modified Oils in Foods
(Frank T. Orthoefer and Gary R. List)
Water Activity in Foods: Fundamentals and Applications
(Gustavo V. Barbosa-Cánovas, Anthony J. Fontana Jr., Shelly J. Schmidt, and Theodore P. Labuza)
Whey Processing, Functionality and Health Benefits
(Charles I. Onwulata and Peter J. Huth)
Contributors
Belem Avendano, PhDProfessorSchool of Economics and International RelationsUniversidad Autonoma de Baja California, MéxicoVicki Bier, PhDProfessorDepartment of Industrial and Systems EngineeringDirector Center for Human Performance and Risk Analysis University of Wisconsin–MadisonMadison, WI, USAHenry Chin, PhDThe Coca-Cola CompanyAtlanta, GA, USAJoe CorbyExecutive DirectorAssociation of Food and Drug OfficialsYork, PA, USAChuckCzuprynski, PhDProfessorDepartment of Pathobiological SciencesDirector Food Research InstituteFood Research Institute and Department of Pathobiological SciencesUniversity of Wisconsin–MadisonMadison, WI, USAM. Ellin Doyle, PhDFood Research InstituteUniversity of Wisconsin–MadisonMadison, WI, USANeal Fortin, JDProfessor and DirectorInstitute for Food Laws and RegulationsMichigan State UniversityEast Lansing, MI, USANa HuGraduate Research AssistantArizona State UniversityPhoenix, ArizonaMaia Jack, PhD, GMAGrocery Manufacturers AssociationWashington DC, USAWenran Jiang, PhDMactaggart Research Chair, China InstituteDepartment of Political ScienceUniversity of AlbertaEdmonton, CanadaRonald L. JohnsonbioMeriuex Inc.Durham, NC, USAAlbert Kagan, PhDAssociate ProfessorArizona State UniversityPhoenix, ArizonaShaun Kennedy, PhDDirector, National Center for Food Protection and DefenseAssistant ProfessorVeterinary Population MedicineUniversity of MinnesotaSt Paul, MN, USARobert E. Koeritzer3 M Food SafetySt Paul, MN, USAJennifer McEntire, PhDLeavitt PartnersWashington, DC, USAClare Narrod, PhDResearch Scientist and Risk Analysis Program ManagerUniversity of MarylandCollege Park, MD, USAWilliam Nganje, PhDAssociate ProfessorMorrison School of Agribusiness and Resource Management Arizona State UniversityPhoenix, ArizonaNancy Rachman, PhDSenior Director, Safety Evaluation and Scientific AffairsGrocery Manufacturers AssociationWashington DC, USATimothy Richards, PhDProfessorMarvin and June Morrison Chair of Agribusiness and Resource ManagementMorrison School of Agribusiness and Resource ManagementArizona State UniversityPhoenix, ArizonaYuanyuan Shen, JDProfessor of LawZhejiang University Law SchoolHangzhou, ChinaAdjunct Faculty, Boston College Law SchoolChesnut Hill, MA, USAandAssociate in ResearchFairbank Center for the East Asian ResearchHarvard UniversityCambridge, MA, USAWilliam H. Sperber, PhDGlobal Ambassador for Food ProtectionCorporate Food Safety and Regulatory AffairsCargill, Inc.Minnetonka, MN, USAJohn Spink, PhDAssociate Director and Assistant ProfessorAnti-Counterfeiting and Product Protection ProgramSchool of Criminal JusticeMichigan State UniversityEast Lansing, MI, USAMarites Tiongco, PhDResearch FellowMarkets, Trade and Institutions DivisionInternational Food Policy Research Institute,Washington, DC, USAEllen Vos, JD, PhDProfessor of European Union Law, Law Faculty,Co-director of the Maastricht Centre for European Law,Fellow at the Institute for Globalisation and International Regulation (IGIR),Maastricht UniversityMaastrichtThe NetherlandsRoger WoodRetiredFood Standards AgencyLincolne Sutton and WoodNorwich, UKLorna Zach, PhDFood System SolutionsMt Horeb, WI, USACenter for Human Performance and Risk AnalysisUniversity of Wisconsin–MadisonMadison, WI, USA
Preface
Food safety has been a global concern for many years. Industry leaders have invested billions of dollars to try to ensure the safety of their products, while regulators from governments around the world have promulgated laws to try and protect consumers from unsafe food. Over the past 5 to 10 years the ability to detect foodborne outbreaks has become much more sophisticated. Today we can detect food safety problems and correlate them with illnesses and adverse reactions faster than ever before. As these problems are detected, the media has brought these situations to the attention of consumers around the world.
