Back in the 1980s in Wasco County, Ore., an extremist group sought to sway election results by poisoning people. They did so by contaminating 10 restaurant salad bars with Salmonella, and 751 people got sick.
In 2014, thousands in Japan became ill after eating food laced with 2.6 million times the allowable level of the pesticide malathion. This was the work of a disgruntled employee from a frozen food company. Before it was over, 6.4 million bags of frozen food were recalled.
This past December, two boys, aged 12 and 13, broke into a Sioux City, Iowa, honey farm and knocked over all of the hives. No bees survived the winter temperatures and the business was devastated.
Political gain. Revenge. Plain old vandalism. The motives and the methods are different, but these three stories have several things in common: the companies were completely unprepared for these actions; and the business and the brand were harmed.
There are many more stories, and with the increasing globalization of the food supply chain, there will be many more opportunities for the intentional contamination of food. No one in our industry is exempt from the threat.
Food Defense in a Global Supply Chain
We live in a country where food from everywhere in the world enters our food supply chain every day. We are truly fortunate to have such choice. But we must also ask ourselves how many steps are in place to protect those products on their journey?
A classic illustration is milk. It is stored at individual dairy farms, transported from farm to farm via tanker truck, moved to a co-op, transferred to a dairy milk processor and moved through storage tanks, mix tanks, homogenizers, and fillers, and finally into a carton destined for a state-wide school system. The possible points of entry for an attack are numerous, and the impact both emotional and physical in loss of life and suffering would be devastating.
These very real threats have been recognized by the U.S. government and the voluntary Global Food Safety Initiative (GFSI) benchmarked standards, which contain criteria for food defense. With the passage of the Food Safety Modernization Act (FSMA), the Intentional Adulteration rules and regulations have been put in place. These state that you must develop and implement a food defense plan that includes: a vulnerability assessment; mitigation strategies; monitoring, corrective actions, and verification procedures; and training and recordkeeping.
At a minimum, the food defense plan must be reanalyzed every three years. Records of all activities must be maintained for two years.
If a vulnerability assessment is an evaluation of each point, step, or procedure in your food operation to identify significant vulnerabilities and actionable process steps, the parallels to Hazard Analysis and Critical Control Points (HACCP) are unmistakable. Any company that has a food safety management system in place understands the framework within which the food defense plan must be developed.
But it would be wrong to simply add food defense to your HACCP team’s list of duties. Food defense requires a different mindset and a different set of skills. And just as you train your workforce in food safety best practice, you must train them in food defense awareness and mitigation strategies.
Building Your Food Defense Training Plan
What to train and how much to train will depend on the specific responsibilities of your workers. The baseline is awareness training: What is intentional adulteration? How does it differ from food safety and food fraud? And what can each individual do to protect the company?
The FDA has developed resources to help you build awareness in your workforce, and I encourage you to take advantage of them.