You could say everything old is new again when it comes to the U.S. Food and Drug Administration (FDA) and food security. In 2003, the FDA issued a set of five food and cosmetic security preventive measures guidance documents designed to help participants in virtually all sections of the food chain minimize the risk of malicious, criminal, or terrorist actions involving products under their control. Their target audience: operators of food and cosmetic establishments, along with businesses that produce, process, store, repack, relabel, distribute, sell, or transport food, food ingredients, and cosmetics.
Five years ago is not ancient history, but the FDA has already revamped these 2003 documents. In December 2007, as part of its comprehensive Food Protection Plan, the FDA released some revitalized self-assessment tools designed to help industry minimize the risk of intentional contamination of food and cosmetics.
“There are no changes in the actual content from the 2003 documents,” says Edmundo Garcia, an FDA policy analyst. Garcia serves on the FDA’s food defense oversight team, which completed the recent project as a function of the Office of Food Defense, Communication, and Emergency Response within the Center for Food Safety and Applied Nutrition (CFSAN).
Using feedback from industry and other government agencies, the FDA repackaged the information found in the original guidance documents and created a corresponding Food Defense Self Assessment Tool (FDSAT) for each one.
“Courtesy of an added checklist format, the revised guides are much more user friendly than the original guidance documents,” Garcia says. “By using these tools, industry members can get a quick and detailed assessment of the measures they currently have in place against intentional contamination of their products. With this information, it should be quite easy for them to see where meaningful improvements to their current practices can be made.” The tools are divided into five sections: management, human element-staff, human element-public, facility, and operations.
Retail Food Security
The original 20-page document, specifically designed for the retail grocery and food service segments, is the “Retail Food Stores and Food Service Establishments: Food Security Preventive Measures Guidance.” The updated version can be found at www.cfsan.fda.gov/~dms/secgui18.html.
Because using the revised guidance documents is voluntary, there’s no way to know how many retail food stores and food service entities are downloading and using them, Garcia notes. “We hope industry will take advantage of the new tools and find them useful,” he says. “If stores and food service operators don’t already have security measures in place, the FDSAT will help them develop a baseline that will give them a better sense of what they can and should be doing to secure their enterprises from criminal and terrorist threats.”
To be successful, implementing enhanced preventive measures requires the commitment of management and staff. “Accordingly, FDA recommends that both management and staff participate in the development and review of such measures,” Garcia says.
The guidance documents revised in 2007 are a reflection of, and complement to, the FDA’s ongoing stance regarding food security, which is that the best defense is to be prepared. In 2006, the FDA developed a food defense awareness initiative based on information in the five original guidance documents. The five-part program, which goes by the acronym ALERT, is intended to raise awareness on the part of state and local government agencies and the food industry regarding food defense issues. To that end, ALERT identifies five key points industry can use to decrease the risk of intentional contamination at their facility: assure, look, employees, reports, and threat.
The initiative has been expanded into a Web-based training module. “This training module will provide stakeholders with the information they need to begin or enhance their thinking about ways to prevent intentional food contamination within their span of control and facilities,” Garcia says. More information can be found at www.cfsan.fda.gov/~dms/alert.html.
HACCP Emphasis Needed
Food security measures are a good thing, but regulatory bodies need to place more emphasis on hazard analysis and critical control points (HACCP) programs in the retail and food service sectors, says O. Peter Snyder Jr., PhD, president of the Hospitality Institute of Technology and Management (St. Paul, Minn.). Dr. Snyder is also a spokesperson for the Retail Food Alliance (RFA; Florence, Ore.), an organization whose members implement HACCP and strive to protect public health while developing new products and processes.