Programs that regulate food safety and quality in countries around the world vary in their scope and effectiveness, with many being underfunded. Rapidly developing countries may not have the expertise, laboratory resources for testing, and established inspection programs to adequately promote safety of foods. Rather, these countries may be more focused on providing enough food for their citizens. Lack of documentation or traceability in the exporting country can further exacerbate the situation. Of course, safety problems in food imported from more developed countries also occurs and we regularly find the source of foodborne disease outbreaks within our own country.
In this book we have gathered information about food safety programs from governments, the food industry, and the testing industry. Chapters have been contributed by authors from the United States, Latin America, Europe, and Asia. You will be able to learn about a variety of regulatory approaches to food safety at the federal and state levels in the United States, as well as in a few selected countries, and within the food industry itself. You may also gain insights into the nature and source of problems, in addition to approaches to food safety around our world.
In the first set of chapters the magnitude of the entire food safety issue is highlighted. The authors bring this forth in dramatic fashion, illustrating the millions of permutations for the origin of ingredients, discussing the difficulty of policing imports, providing a unique perspective on the economic situation in China, and insight into the development of support for small farm producers in Mexico.
Doing business in today’s global economy calls for understanding the environment in which our trading partners work. We must understand their difficulties in production as well as the laws and regulations under which they work. Therefore, we have included a second section of chapters describing the legal and regulatory system in a variety of countries: the European Union, the United States, and China. We have also included a chapter addressing global approaches to fraud, but very much based on the US system. However, we have not delved into the Food Safety Modernization Act of 2011 because as we write this, the rules are being written.
The last section approaches the complex issue of food safety and presents potential strategies to deal with what are ultimately global issues, but on multiple levels. Perspectives are provided by authors from industry, an industry trade association, academia, and a recently semi-retired, global ambassador of food safety. A number of suggestions for improving food safety are discussed, as well ideas for new programs and processes.
The reader will find this book noteworthy because of the diverse topics and perspectives offered on challenges of food safety in a global economy. The authors come from a variety of backgrounds and each of them has provided a unique perspective on this critical topic. The background information that is provided will give the reader a broad perspective and solid understanding of the global nature of food safety issues. The chapters addressing regulatory structures will round out the readers’ understanding of the topic, and the authors’ insights into different ways to improve food safety will leave the reader with a multitude of “thought provoking” ideas.
Lorna ZachCenter for Human Performance and Risk Analysis, University of Wisconsin–Madison, and USA and System Solutions for the Food IndustryWayne EllefsonCovance Laboratories, Inc.Darryl SullivanCovance Laboratories, Inc.
Acknowledgment
The editors wish to thank the Center for World Affairs and the Global Economy (WAGE) at the University of Wisconsin – Madison for funding the multi-disciplinary collaborative project, “Managing Challenges of Import Safety in a Global Economy”, which provided funding to bring many of the chapter authors for this volume to campus for university seminars and conferences.
The editors thank Covance Laboratories, Inc. for their support of this book.
Lorna Zach acknowledges partial support for her work on this book from the University of Wisconsin-Madison, Center for World Affairs and the Global Economy (WAGE) and the Center for Risk and Economic Analysis of Terrorism Events (CREATE) at the University of Southern California under Grant No. 2007-ST-061-000001 from the Department of Homeland Security, Science and Technology Directorate, Office of University Programs. She also wishes to thank Professor Vicki Bier of the Department of Industrial and Systems Engineering and the Center for Human Performance and Risk Analysis.
Part I
Highlighting Key Issues
Chapter 1
Emerging Global Food System Risks and Potential Solutions
Shaun Kennedy
Overview
The food system is becoming ever more globally integrated, providing a broader array of foods available all year long than ever before. This adaptive, dynamic system does this very rapidly and at very low cost due to the high efficiency of the food and agriculture supply firms and chains. Globalized, just-in-time and cost-optimized supply chains do not come without concomitant risks. The lengthening of a supply chain and the inclusion of firms of different scales inherently increases the risks associated with that supply chain. Sourcing from a wide range of countries also places a reliance on the food protection (safety and defense) systems of the source country to protect consumers in the country of consumption. One of the challenges of this reliance is that, in some cases, the actual source of the product or ingredient may be difficult for regulators, or in some cases even food-system firms, to discern due to how data are captured and shared in food supply chains. Dynamic import risks and other emerging risks, demonstrate the need for new mitigation strategies to reduce the risk to public health from our globally interdependent food system.
Figure 1.1. A simplified characterization of the supply chain for a cheeseburger. (Copyright 2010 National Center for Food Protection and Defense. All rights reserved.)
Supply Chain Complexity
The supply chain for even apparently simple items can be much more complicated than it would appear, especially if it is a multicomponent product where the supply chain of each ingredient or component must be considered as well. Figure 1.1 provides a simplified characterization of the supply chain for a quick service restaurant sandwich. The 11 basic components of this item make their way from primary production to consumption through a simplified supply chain that includes harvest, storage, production, and retail food service to the consumer, with transportation between each step. Considering this simple system, a contamination that could occur at three, unspecified points in the supply chain for the item represents over 45 000 permutations and combinations of potential contamination scenarios. All of the potential scenarios would have the potential to cause harm, either public health or economic, or in some cases both.
