REGULATORY AND SUPPLY CHAIN CONTROL CHALLENGES AND GLOBALIZATION
Our food supply is becoming increasingly globalized. Imports of food and agricultural commodities in many developed countries are rising. The US Food and Drug Administration (FDA) reported increases of 10% per year in shipments of FDA-regulated foods between 2002 and 2009 (United States Food and Drug Administration, 2011). The percentage of volume of US food consumption attributed to imports rose from 11% in 1989 to almost 17% in 2009 (http://www.ers.usda.gov/topics/international-markets-trade/us-agricultural- trade/import-share-of-consumption.aspx). A 2010 FDA report projected that future growth in imports of regulated products would exceed growth of domestic products. The European Union (EU) is the top agricultural importer, by value (European Commission, 2013). Total agricultural imports into the EU increased an estimated 24% between 2000 and 2008 (von Witzke and Noleppa, 2010). Globalization of the food supply facilitates market growth and consolidation, gives populations in many countries a year-round supply of food products that cannot be grown domestically, and can help drive down production costs. It can also result in long, interconnected, multinode and complex supply chains, which can be challenging to oversee and regulate.
The United States has less direct regulatory oversight for imported food products than those that are domestically produced. Foreign facility inspections are more expensive than domestic inspections, and the FDA performs inspections of foreign food facilities at a far lower rate than domestic facilities (United States Food and Drug Administration, 2011). Globalization of the food supply has dramatically increased the distances that food products and ingredients travel, as well as the number of intermediate parties between primary production and the ultimate consumer (“farm to fork”). In 2005, a large recall was initiated in the United Kingdom as a result of contamination of chili powder with the industrial dye Sudan 1 (http://www.theguardian. com/society/2005/feb/23/food.foodanddrink1). The chili powder supply chain involved transactions among at least six different companies in India and the United Kingdom over a time period of more than two years (http://www.telegraph.co.uk/news/uknews/1484427/Tracking-down-the-rogue- powder.html). The chili powder was subsequently used in the production of Worcestershire sauce, which was then sold as an ingredient to at least 60 manufacturers and suppliers and incorporated into more than 600 finished food products. Fig. 1.1 shows a visual representation of the complexity and breadth of the reported supply chain for the recalled chili powder. In this example, various factors contributed to the loss of oversight of the supply chain and hindered trace-back and trace-forward investigations. These factors included the number of intermediate parties, the lack of transparency throughout the supply chain, the physical nature of the product (it was sold
FIGURE 1.1 Visual representation of the reported supply chain for recalled chili powder. Data sources: Food Standards Agency of the U.K. National Archives and The Guardian.
in powdered form), and the amount of time that elapsed between production and ultimate retail sale. The recall of more than 600 finished food products cost the United Kingdom an estimated ?100 million. In a separate example, the tragic 2008 incident of melamine contamination of dairy supplies in China, the resulting illnesses in hundreds of thousands of infants were confined to China. However, public health, laboratory, regulatory, and other government resources throughout the world were needed to respond to the incident, conduct product testing and recalls, and determine the risk of human exposure to melamine (http://www.ncbi.nlm.nih.gov/pmc/articles/ PMC2799451/). Ultimately, food product recalls occurred in at least 47 countries.
Arguably, the increasingly complex nature of supply chains for food products increases the risk of contamination, both unintentional and intentional. It also increases the burden of ensuring authenticity along the supply chain. Routine laboratory testing of ingredients for quality assurance can be costly, and it is impractical to test food ingredients for a wide range of adulterants during each transaction along the supply chain. Therefore, one of the risks that increase when supply chain oversight and visibility are reduced is economically motivated adulteration or food fraud (Everstine et al., 2013). In a 2010 report, the FDA cited EMA as “perhaps the most serious challenge on the horizon” for the foods, drugs, and medical devices that the agency regulates (United States Food and Drug Administration, 2011). The 2013 horse meat adulteration incident in Europe prompted a UK review of the systems that assure food integrity and outlined a number of recommendations to improve the deterrence, detection, and prevention of food fraud and food crime (HM Government, 2014). As noted in the report, “much less attention has been focused on food authenticity, food fraud and food crime” than on food safety, and there is a need to “protect consumers and honest businesses through an effective regulatory framework.”