Food Safety Plan Needs to Extend Beyond HACCP

Jan. 5, 2006
Food plants are fertile ground for product contamination from tiny microbes to terrorists. You need a plan that extends beyond HACCP.
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 planFailing 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.Preventive measures should be outlined to reduce risk. Test the plan's effectiveness in mock trials and brainstorming exercises.Plans should focus on critical and vulnerable areas of the plant."Apply the highest security to the most critical components of your food operation," advises Vitiello, who also suggests a "layered" approach consisting of physical, personnel and operational security measures.
Yud-Ren Chen, an agricultural engineer with USDA's Agricultural Research Service, is developing a computer-directed scanning system that may speed inspection of the nearly 8 billion chickens processed annually through federally inspected U.S. plants.
Tyson Foods, which is now North America's largest food company, according to Food Processing's 2005 Top 100© report, has ratcheted plant security up several notches to protect product, customers and plant personnel. "Our biggest concern is food safety," says John Tyson, chairman and CEO. "It impacts the consumer. It impacts consumer confidence. It impacts the strength of the brand.""We have added entry security measures, issuing badges and seeing that only specific people are admitted into certain places," notes complex manager Irvin. "We have added guards, as well. And we continue to upgrade our security measures all the time."External security measures came in several phases at Tyson. They included the addition of fences, cameras, motion detection devices and guarded doors.FSIS encourages plants to post "no trespassing" signs, to monitor the plant perimeter for suspicious activity and unauthorized entry and to introduce guards, alarms, cameras and other appropriate security hardware at all access points. Emergency exits should have alarms and self-locking doors that can be opened only from the inside. Carefully monitor and document personnel entering and leaving the plant. (See FSIS Security Guidelines for Food Processors for an extensive list of outside security measures.)Inside security measures include marking and securing restricted areas, limiting access to labs and restricting access to central airflow, water, electricity and gas controls. Emergency alert systems should be operational at all times and all employees instructed in their use. Computer systems must have effective password, virus and firewall protection. (See FSIS Security Guidelines for Food Processors for an extensive list of inside security measures.)Airflow systems should be designed so that contaminated rooms or areas can be isolated easily.Process security and sanitationAt the core of every food security defense system should be a sound food safety program. HACCP programs provides a strong framework, helping to identify high-risk zones that merit extra watch and protective measures. But equally important, HACCP calls for practices that may help detect or prevent contamination and documentation that will help trace times and sources of product contamination and track down tainted product.Processors of animal protein face multiple levels of safety concerns. Tyson, as the nation's largest protein processor, employs more HACCP-trained individuals than any company in the world. It has added a state-of-the-art quality assurance lab.To provide an overlapping layer to its safety program, however, Tyson initiated the Sentinel Site Program, an environmental monitoring and product testing program that provides early warning alerts and allows plant personnel to prevent and eliminate listeria monocytogenes in Tyson facilities that produce ready-to-eat products. In effect, it monitors and validates the company's HACCP system with overlapping checking measures."It's a program of random site monitoring and contact and non-contact sampling, a scientifically valid method of testing," says Irvin. Some have credited it with elevating industry standards for testing for bacterial pathogens in ready-to-eat meats.In addition to food contact surfaces on processing lines, coolers and freezers, non-contact surfaces - walls, floors and ceilings - also are tested weekly. The Sentinel Site Program calls for intensified monitoring at sites where a positive trace of the microorganism is detected and the holding of product in the event of a positive listeria reading at an RTE food contact surface critical control point.The program has reduced the occurrence of listeria in process areas and risk of RTE product contamination. Tyson enters all Sentinel Site data into a common database to help assess equipment and plants. The data has helped to compare equipment and evaluate processes and procedures at different processing facilities to determine best practices.FSIS offers these tips for securing slaughter and processing areas:
  • Establish procedures to monitor the operation of pieces of equipment (blenders, choppers, poultry chill tanks, etc.) to prevent product tampering.
  • Implement a program "to ensure the timely identification, segregation and security of all products involved" if a product is deliberately contaminated.
  • Have a validated procedure for trace-back of ingredients and raw materials and for trace-forward for finished products.
  • Material involved in rework should be examined for evidence of tampering before it is re-introduced to the processing area.
  • Verify the integrity of packaging for spices, restricted ingredients and pre-mixes.
  • Maintain accurate finished product inventory; account for all additions or withdrawals from stock.
  • Restrict access to the processing area to plant and FSIS personnel only.
  • Use a clear and apparent system of personnel identification, such as uniform color, to distinguish valid entry and presence in the processing area.
Don't let the remarkable record of safety in America's food supply or your own plant allow you to lower your guard. Attacks, whether planned or accidental, are most likely to occur when complacency has set in or an extremely high level of activity has caused plant personnel to cut corners. Defense at your plant helps to maintain confidence in America's entire food distribution system.

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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