Figure 1.2. All of the ingredients in a McDonald’s Big Mac. (Graphic copyright 2010 National Center for Food Protection and Defense. All rights reserved.)
Consider, however, that the actual composition of a cheeseburger, for illustration purposes a Big Mac as per McDonald’s nutritional information, contains all of the ingredients shown in Figure 1.2. Considering the same threat, that the supply chain is contaminated in three locations but no indication of where, means that there are over two million permutations and combinations of potential contamination scenarios. This does not take into account how much more complicated it would become with the inclusion of each of the ingredient’s supply chains. This is one reason why multicomponent foods, which are a rising source of foodborne illness outbreaks, pose a significant challenge during foodborne illness outbreak epidemiology and food trace-back investigations. While this complexity is obviously important for food safety, it is perhaps more important for food defense as there are many more ingredients that are viable candidates for intentional contamination than are likely to be the vehicle for accidental food safety contamination.
Imports further complicate existing food protection challenges. While only the producer would have the opportunity to know the probable origin of the ingredients in the finished product, looking at where they could come from is enlightening. Choosing just four of the ingredients from Figure 1.2 illustrates this point: imports of beef into the United States in 2010 came from 10 countries (Australia, Canada, Chile, Costa Rica, Honduras, Japan, Mexico, New Zealand, Nicaragua, and Uruguay); imports of tomatoes from 12 countries (Belgium, Canada, China, Costa Rica, Dominican Republic, France, Guatemala, Israel, Mexico, Netherlands, New Zealand, and the United Kingdom); imports of wheat gluten from 17 countries (Australia, Belgium, Canada, China, France, Germany, India, Italy, Kazakhstan, Lithuania, Netherlands, Poland,Sweden,Switzerland, Taiwan, Thailand, and Turkey); and imports of vinegar from 36 countries (Argentina, Australia, Austria, Belgium, Brazil, Cambodia, Canada, Chile, China, Colombia, Dominican Republic, France, Germany,Greece, Honduras, Hong Kong, Israel, Italy, Japan, Jordan, Korea,Lebanon, Mexico, Monaco, Netherlands, Panama, Peru, Philippines, Poland, Portugal, Serbia, South Africa, Spain, Taiwan, Turkey, and the United Kingdom) (US Department of Agriculture Foreign AgriculturalService, 2008). These countries encompass a wide range of food protection system capabilities and challenges.
Increasing Role of Imports
Food and agriculture imports have been rising rapidly, accelerating as early as 2003. In 2003 the total food and agriculture imports to the United States totaled just over $35 billion. In 2010, that increased to nearly $82 billion (US Department of Agriculture, 2010). This rate will likely accelerate in the coming years. This is driven by a number of factors, including: increased food and agriculture industries outside the United States; consumer desire for a wide variety of fresh fruits and vegetables; increased consumption of seafood; and many others. While the United States continues to be a net exporter of food and agriculture, there are more food manufacturing firms registered to produce food for United States consumption in FDA’s Bioterrorism Registration Database outside the United States (150 000) than in the United States (130 000).
Table 1.1. The most imported foods and ingredients from selected countries.
Country
Import
Albania
Sage
Azerbaijan
Juices
Bosnia/Herzegovina
Pastry
Cambodia
Honey
Chad
Gums
Georgia
Fruit juice
Haiti
Cocoa beans
Iran
Juices
Kazakhstan
Wheat gluten
Kyrgyzstan
Walnuts
Lebanon
Fruit/nut preparation
Mongolia
Honey
Pakistan
Rice
Sri Lanka
Tea
Sudan
Gums
Syria
Olive oil
Venezuela
Sesame seeds
Yemen
Coffee
Zimbabwe
Sugar
Unusual Sources for Imports
The globalization of the food system results in more countries being sources of food products for the United States than ever before. The countries are not always, however, those that you would expect. Table 1.1 is a selective list of source countries and the foods and ingredients imported most from those countries in 2008 (US Department of Agriculture, 2010). These sources may have food safety and defense systems that are different, either better or worse, than those of the United States. In some cases they also may not be a rational source of the commodity. At a US Governmental level this is a challenge because the only source of data on country of origin is what is captured through import data collections under the tariff system. For tariff purposes, the country of origin is the one that represents > 50% of the economic value of the item at the border.
