In November 2018, a Berrylicious/Berry Obsession fruit farm’s disgruntled former employee was arrested in Brisbane, Australia, and charged with seven counts of contaminating goods, which included the corruption of numerous punnets of strawberries with sewing needles. It is believed that the malicious act occurred between the time the strawberries were packed and the time they were purchased. Although this crime might seem rare in the food industry, the evidence depicts a high probability of insider attacks against the food supply for reasons that include sabotage and terrorism.
In order to prevent this serious issue, the Food Safety Modernization Act (FSMA) was signed into law, giving the Food and Drug Administration (FDA) new authorities to protect foods from acts of intentional adulteration and to regulate the way they are grown, harvested, manufactured, processed, packed and stored. In May of 2016, a final Intentional Adulteration rule (IA rule) was created to help facilities prepare and apply with rigor food defense plans, which they must comply with on specific deadlines, depending on their particular size of operations.
The law has focused attention on the purity of foods from the perspective of deliberate contamination. For the first time in the history of food legislation, the concept of food defense has been introduced. Food defense is defined as measures to protect food from premeditated tampering from criminal or terrorist sources and it applies both to domestic and foreign organizations that export food to the United States.
It is important to note that no food is inherently more at risk than another. On the contrary, the drivers of vulnerability are found in the processes. Protecting the food supply from intentional contamination, therefore, requires the application of effective food defense strategies. Food defense is a relatively new, but extremely important concept because of the many vulnerable access points in the farm-to-table food supply chain.
People often assume food contamination is unintentional, nevertheless, based on an evaluation of critical infrastructure in the early 2000s, the Federal Government declared the Food and Agriculture sector to be one of 17 critical national infrastructures open to intentional attack.
Acts of intentional adulteration can look like:
- Acts intended to cause wide-scale public health harm. (e.g., significant human morbidity and mortality)
- Acts of terrorism on the food supply.
- Acts of disgruntled employees, consumers, or competitors intended to attack the reputation of a brand.
- Economically motivated adulteration (EMA)
Organizations must take the time and money to create a food defense plan with comprehensive security solutions, covering every aspect of their facilities including processing, material handling, personnel, storage, shipping and receiving, site security, utility connections, and the use of cybersecurity. It is vital that food facilities identify significant pain points, implement the recommended mitigation strategies and take a systematic approach to the food defense program.
Components to the Plan:
Recordkeeping starts with having at least two copies of the food defense plan: one to be used by the food processing facility and one to be kept outside, in the event an IA or other emergency occurs and access to the facility is not possible. The defense plan for your own food processing facility should include the food defense team, vulnerability assessments with justification, and mitigation strategies with documentation of implementation. In addition, monitoring procedures, including frequency and security measures must be clearly stipulated.
Tracking of monitoring activities, corrective actions, and verification are other aspects of record keeping. Records should be maintained for two years to comply with the regulations; however, they must be easily and readily available when requested. Moreover, it is necessary to collect the data in an electronic form.
Processors of all types of food are required to evaluate the hazards in their operations, implement and monitor effective measures to prevent contamination, and have a plan in place to take any corrective actions that are necessary. The average cost of a recall to a food company is $10 million in direct costs, in addition to brand damage and loss of sales according to a joint industry study by the Food Marketing Institute and the Grocery Manufacturers Association.
There are many different types of guidelines and protocols that are appropriate for each type of facility. The FDA has comprehensive Guidance for the Industry that should be adhered to. In terms of plant physical security, here are some good steps to have a plan of action for:
- Protecting perimeter access with fencing or another deterrent.
- Minimizing the number of entrances to restricted areas and set up strong access control to these entrances.
- Establishing a system of positive identification and recognition that is appropriate to the nature of the workforce (for example, issuing uniforms, name tags, or photo identification badges with individual control numbers, color-coded by area of authorized access).
- Setting up remote monitoring and alarms that are triggered when unauthorized employees access certain areas or access is requested at odd times.
- Monitoring the security of the premises using appropriate methods (for example, using security patrols and video surveillance).
The IA rule gives food organizations the flexibility on how to monitor food processes. In many instances, managers may elect to have employees observe whether the mitigation strategy is operating as intended. However, this error-prone solution is expensive and ineffective. On the other hand, monitoring with IP-based sophisticated cameras, built to withstand the harsh conditions of the food industry, can truly prevent a damaging IA situation.
The right cameras can be used as an outstanding strategy for food defense, allowing the facility to monitor production line staff and day-to-day operations, pinpoint cross-contamination instances, consolidate reporting across locations, and assist with investigative processes.