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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Biosecurity - a global concern

Basic animal proteins have become a global health concern. Aside from the ever-present problems of listeria, salmonella, and E. coli contamination, puzzling and insidious animal diseases such as bovine spongiform encephalopathy (mad cow disease) and the new and highly pathogenic avian influenza H5N1 have added abundantly to the food processor's burden of food safety responsibility. And as the food marketplace becomes increasingly global, the challenges to processors worldwide grow.

"As an industry, we have to prepare ourselves. We will need to know what percent of our raw product will come from outside American borders and [build] our [safety] strategies accordingly," says Richard Bond, Tyson Foods president and chief operating officer.

Bond acknowledges an increase in U.S. biosecurity efforts since the 9/11 attacks. But, as the avian influenza challenge illustrates, biological villains are among the hardest to identify and control.

Low-pathogenic avian influenza has been common in America for at least six decades, cropping up in bird populations each spring with minimal impact on birds or humans. Avian influenza H5N1, a disease currently affecting Asian bird populations, presents a far more serious health threat. At this writing, the Chinese government has announced its intention to inoculate the 14 billion birds in its poultry stock - an almost impossible task.

Global health authorities see an outbreak of this deadly influenza in North America as highly possible, if not inevitable. How great is this threat to America's biosecurity? No one can say for sure, but at least some measures to deal with it are already in place.

Tyson raises chickens for its North American operations in enclosed facilities, all but eliminating contact with wild birds and other potential carriers of many diseases. Workers don protective clothing at poultry facilities to keep from spreading the disease.

The practice of "all-in, all-out" farming - moving birds of the same age in and out of production houses at the same time – is also deemed an important safety practice.


Terrorists aren't the only threats to a food processing plant's safety and security. Aggressors come in a variety of shapes, sizes and profiles. Here, however, is a list of the high-percentage suspects from the FSIS Office of Food Defense and Emergency Response (OFDER):
  • Disgruntled insiders -
  • Criminals -
  • Protesters -
  • Subversives -
  • Terrorists -
      Unhappy workers, malcontents with a bone to pick with the company or industry.

      Careers "outside the law" often come with practiced and refined skill sets and tools.

      Keep an eye on those with a highly charged personal, political or philosophical objection to the company or industry or its customer reach.

      Set on undermining the industry or an entity it represents, subversives may be highly skilled and capable of detailed, even elaborate, plans.

    Driven by political or ideological beliefs, they are motivated to create destruction, fear, mayhem, disruption of the daily lives of the population served by the industry and loss of confidence in systems and institutions.
Most dangerous of all can be the individual and collective apathy of workers. Failure to take an interest in or to take seriously threats or the possibility of aggression is an invitation to disaster. Employees need the knowledge, resources, awareness and motivation to commit to a food defense effort.

Time for an irradiation comeback?

In 1993, five children died and hundreds more became severely ill due after eating undercooked hamburgers contaminated with E. coli.

"The product [ground meat] came out of a plant with several barriers in place to prevent [microbial] contamination," notes Richard Hunter, CEO and president of Food Technology Service Inc., Mulberry, Fla. "Those barriers failed. That's why processors must put up multiple barriers."

Had the hamburgers been cooked thoroughly, the outbreak would not have occurred either, Hunter notes, marking another breakdown in the system. But one measure not then implemented would also have done the job.

"Irradiation could have prevented five kids from dying and another 500 from getting sick," says Hunter. "We see irradiation as part of a multiple barrier approach. The good thing is that irradiation is an excellent barrier."

Food Technology Service provides contract irradiation service to food processors. Irradiation received its first clearance from the FDA for use on spices in the 1980s and has been approved since for poultry, ground red meat, oysters and pork, with shellfish and other approvals on the horizon.

To date, consumers have remained wary of the process (actually regarded as an "ingredient" under current food law). Wrongly, they associate it with radioactivity. Time and a small but safe history have eroded some resistance. With the potential of deliberate contamination by a food terrorist adding to the prospects of microbiological contamination in foods, processors - and maybe even the public - may be looking at the radura (at right, symbol of an irradiated product) in a whole new light.

Colorado Boxed Beef of Auburndale, Fla., offers irradiated poultry and ground beef to its restaurant and institutional customers. Equally significant, it regards the radura as a marketing plus.

"This (radura) symbol offers you an important new choice of premium quality product," the company reports to customers and prospective buyers of its New Generation ground beef. "The symbol is your assurance that this food product has been treated to reduce the possibility of bacterial contamination. While America has one of the safest food supplies in the world, millions still become ill each year because of harmful microorganisms in the food we eat."

Omaha Steaks, based in Omaha, Neb., markets irradiated vacuum-packed and frozen beef, poultry, pork and other products to its retail, mail order and foodservice customers. Irradiation provides exceptional protection for product that may undergo unintended freeze-thaw cycles before the product is finally consumed.

Three methods of irradiation - gamma-ray, electron beam and X-ray - may be used. Each involves sending a pulse of energy through the product and package. Product treated by Food Technology Service undergoes a single gamma-ray treatment after the product has been packaged. The energy hitting a pathogen or spoilage organism breaks the DNA in the organism and kills it.

The company has taken a conservative marketing approach, offering irradiation as but one barrier in a multiple barrier approach to food safety and security. "One advantage is that you can treat the product in the final package," notes Hunter, identifying the effectiveness of the technology against salmonella, listeria, E. coli, and other dangerous pathogens. "No other technologies really compete with it. Irradiation has no real equals."

Even opponents of the technology admit that it does not leave the product radioactive. Their opposition continues to focus on "unique radiolytic products," that is by-products of the treatment that may produce deleterious effects on consumers. Several years ago, such a by-product - known as 2-ACB - was discovered. According to Hunter, researchers at USDA and other institutions do not regard the by-product as a human health hazard.

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