As an example of tariff rules, consider how Canada can be identified as the single largest source of cocoa and cocoa preparations for the United States (US Department of Agriculture, 2010), even though there is no cocoa grown in Canada. Since cocoa beans are often further processed outside of the growing country, including Canada, it seems reasonable that the economic value of the cocoa butter, chocolate blocks, or other products coming into the United States could represent > 50% Canadian added value. Less obvious, however, is that Canada is the second largest source of citric acid at 40% of total citric acid imports in 2010, even though there are no citric acid production facilities in Canada. The economic value, for tariff purposes includes all costs: transportation, labor, and packaging. Bulk receipt of a product in Canada that is then blended or ground or otherwise handled and then packed off into smaller unit sizes before being shipped to the United States could end up being assessed as > 50% Canadian economic value, as is evidently the case for citric acid. The tariff system was developed to protect the private sector from unfair business practices, as a result its use as a public health tool to validate the source of materials is of variable utility.
There are other cases where the fact that the country is even a source of imported foods, juices from Iran for example, is itself surprising. There are others where the country is a source of a food or ingredient that does not seem logical, such as fish being the largest import from Kazakhstan whose main agriculture industries, as identified in the Central Intelligence Agency World Fact Book, are wheat, cotton, and livestock.
Examining a specific commodity in detail yields other surprises. Table 1.2 lists all the countries that were sources of shrimp into the United States in 2010 (US International Trade Commission, 2010). While most are obvious sources, such as Vietnam and Thailand, there are some that are somewhat surprising. When shrimp products are included, which includes processed foods, another non-obvious source country like Estonia is added to the list. There are also cases where the import data may reflect trans-shipment or further processing through a country that is not a normal source of the base commodity. For example, several of the countries listed have no significant shrimp aquaculture, whether farmed or wild caught, and are not large food processing countries.
Table 1.2. Countries that imported shrimp to the United States in 2010.
Argentina
Guyana
Philippines
Australia
Honduras
Portugal
Bangladesh
Hong Kong
Russia
Belize
India
Saudi Arabia
Brazil
Indonesia
Singapore
Canada
Japan
South Africa
Chile
Korea
Spain
China
Madagascar
Sri Lanka
Colombia
Malaysia
St Helena
Costa Rica
Mexico
Suriname
Cote D’ivoire
New Caledonia
Taiwan
Denmark
New Zealand
Thailand
Ecuador
Nicaragua
United Arab Emirates
El Salvador
Nigeria
United Kingdom
Estonia
Pakistan
Venezuela
Gambia
Panama
Vietnam
Guatemala
Peru
New source countries and supply chains for raw agricultural products, ingredients and processed foods will continue to emerge. Primary agricultural production and value-added food processing are two key ways in which developing nations can build their economy.The economic growth comes both through domestic consumption by raising the living standards of rural populations and by building an export base. Recognition of the benefits of building a food and agriculture industry is why there is so much investment in food and agriculture development by organizations such as the United Nations, US Department of Agriculture, US Agency for InternationalDevelopment, and others. The Gates Foundation has dedicated over $280 million to find ways of increasing the farm productivity and income to help lift African nations out of poverty. An interesting example, at least from a perceived risk point of view, is the United States investment of $12 million in Afghanistan to help develop a pomegranate industry. Pomegranate is important because it is one of the very few crops that can be as profitable as poppy, the source crop for opium, and Afghanistan grown pomegranate are reputed to be among the best in the world. Given the instability in Afghanistan, imported pomegranate juice labeled as “Product of Afghanistan” might face some consumer confidence challenges, both for food safety and food defense. In the face of such concerns, it is important to build the food protection infrastructure in the developing world, both public and private, as their food and agricultural production infrastructure develops. If the food protection infrastructure is not advanced as developing countries are growing their food and agriculture industry, the growth actually may subject consumers to greater food protection risks.
Other Emerging Food Safety Risks
There are a number of other trends which are increasing food safety risks that need to be considered in the context of the global food system. TheSalmonella Saintpaul outbreak of 2008 associated with fresh produce was an example of novel agent–vehicle combinations. Many of the foodborne illness outbreaks over the past several years have involved new agent and food vehicle combinations. New agent–vehicle combinations present significant challenges for risk assessment and risk management, especially during early outbreak investigation.
Consumers’ desire for more fresh produce and minimally processed or ready to eat foods is another source of emerging risk. In the period 1998–2007 over 684 foodborne illness outbreaks in the United States were associated with produce, only 15% of the total, but they were associated with over 23% of the illnesses (Center for Science in the Public Interest, 2009). The US Department of Agriculture (USDA) estimates that fruit and produce consumption will significantly increase by as much as 8% per capita from 2000 to 2020 (Lin, 2004). Foodborne illness outbreaks associated with produce now represent a larger portion of the total outbreaks than ever due to the combination of increased consumption, the type of produce, and what in-home handling practices are being employed. As initiatives to move to healthier diets that include more fruit, produce, and seafood and less highly processed foods increase, foodborne illness risks may continue to rise.
