Food Safety Plan Needs to Extend Beyond HACCP

Food plants are fertile ground for product contamination from tiny microbes to terrorists. You need a plan that extends beyond HACCP.

By Mike Pehanich, Plant Operations Editor

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Whether initiated by tampering cranks or terrorists, attacks on the food, water or drug supplies are among the most frightening incidents imaginable to Americans. Chilling as these headline incidents have been, they pale next to the threat of an organized terrorist attack on one or more components of our food network.

Since the 9/11 attack, the Dept. of Homeland Security has identified the food industry as a major potential terrorist target. Processors, associations, government agencies and others have teamed to develop guidelines and plans to cope with an attack on our food distribution system and any part of its infrastructure. But even before Sept. 11, 2001, less organized and more vaguely motivated threats - the Tylenol tampering incident may be the most memorable - had given us a hint of the kind of mayhem that enemies might wreak on an unsuspecting public.

Mix in the accidental microbial attacks that have plagued the industry over the past two decades, and the importance of preparation for attack by all kinds of "invisible" enemies becomes apparent.

Concern today for the security and safety of the food supply pervades the entire food distribution system, thanks to widespread government and industry communications. The Food and Drug Administration and Dept. of Agriculture (USDA) offices and web sites offer guidelines and assistance with education and training. The Food Products Assn. and other industry associations provide valuable assistance as well.

Four factors consistently associated with foods - large batches, uniform mixing, short shelf life and ease of access - are at a higher risk of terrorism, according to FSIS' Don Vitiello.
University programs have added biosecurity training to their course offerings. "We do biosecurity training today as a result of the Bioterrorism Act of 2002," says Renee Goodrich, University of Florida food science and extension specialist for citrus processing. The university's Institute of Food and Agricultural Sciences (IFAS), which also offers extensive hazards analysis and critical control points (HACCP) training, finds many processors of citrus and other agricultural products need assistance in meeting new record-keeping and registration requirements and to monitor imports and exports.

The largest food companies have the longest consumer reach. Most understand they may be prime terrorist targets.

"After 9/11, we took a harder look at the security of our facilities," says Richard Irvin, facility complex manager in Fayetteville, Ark., for Tyson Foods Inc. "Tyson has a global security department today. And that has been a big help."

An easy target?

Keeping a food plant safe and secure in the 21st century requires planning, execution and relentless vigilance. The infrequency of incidents coupled with the absence of a clearly defined aggressor makes the challenge all the more difficult. Terrorist attack, tampering madness or a simple microbial mishap are most likely to occur when a plant has slipped into a false sense of inviolability.

Food processors have many of the attributes of a prime terrorist target, according to Dan Vitiello. As director of the USDA's Food Safety Inspection Service (FSIS) scientific and technical support staff, office of food defense and emergency response, he manages homeland security activities within FSIS. His office is charged with prevention and response to food security threats.

"Vulnerability assessments demonstrate four factors consistently associated with foods are at a higher risk of terrorism," he told attendees at Worldwide Food Expo in October. "Large batches, uniform mixing, short shelf life and ease of access."

The logic is simple. Large batches have the potential to reach large numbers of consumers. Uniform mixing enables a toxin to contaminate all servings from a given batch. Short shelf-life products are likely to be consumed shortly after purchase, diminishing the likelihood of a successful recall before damage from the tainted product might be realized. Finally, products and processes that are easily accessed increase the odds of a tamperer/terrorist realizing a deadly mission.

Similar logic makes products offered in large serving sizes attractive targets. Other attributes of prime process/product targets are strong flavors or odors, certain textures and intense colors -- in other words, any trait that may provide a sensory veil to the contaminant.

Of course, products without tamper-evident packaging are clearly vulnerable. So are ready-to-eat foods, because foods with preparation steps offer opportunities to detect, dilute, wash out, destroy or otherwise minimize the impact of the contaminant.

Sounds like a plan

Failing to plan is planning to fail in the event of an attack on the processing plant or product. A plan should begin with a food defense assessment, which will focus upon areas of concern in the plant and possible holes in the safety or security net. The plan also provides critical documentation for justifying capital or workforce expenditures and the establishment of new organizational divisions or structures. It also may provide guidelines and background for newly introduced operational measures.

Most importantly, the plan will provide the basis for emergency response preparedness.

Plan elements should include inside security, storage security, outside security, security at shipping and receiving points and security at critical operations areas, including processing, slaughter and all inspection areas. Clear outlines of contacts and recall procedures are critical.

Few plans will succeed without strong visible and vocal support from management.
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