Current State of Intentional Adulteration
By The Food Protection and Defense Institute
The last century has seen significant changes in our food production and consumption. The early 1900s were met with global challenges in world wars, economic depression, and food rationing. Rapid production and technology growth in the second half of the twentieth century introduced advanced capabilities in food production including advances in preservation and packaging. These changes, along with advances in transportation, moved consumption patterns of food from local to global sourcing. Today, our global food system is a complex, integrated system of systems. While we will need to produce a lot more food to feed an estimated 9 billion people by 2050, we can’t ignore the threats to our food supply from adulteration.
With the terror attacks of 9/11 seventeen years in our rearview mirror, response structures have evolved and funding scenarios have changed. The limited economic environment at all levels of government presents new challenges for maintaining and protecting critical infrastructures, including food and agriculture. In the food and agriculture sector, a multitude of factors complicates the task of protecting and maintaining critical infrastructure. Food is produced, harvested, processed, formulated, packaged, and transported through an interconnected network from farm to fork, with challenges presented through global production, just-in-time delivery, and evolving consumer demands.
Whether at a restaurant or processing facility, intentional adulteration perpetrated by disgruntled employees, terrorists, or those motivated by money can happen at any time. No doubt you’ve seen past headlines:
“Factory worker sentenced for lacing seafood with malathion”
“Woman draws jail sentence for contaminating chicken in 2016”
“Michigan Man Charged With Sprinkling Poison on Food at Stores”
“Extortionist seeking millions by poisoning supermarket food: German police”
Intentional adulteration of food did not diminish in 2017. Adulteration cases of spices with undeclared ingredients to extend the product or boost color were documented. Terrorists’ plans and food adulteration tests were uncovered and publicized. As evidenced by the headline above, a German man threatened to put antifreeze in the nation’s baby food supply chain. Disgruntled employees continued to adulterate food to get revenge on their employer or coworkers.
We hear about terror attacks or foiled terror attacks involving explosives with increasing frequency. However, a 2017 incident in the UK is one of the first we’ve seen where an intelligent adversary met all three conditions of the food defense triangle to present a threat—motivation, capability, and insider access to vulnerable food production. In this case, two people were found guilty of preparing for a terrorist attack, including ties to a terrorist organization and the manufacture of ricin. One of the two was employed by a major food manufacturer. Inside attackers with legitimate access to our food systems exist, and even though we may not be able to influence their motivation and capability, we can certainly mitigate the vulnerabilities to the resource we depend on for life.
Given the complexity of our food system and limited transparency of supply chains from farm to fork, those willing and able to adulterate will continue to do so in 2018. Certain trends or issues like consumer demands, global supply chains, and disasters create new opportunities and motivations for adulteration or increase vulnerabilities in the food system. However, we can all work together to decrease the vulnerabilities and risks of intentional adulteration through continued research and outreach, conferences and networking, and employee and public education, and training.
We speak with our dollars spent. And food companies listen. Food production is driven by consumer purchasing, whether it is a flavor trend—sriracha-flavored almonds—or a perceived health benefit—Golden Milk (juice with turmeric). Look at your local grocery aisles and you will find an ever-increasing section of “freedom foods.” These are foods that claim to be free of something, whether it be gluten, lactose, pesticides, or genetically modified ingredients.
With increasing frequency, consumers are also asking questions about the sustainability and agriculture practices of the food they buy: How have the oceans been fished? Are my eggs from cage-free chickens? Does the food I buy protect the environment? Based on current trends, consumers will continue to spend their food dollars on flavor trends, organic, “free of,” and sustainably produced food. Consumers are willing to pay the additional costs for these items, making it a lucrative business for both legitimate food companies and fraudsters.
This means food defense needs to have a keen eye on where those with intent to adulterate could enter the market with products representing these food trends. Such opportunities may come from an evolution in technology or policy where regulation or inspection has not caught up or from the sheer demand of a trendy food product.
Cascading Events of Supply Chain Failure
Today, the food system from farm to fork is a global, highly integrated, and complex system of systems. Failure in one place has ripple effects downstream. When these infrastructure failures stack on top of each other, there are cascading effects that leave the companies without product for the market and consumers without food. For example, a sign was posted in our local grocery not long ago that read:
Sorry for the inconvenience we are currently out of bananas
The causes of the current shortages are many and complex:
• Typical low winter production from the tropics, exasperated by both flooding and colder than normal temps in Costa Rica.
• Abnormal Heavy seas causing vessel delays both in delivery to the US and return vessels to reload in the tropics.