Industry consolidation and the broad use of common ingredients also pose significant emerging risks. The Peanut Corporation of America (PCA) processed less than 2% of the peanuts harvested in the United States. The recall of its products in 2009 now ranks as the single largest recall in US history. It is at first surprising that PCA could be responsible for a foodborne illness outbreak with at least 714 cases in 46 states, until the ubiquitous use of the contaminated products are considered. As a result, at least 2100 products from 200 companies were recalled. It is, however, just one example of an ingredient that is used broadly from a small number of suppliers. The peanut paste that was PCA’s primary product found its way into everything from granola bars to ice cream.
As demonstrated by the Peanut Corporation of America (PCA) outbreak and recall, products can go through an intricate web of distributors and manufacturers, in some cases going through several interim manufacturers before ending up in the final consumer product. The complexity of the path from source, through one or more processors and distributors, into a wide array of final products makes it very difficult to rapidly trace all ingredients to their source or to trace the ingredients to final consumer products. That is why some products were being added to the PCA recall as late as 2010 when the initial recall was announced in early January of 2009. If the common ingredient has an international origin, this becomes even more challenging due to the existing difficulty in just accurately determining the country of origin of imported materials.
Economically Motivated Adulteration
The melamine contamination of wheat gluten that resulted in illness in pets in the United States in 2006–2007 attracted public attention to a long-standing industry problem, economically motivated adulteration. Adulterating a food or ingredient in order to have a lower quality item appear to be of higher quality to make a profit drove some of the earliest food laws. This includes adulteration of wines in ancient Greece to thirteenth century food laws in Germany and France and the Assize of Bread proclamation by King John in 1202. Economically motivated adulteration is a significant and growing problem, driven by globalization, economic opportunity, and low probability and severity of punishment. A Grocery Manufacturers Association study estimates that an economically motivated adulteration event results in losses on the order of 2–15% of net annual sales for the firm (Grocery Manufacturers Association and Kearney, 2010). In Europe, reports into the Rapid Alert System for Food and Feed identified 256 “food fraud” reports in 2003–2007, and 78 of them were on imported products, the single largest type (Kuiper and Kleter, 2009). For the vast majority of the times this represents no health risk to consumers, other than potentially inferior nutrition. The death of infants in China from infant formula that was basically lacking in nutritional content is an extreme example of this (Gossneret al., 2009). The criminal does not want to make anyone sick; they want to make a profit through repeat business.
The 2007 contamination of over 40 000 tons of sunflower oil sourced from the Ukraine with mineral oil is just one of the more recent and public oil adulteration events (Anon, 2008; Patton, 2008). The intentional misrepresentation of lower value oils as higher value oils occurs frequently enough that the International Olive Oil Council was established in Madrid under the auspices of the United Nations. Established in 1959, the Council’s main purpose is developing standards and supporting analytical testing to verify the type and origin of oils. The 2008 melamine contamination of dairy products, however, is an example of “conventional” economically motivated adulteration going terribly wrong. The perpetrators likely did not realize that melamine could cause illness in children. In response to the 2007 contamination of wheat gluten the US Food and Drug Administration (FDA), USDA and the World Health Organization (WHO) all asserted that melamine at the levels present in food and feed did not pose a human health risk. Those assessments were based on adults, but infants and small children are apparently susceptible to similar crystal formation and necrosis processes that occured in the pets. As a result of this lack of knowledge, and because of the delay in any public notification or regulatory action, over 280 000 children became ill in China. While the reasons for the delay in public notification and regulatory action are still a source of debate, this unfortunately illustrates the risks posed when a source country is motivated to do something that is not in the best interest of consumers in the United States (or even their own countries). That products with melamine contamination ended up in at least 47 countries (Lin, 2004) illustrates how economically motivated adulteration represents an imported food safety risk. A risk that is magnified if there is uncertainty in how vigilant the source country is in preventing or reporting intentional acts.
Other Emerging Intentional Threats
While protecting the food system against intentional contamination meant to cause harm has become a broad public concern only since the terrorist attacks of 9/11, the use of food to cause harm has a long history. The earliest well documented use of food as a military weapon is from 590 BC. In the war between Athens and Kirrha of the Amphictyonic League, the Athenian poisoning of stored water with the root of the plant helleborous enabled the Athenians to overrun the city when severe gastrointestinal illness rendered the city defenseless.
The Carthaginian general Maharbal successfully used wine contaminated with mandragora (mandrake) in his battle with tribesmen, as did Julius Caeser in 75 BC in Miletus, as he was able to slaughter his Cilician pirate captors by arranging for wine adulterated with mandragora to be delivered along with the ransom for his release (Dalziel, 2009).
