食品供應鏈中惡意汙染行為之防治：以美國、歐盟與國際組織的實踐為例

Preventing and Governing Deliberate Contamination in the Food Supply Chain -Case Studies of Practices in the US, the EU and International Organizations

本文對「食品供應鏈」進行研究與分析，說明何以在供應鏈後端的惡意汙染行為較難預防，卻受害者範圍較小。反之，在供應鏈前端的汙染行為並不容易得逞，惟一旦成功則往往造成較為嚴重之損害後果。研究結果顯示，預防食品受到惡意汙染行為的治理重點應聚焦在對「威脅」的控管；操作上，威脅評估與關鍵管制點是值得考慮之治理途徑。鑑於現行全球食品貿易自由化的趨勢與結構不可逆，食安風險必然不會消失，在容許風險的概念下，建立預防威脅擴大和限縮損害結果的治理機制，將是防治惡意汙染食品行為較為務實之辦法。

This paper discusses current issues in the global food supply chain (FSC). More specifically, it focuses on why it is difficult to prevent deliberate, criminal contamination in downstream sections of the FSC, yet only limited harm is done to consumers. The paper also investigates why it is more feasible to hamper the food contamination in the upstream of FSC while the adverse effect could be serious given the effective criminal behavior. Observing the practices of food safety governance in the US, the EU and international organizations (the WHO in particular), the key point in preventing deliberate contamination should be the management of 'threats.' It is worth noting that threat assessment and critical control points (TACCP), as an approach to governing food safety, is certainly a considerable alternative. Thanks to the irreversible structures and trends associated with global food trade liberalization, current risks of food contamination from various sources will by no means fade away. Given this, efforts to establish an institution based on the concept of acceptable risk for preventing threats while managing the spillover effects of damages are a pragmatic means of defending against deliberate food-contamination.