Bioterrorism: The Next Food Safety Threat
By Michael M. Cramer
Like many other Americans, on September 11, 2001, I sat in stunned horror watching television news reports of the deliberate and cowardly attacks on New York and Washington and in the skies over Pennsylvania. I was travelling at the time and was fearful of when and how I would get home or if the flight home would be safe. That’s one of the objectives of terrorism, to strike fear and diminish confidence. Terrorists seek to do harm, to kill and maim, but they also seek to disrupt our businesses, our economy and our security. They are like the foodborne pathogens we in the food business fight so diligently; ubiquitous, hiding in dark recesses and striking, sometimes without warning, causing harm to those with whom they come in contact.
In the time since the attacks, I continue to travel, less fearful and more confident due to added security at the airports. I find, however, that I remain at a heightened level of awareness of the potential for further action against our country by those who wish us harmed. Though terror might not come again from the skies, it may well come from a source closer to all of us, through contamination of our food supply and our products. It is with this in mind that I write about the need for food companies to be at a high level of awareness and take actions to minimize the risk of being a terrorist victim. Ask yourself if you are the potential target of a terrorist attack and then put plans together to assess your vulnerability. Evaluate the following recommendations and take the appropriate actions, where you are capable and where they are applicable, to prevent product tampering or other interference with your business operations.
VISITORS AND EMPLOYEES
Have a clear visitor policy that requires sign in and sign out at a security desk or reception. Limit access to the plant to all visitors unless accompanied by a company employee. Require visiting regulatory personnel to present official identification (ID) and sign in and out of the plant. Inspect all incoming visitor vehicles. Keep plant doors closed at night and on weekends, even if the only ongoing activity is sanitation or maintenance.
Maintain accurate and updated employee rosters, including rosters specific to each shift. Know who is and who should be in the plant. Where possible, have photo ID cards for associates and restrict access to the plant to employees and regulatory personnel. Limit cooked ready-to-eat area access to essential personnel and prohibit all personal items, including lunch containers, cases, purses, and so on, from processing areas.
Maintain an up to date inventory of all hazardous lab chemicals and solvents and keep hazardous materials securely locked. Microbiological labs should keep positive control of pathogen cultures under lock as well. Assure that mercury thermometers are accounted for on a daily basis. Restrict lab access to lab personnel and essential management and keep the lab locked when not occupied. Do not allow lab materials, with the exception of sample collection materials, to be brought out to the manufacturing floor.
It is also recommended that plants conduct an assessment of all potentially hazardous chemicals such as maintenance solvents and paints, sanitation chemicals and wastewater treatment compounds. These too should be kept in a secured storage area with limited access.
Know your suppliers. Have a specific policy to identify new suppliers to assure a safe supply and be certain to have a general and continuing letter of guaranty on file. Have a program for inspection of incoming ingredients and incoming ingredient package integrity to assure that ingredients have not been tampered with. Develop accountability for all restricted ingredients (nitrites) and food allergens (dairy, wheat, soy, peanuts, tree nuts, eggs, fish and crustacea). Keep sensitive ingredients locked and have specific personnel identified and trained to handle them properly. Fill ports for ingredients stored in external silos or tanks (e.g. oil, flour, corn syrup) must be secured to prevent tampering. Have the ability to trace specific ingredient lots to finished product lots. These precautions apply to direct product contact packaging as well as to ingredients. Does your facility have a well for processing and clean-up water? Evaluate the security of the well systems. Consider testing for water potability more frequently, depending on the water source; e.g., weekly rather than monthly, or monthly rather than annually.
Personnel who move freely through the plant, typically quality assurance (QA) and production associates, should be alert to and aware of any abnormal findings in the plant. Look for signs of sabotage to equipment, missing, broken or unprotected glass or indication of tampering with ingredients and packaging. Make sure that protective equipment (e.g., screens, sifters, magnets or metal detectors) is in place and functioning properly. Report any unusual activity to a manager, supervisor or appropriate authorities. Account for all keys to the facility or restricted areas held by supervisory employees.
It is not enough to simply have a recall policy and procedure; food companies must also have a Crisis Management Policy and Procedure. In the event of a threat or real product tampering there must be a plan to address both the immediate issues as well as near term and long term issues. Terrorist actions can result in potential harm to plant employees, lost productivity, loss of customer confidence or lost business. There are very good consultant companies that can help you prepare an effective plan; however, listed below are some examples of steps that you can take to help you pull through a crisis period.
• Have emergency telephone numbers (e.g., fire, police, ambulance, hospital, the Federal Bureau of Investigation and regulatory agencies) available to key management and plant personnel.
• Have an emergency evacuation plan to get personnel out of the plant quickly and safely (this is an OSHA requirement).
• Provide a plant plan to the local fire department or have one in a locked, sealed container outside the plant in the event the plant cannot be accessed.
• Prepare a strategy for continued production using an alternate company plant or co-packer to avoid prolonged disruption of product flow to customers.
• Have an effective recall policy and plan. Test the effectiveness annually, at minimum.
• Develop a relationship with a qualified forensic lab to help with microbiological and chemical analysis or physical evaluation of unknown materials.
• Have prepared statements for the press and for customers identifying the action that you have taken depending on the situation. Develop a relationship with local print media, radio or television personnel so that they know about the company and the measures that you take to produce safe, quality products.
• Designate a spokesperson to deal with media calls, but be sure that they are well trained in handling the media.
• Prepare information about the company, especially detailing positive information about food safety, quality, and customer recognition and community relations.
As a nation we will recover from the tragedy of September 11 and our ideals of freedom and democracy will withstand evil terrorism. Our political and military leaders will develop their plans to battle terrorism on an international front to prevent further catastrophe. The American people have shown tremendous resilience in the face of adversity and a willingness to restore our damaged cities, our wounded economy and our fragile confidence. As food processors, we must do our part to assure that confidence in our products is never an issue. We must be prepared to prevent terrorists from striking our businesses; we must protect our common assets, valued customers and consumers.
Michael M. Cramer is Vice President Food Safety and Quality Assurance, Specialty Brands, Inc. in Ontario, CA. He is primarily responsible for the development and implementation of food safety and quality programs for the company He has been involved in the food industry for more than 24 years with experience in poultry, processed meat, spice and coatings and frozen foods. Specialty Brands, Inc. is a manufacturer and distributor of high quality, value-added frozen foods for both foodservice and retail. Brands include Rotanelli pasta, Fred’s appetizers and cooked portion meats, Posada and Marquez burritos and the highly successful retail line of Jose Ole Mexican entrees and mini Mexican appetizers.
Categories: Management: Food Defense, Recall/Crisis Management