Far more concerning examples of using food as a weapon occurred during World War II. The Japanese Army experimented with the use of various foods for the delivery of several pathogens, includingBacillus anthracis, Shigella spp,Vibrio cholerae, andYersinia pestis. The foods included candies that were dropped by planes over villages, as well as experiments with produce, meat, and fish (Harris, 1992; Moon, 1992). More recently, the most well-known, large-scale intentional contamination event in the United States was the 1987 contamination of salad bars withS. typhimurium by members of the Rajneeshee cult in Oregon. The attack, which resulted in 751 confirmed illnesses, was a test run by the cult as they were considering options to change the outcome of an upcoming election. Their plan was to see if they could depress voter turnout enough to enable their candidates to be elected to the county boards in order to allow expansion of their compound. The attack was only understood a year later when members of the cult revealed it during another investigation (Shears, 2010). While they are not all well publicized, there have actually been a fairly large number of intentional instances of food contamination in the past 50 years, as are summarized in reports by Mohtadi and Murshid (2006) and Dalziel (2009).
The prior examples of intentional contamination illustrate that there are cases when the consequences of such acts were considered to be, by the aggressor, acceptable. Emerging information indicates that the range of potential aggressors that would consider poisoning food may be increasing. Disgruntled employees, for example, have always been a concern and there are instances of employees dropping metal or glass into products during production or storage. These acts are intended to cause the company operational and economic harm, and have not, historically, been intent on causing public health harm. There is no fundamental reason, however, that harming others would not be an acceptable choice for some disgruntled employees. The potential for this becomes greater if the disgruntled employee is compromised or influenced by an individual or group that does want to cause significant public health harm. To that aggressor, the disgruntled employee may represent an attack route that reduces his own operational risk in carrying out the attack.
Criminals and criminal organizations represent another emerging risk. Lone actors, such as Shane Ward who left a bag with a claimed, contaminated baby food product in the Morrisons’ King’s Lynn branch in the United Kingdom, is one example of those who might leverage the food protection concerns to their benefit. While he was arrested, Morrissons still suffered the negative consequences of his hoax as the difficulty in proving the negative, that there was no contamination, forced the firm to remove the implicated products from the shelf in order to protect both consumers and their brand.
Extremist special interest groups have been an ongoing concern for food firms. While they have not conducted any food-system attack with significant public health implications, arson, vandalism, and animal release are already established strategies of groups like the Animal Liberation Front and the Earth Liberation Front. A wide range of other activist groups have specifically targeted production agriculture firms because of their activist view of the various firms’ impact on the environment, animal welfare, animal use in general, and other related concerns. If any extremist groups cross over the line to consider intentional contamination of food to be an acceptable means of achieving their aims, then public health risks increase significantly. From a United States import perspective, these risks are perhaps even more concerning as the ability to contaminate a food product may be significantly easier, or pose less operational risk, outside rather than inside the United States.
Post-9/11 state sponsored or condoned terrorist groups have been a focal point for a great deal of the homeland security related investments inprevention, response, and recovery to potential weapons of mass destruction (WMD) events. The 2010 Graham–Talent Commission WMD report card rated the country’s bioterrorism preparedness as F, or failing (Commission on the Prevention of Weapons of Mass Destruction Proliferation and Terrorism, 2010), hardly encouraging given the investments made. A comparatively small amount of that investment has been directed to food and agriculture systems, even though terrorist groups have demonstrated interest in food and agriculture. Such groups could effect potentially catastrophic consequences through the intentional contamination of food, either domestically or overseas for import into the United States. Documents recovered from Tarnak Farms in Afghanistan, an Al-Qaeda training facility, confirm that they had been evaluating food and agriculture system attacks as a means of delivering biological or chemical agents (Associated Press, 2006). While a localized event, the intentional contamination of food at an Australian run commissary for Iraqi police in 2006 resulted in at least 350 casualties (Associated Press, 2006), and also establishes food contamination as an acceptable weapon for some groups. It also confirms that there are individuals or groups who are looking at the food system as an attractive target, depending on their objective. When the potential of looking at food systems as the means of delivering an agent is integrated into understanding how globally integrated food systems function, then import vulnerability comes to the forefront.
The total economic value of food imports, ingredients included, is less than 20% of the total economic value of consumed foods. It is nearly impossible, however, for the vast majority of consumers to go through a normal day without eating something that has been imported. This could range from vitamins, spices, processed seafood, fruit, produce, and a wide range of other ingredients and foods. Every imported ingredient or product must be viewed with both a traditional food safety lens as well as the much more threat-based vantage point of potential intentional acts.
