Bond, James Bond, and Food Defense

November 24, 2017

Most people would agree that British author Ian Fleming was a great writer, but few would probably expect his work to touch on protecting the food supply.

In the tenth book of his James Bond series, “On Her Majesty’s Secret Service,” Fleming has secret agent James Bond addressing Food Defense — one of three “Food”-based terms relating to the safety and security of food products.

Another of these terms, Food Safety, describes keeping food safe from chemical, microbiological, or physical contamination. Food Security, another term, describes ensuring a secure supply of food — adequate to supply a population. Food Defense is perhaps the least-known term. It refers to the protection of food from fraud or deliberate adulteration intended to cause harm or economic disruption.

In “On Her Majesty’s Secret Service,” the villain, Ernst Stavro Blofeld (a great name for a villain), is preparing to bring Great Britain to its economic knees by contaminating its food supply. Bond (a great name for a spy — nothing is stronger than a bond), uncovers the plot, which involves bringing farm girls with food allergies to a clinic in the Swiss Alps and using hypnosis to cure their allergies. Along with the cure, the girls are brainwashed to “improve” their flocks, herds and crops by spraying them with microbial contaminants. All in all, a good plot for a spy thriller — and remember this was published in 1963, when Food Defense risks were not nearly as talked about as they are today!

FSMA, Food Safety Modernization Act, and Food Defense

Fast forward to 2011, and Food Defense is a significant component of the Food Safety Modernization Act, especially under the section “Mitigation Strategies to Protect Food Against Intentional Adulteration, (21 CFR Parts 11 and 121).” The regulation’s Final Rule became effective on July 26, 2016 with compliance dates for most facilities of July 26, 2017. (Small businesses were given one year to comply, and very small business were given two years.)

This regulation requires both foreign and domestic food production facilities to conduct vulnerability assessments and implement a written food defense plan — something that probably would have helped producers using ingredients from the vulnerable-to-the-sinister-microbial-spray-plot farms in the novel. (This includes facilities registered with the Food and Drug Administration under section 415 of the Food, Drug & Cosmetic Act.) Farms (and very small businesses) are exempt from the regulation.

A food defense plan must contain two key components: a vulnerability assessment and mitigation strategy. The vulnerability assessment identifies vulnerabilities associated with types of food manufactured, processed, packed, or held at the facility. Each step of the operation must be evaluated for vulnerability by considering accessibility, product volume, agents of concern and estimates of human impact if contamination occurs, including how fast the food moves through the distribution chain.

The goal of the mitigation strategy — which must be implemented at each process step in the assessment — is to minimize the risk of intentional adulteration. The mitigation strategy has three main components: monitoring, corrective actions, and verification.

Monitoring the mitigation procedures includes documenting the frequency at which they should be monitored. Corrective action steps address what happens if the mitigation strategies aren’t properly implemented. The verification steps ensure that monitoring is being performed. Facilities are also required to ensure that personnel in vulnerable areas are appropriately trained and that proper records are kept.

To learn more about the Food Defense Rule, click here.
To learn more about how much times have changed since a paperback cost 50 cents and adulteration was fiction, read “On Her Majesty’s Secret Service,” by Ian Fleming.

Category: Food Safety