Food Defense Center Comments on FDA’s Proposed Rule To Protect Food Against Intentional Adulteration

The National Center for Food Protection and Defense submitted comments to the FDA regarding its Proposed Rule for protecting food from intentional adulteration.

Online PR News – 25-June-2014 – St. Paul, MN – The National Center for Food Protection and Defense (NCFPD), a U.S. Department of Homeland Security (DHS) Center of Excellence, recommends several changes to the rule proposed by the Food and Drug Administration (FDA) that carries out the Food Safety Modernization Act’s requirements to protect the public from intentional adulteration of food. These requirements stem from concerns that terrorists might attack the public by intentionally adulterating food. This is the first time such a rule has been proposed to address this threat to our food.

“NCFPD commends FDA’s effort to directly address, for the first time, protection of our food supply through specific food defense efforts,” says NCFPD Director, Dr. Amy Kircher. “We have provided comments in the spirit of support to FDA in crafting a Rule that will best protect public health.”

In its recommendations, NCFPD advocates a strategy of identifying and strengthening the weakest links in a food product’s entire supply chain. “The path our food takes from farm to our plate is enormously complex, and each product or ingredient has its own unique vulnerabilities to attack. For this reason, we recommend a supply chain focus for food defense to ensure we close gaps wherever they may be, such as during transport of food products,” says Kircher. “Using a supply chain approach allows companies to cost effectively target their food defense efforts.”

In addition, NCFPD strongly recommends the Rule address food fraud, referred to in the Rule as “economically motivated adulteration” (EMA). It is a known risk to the food supply, such as when dairy processers in China tried to conceal the watering down of milk by adding the chemical compound melamine to it. This adulteration killed several children in China and sickened thousands. The Center further recommends the Rule require efforts to prevent intentional adulteration by disgruntled employees, another well-documented risk it now exempts. “Each of these motivations, regardless of intent, takes advantage of a vulnerable point in our food supply and can cause catastrophic health effects,” says Kircher.

NCFPD’s full comments to FDA regarding the Proposed Rule are available at:

The FDA released the proposed rule on Tuesday, December 24, 2013 and will be closing the comment period on June 30, 2014. All submitted comments will be available at

The National Center for Food Protection and Defense (NCFPD) is multidisciplinary and action-oriented research center and consortium of academic, industry, and government partners that address the vulnerability of the food system to intentional and catastrophic contamination. The Center’s research and educational programs are aimed at reducing the potential for adulteration at any point along the food supply chain and mitigating potentially catastrophic public health and economic effects of such attacks.


If you would like more information or to schedule an interview with Dr. Amy Kircher, NCFPD Director, please contact Kendra McCormack at or 612-626-6406.