Potential Solutions
Just as is the case for food safety, there is no such thing as zero risk when it comes to food defense. There are, however, things that can be done now to reduce the risk, with new mitigation strategies under development. Since the private sector controls the food supply chain, mitigation strategies to minimize public health risk will often be private sector solutions, whether it is domestically sourced or imported food products that are being considered. The costs of any mitigation strategy are, as a result, very important. While in the end it is the consumer who bears the burden of any additional costs, incurring new costs could put a firm at a competitive disadvantage if others do not incur the same costs. Firms can be incentivized to implement mitigation strategies above those that their own risk management program justifies if the demonstrated reduction in their overall supply chain risk is either attractive to firms downstream from them in the supply chain, or if it reduces their insurance costs. No firm wants to be the source of a foodborne illness outbreak or wants to be the victim of an attack that results in catastrophic public health harm, but not every risk can be mitigated. In cases where there would be competitive disadvantages for leading firms to incur the cost of a mitigation strategy, then regulations or enforced private sector standards are a means of ensuring that all firms bear the financial burden. When this is done well, such as in Hazard Analysis and Critical Control Points (HACCP) requirements, it protects the public without large and unnecessary costs and complexity for food system firms.
Supply chain verification and ingredient certification are areas where either regulations or industry standards could be effective. Verifying the supply chain and all ingredients from consumer back to the point of primary agricultural production are fairly straightforward concepts, but translating them to either private sector equivalents of the Universal Laboratories seal of approval or regulatory agency validation is a much more difficult task. As illustrated by the PCA recall, food supply chains can be very complicated and usually no one firm in the chain has full knowledge of the chain. Some firms are already working toward total supply chain situational awareness, but doing that across all firms and supply chains is a daunting and expensive task. Data management challenges, ranging from data structure to private sector data protection, interoperability of data systems and cost of implementation are all significant challenges in need of additional focus. Attempts to deal with portions of these challenges are being advanced by iCix (http://www.icix.com/) and GFSI (http://www.mygfsi.com/), but these are not complete solutions, especially when imported foods are included.
The significant opportunity to use market mechanisms such as insurance to both reduce public health risks and incentivize private sector investment in food system risk reduction strategies faces an ongoing challenge in ensuring that regulatory and nonregulatory mechanisms are positively reinforcing. There are examples of regulatory mechanisms such as “zero tolerance” for the presence of a microbial contaminant in a food system that result in a reduction of surveillance for the specific organism of concern due to the economic consequences of a positive result. Given the limited amount of investment that will be available for reducing import system risks and food defense risks, negatively reinforcing regulatory interventions, like zero tolerance, must be avoided. This is why any step forward with regulations should significantly engage the private sector to avoid potential unanticipated negative outcomes.
Food system surveillance, by both the public and private sector, provides significant opportunities to reduce import risks. In the case of the 2007 melamine contamination of wheat gluten, better public and private surveillance efforts might have avoided the event. If stakeholders had been tracking regulatory changes made by the European Union in 2006 because of issues relating to melamine in imported products, they could have increased their inspection and import surveillance of protein-based products. There may also have been commodity-based indicators that could have alerted stakeholders to increase surveillance. At the time of the contamination, wheat gluten was in short supply and the implicated lot was purchased on the spot market. Also, in the two years leading up to the event, imports of wheat gluten from China had risen sharply without a similar increase in Chinese wheat production. These supply chain indicators could have alerted both the private and public sector to look more closely at protein imports in general and wheat gluten in particular. Under the auspices of the Food Safety Work Group established by US President Obama, a subworking group was launched in January 2010 to look at ways of better identifying potential economically motivated adulteration, with the goal of proactively intervening to mitigate public health risks. The Grocery Manufacturers of America (GMA) initiated efforts in 2009 to help firms develop capabilities to avoid economically motivated adulteration. These efforts are taking a particularly close look at risks of imported products for economically motivated adulteration.
Detection strategies, one of the bedrocks of validating food safety systems, also have a potential role in both bolstering food defense and identifying import risks and economically motivated adulteration risks. Effectively utilizing detection systems for these risks requires different strategies than for conventional microbial or pesticide contaminant detection. While the range of potential agents for intentional contamination to cause public health harm is very large, there are some differences relative to food safety that may enable successful deployment. Unlike the need to find one organism in a milliliter or in 625 grams, intentional contamination will most likely involve much higher concentrations of the agent, as the aggressor either wants to ensure the success of the contamination or wants to maximize profits. At a higher limit of detection, existing, or new, technologies may be effective mitigation strategies.
For both intentional contamination and economically motivated adulteration, nonspecific detection approaches also may be useful. Knowing that something is “wrong” with the product but not knowing what could be very useful. Research by the FDA demonstrated that adding strychnine to certain juice products turned them purple (USFood and Drug Administration’s Food Defense Programs, 2005), a fairly obvious indicator that something is “wrong.” The common practice of checking the conductivity of sugar as a final quality assurance step would also identify a broad range of potential intentional contaminants. Similar research needs to be done across a broader range of threat agents and foods to determine which combinations can be easily picked up by either existing, or slightly modified, quality assurance tests. For example, conductivity tests could also be used to determine if something had been added to bottled water, or if the salt for a salted snack had been diluted. There is significant opportunity to develop new detection strategies to identify that something is “wrong” or to “fingerprint” the product.
Going from nonspecific detection methods, there is also a future role for highly specific new detection systems. If there are some agents or agent–food combinations that represent a significant concern, then the specificity may represent an opportunity for tailoring a technology solution. As one example, research on microfluidic devices or reactive filmsthat are specific to the active sites on botulinum neurotoxin show promiseas a strategy for detecting toxins via an in-process, real-time system.
Conclusions
Improving imported food safety and effectively managing emerging risks in the globally integrated food system are both critically important. The current, and as of yet unidentified, emerging risks present new and evolving challenges to food system protection that must be managed effectively to protect public health. Regulations will be an important tool in improving import safety and managing emerging risks, but the solutions are still primarily the responsibility of the private sector. The private sector owns the food system and relies on a sound regulatory framework as the base for protecting their supply chains and their consumers. Both public and private food system stakeholders have to be diligent in protecting the ultimate stakeholders – consumers. Industry and government may bear the direct costs of the implementation of any mitigation strategies, and they also manage the consequences of any food system protection failure. In the end, however, it is the consumer that really pays the price of either successful mitigation strategies or food system protection failures, whether imported or domestically sourced.
References
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Chapter 2
A Cooperative Federal–State Approach for Monitoring Imported Foods: Reviewing the New York State Model
Joe Corby
Introduction
There is a general misunderstanding that the US Federal Government alone handles all matters associated with the safety of imported foods. On the contrary, when imported foods pass through the scrutiny of our federal agencies at border points to be distributed domestically, they become the primary responsibility of state and local food safety agencies. Over 90% of all domestic food safety work performed in this country is performed by state and local food safety agencies (AFDO, 2009). More than half the inspections reported annually by the US Food and Drug Administration (FDA) at food manufacturing plants are actually performed under contract for FDA by state food safety agencies (AFDO, 2009). In addition, consumer complaints, including illness investigations that are associated with imported foods are usually first investigated by state or local officials. Finally, most of the food samples collected and analyzed in this country are done so by state and local officials. Consequently there is an enormous amount of information concerning imported foods available from state and local agencies, which could be shared with federal agencies. Clearly state and local agency cooperation plays a significant role in safeguarding public health from hazards in imported food.
According to a “2008 State Food Safety Resource Survey” (AFDO, 2009) more than 400 000 food products are collected and analyzed annually by state and local agencies. Yet most of this surveillance information remains within the state or local government where decisions are made and enforcement occurs. Such information is seldom utilized by federal agencies. The same is true for data involving inspections, recalls, and consumer complaints conducted at the state and local level. Fortunately, efforts are underway to change this situation as the nation considers moving closer to an integrated food safety system where all levels of government share important information relating to food safety.
There are a number of federal agencies that American citizens rely on to assure that imported foods are safe, and these include US Customs and Border Protection (CBP), the US Department of Agriculture (USDA) Food Safety and Inspection Services (FSIS), and the FDA. These agencies play the primary and pivotal roles in the imported food safety monitoring system. The major responsibilities of these agencies concerning imported foods are detailed below, but for more information on this subject, see Fortin (Chapter 5, this volume).
The CBP Agency is a part of the Department of Homeland Security (DHS) and is responsible for classifying and appraising a portion of the commercially imported merchandise that enters the United States every year (CBP, 2009). This agency also determines which products may legally enter the country by enforcing laws that protect public health and safety, intellectual property rights, and fair trade practices. Investigations of smuggling, commercial fraud, and counterfeiting are also performed.
The USDA FSIS is responsible for ensuring that imported meat, poultry, and egg products are safe, wholesome, and accurately labeled (USDA, 2009). Foreign countries that export meat, poultry, and egg products tothe United States are required to establish and maintain inspection systems that are equivalent to those of the United States. In addition to auditing foreign inspection systems, FSIS evaluates meat and poultry at the port-of-entry to ensure that foreign countries have maintained equivalent inspection systems resulting in acceptable imported product.
The FDA (as part of the US Department of Health and Human Services) ensures that products imported into the United States and regulated by the agency meet the same safety, efficacy and quality standards as those products manufactured domestically (FDA, 2009). The agency is currently increasing its presence in foreign countries and recently opened offices in China, India, and Central America.
Other federal agencies with imported food responsibility exist within the federal Departments of Health and Human Services, Agriculture, Commerce, Homeland Security, and Transportation. The US Consumer Product Safety Commission (CPSC), the US Environmental Protection Agency (EPA), and the Office of the US Trade Representative. These agencies also play important roles and further background information in this area may be found in Fortin (Chapter 5, this volume).
State and Local Government Strengths
The FDA and the states have a tradition of working together in a number of domestic areas but have only recently begun to partner on imported food matters. A number of strengths exist specifically at state and local government levels that, if utilized by federal agencies, will strengthen the US Government’s ability to monitor imported foods and protect public health.