• The same weather front causing heavy seas bringing heavy rains in Guatemala.
• Political upheaval in Honduras. In addition to unseasonable heavy rains, Honduras has been under political unrest for two months after their election. Now there are major strikes going on causing a very small amount of bananas to leave the country.
The sign single-handedly demonstrates our point. The “banana shortage” is a result of disruptions, including weather events, political unrest, and civil strikes. These precipitated a series of cascading infrastructure and supply chain failures. Extreme weather (flooding and temperature) led to low production. Choppy seas disrupted transportation of product. Political instability in one region of the world resulted in labor challenges. All these factors contribute to significant supply chain disruption. Obviously, the disruption in banana supply affects consumers, but how does it impact protecting our food from intentional adulteration?
Another recent example illustrates how easily intentional adulteration, economically motivated adulteration in this case, may occur with supply chain disruption. A major fast-food chain experienced catastrophic failure in their supply chain as they transitioned to a new transportation company. The fast-food chain has been forced to temporarily close more than 80 percent of their stores in one of their significant markets. This in itself is significant, but when paired with headlines like “Workers filmed smuggling chicken through the backdoor,” damage to the brand grows even more due to the mistrust sown in the consumer mindset about the quality of product in the restaurants.
Intelligent adversaries constantly look for new vulnerabilities to exploit in the food system, whether to make money (economically motivated adulteration, EMA) or cause harm to humans, animals, or brands. A significant shift in supply and demand offers an opportunity for adulteration when there is less product available in the marketplace. It is imperative that we start integrating our information and make sense of what it is telling us to make evidence-based decisions. While the banana shortage case is one example among many (e.g., transshipment of product, species substitution of meat and fish), it is a great example of predictable surprise. The concept articulated by Bazerman and Watkins defines these circumstances as “an event or set of events that take an individual or group by surprise, despite prior awareness of all of the information necessary to anticipate the events and their consequences.” With data and computing power available, we can, and need to, identify these cascading infrastructure failures sooner. We can prevent and mitigate catastrophic consequences of adulterated food. This critical work of “sense making,” or putting disparate information pieces together to share a complete picture of potential or actual disruption, is the focus of projects like the Food Protection and Defense Institute (FPDI) Focused Integration of Early Signals.
Current State of Food Defense
“Food defense” is the sum of actions and activities related to prevention, protection, mitigation, response, and recovery of the food system from intentional acts of adulteration. We have seen global expansion of food defense activities to counter all motivations of intentional adulteration (terrorism, sabotage, and EMA). Typically, there has been some intentional adulteration threat or event that has led countries around the world to change their food defense posture. In the UK, the 2013 horse meat scandal created reform to address this issue, which led to EU funding for food integrity. New Zealand initiated its reform in 2015 after a blackmail case where the perpetrator threatened to lace infant formula with a pesticide. Some countries have added policies under their food safety laws and others have labeled this work as food protection.
In the U.S., the Food Safety Modernization Act (FSMA) initiated the largest food policy reform in decades. Two of the published U.S. Food and Drug Administration (FDA) rules relate to food defense activities. EMA must be addressed under the Current Good Manufacturing Practices, Hazard Analysis and Risk-Based Preventive Controls for Human Food rule. EMA is considered a hazard that is reasonably foreseeable, and companies must develop preventive controls to address the risk. The second rule related to intentional adulteration is the Mitigation Strategies to Protect Food Against Intentional Adulteration rule, which requires, for the first time in the United States, that food companies develop a plan to defend and protect the food system from terrorism and acts by insiders with legitimate access that may cause wide-scale public health harm.
The Final Rule for Mitigation Strategies to Protect Food Against Intentional Adulteration, also known as the Intentional Adulteration or “IA” rule, requires FDA-registered food facilities to identify specific vulnerabilities in their facilities that could allow someone with bad intentions to deliberately introduce an adulterant. This vulnerability is named an actionable process step by the IA rule. Food companies must also create a food defense plan to prevent or mitigate those vulnerabilities at the actionable process steps. The IA rule also requires that employees who work at actionable process steps in food facilities must have:
• Education, training, and necessary experience to perform their responsibilities
• Knowledge of the mitigation strategies at the actionable process step
• Training in food defense awareness
Any employee who is responsible for an identified actionable process step in a food facility—and the supervisors of those employees—must complete food defense awareness training. Furthermore, any employees responsible for writing the parts of a food defense plan (e.g., vulnerability assessment, assignment of mitigation strategies, plan reanalysis) will also have to complete appropriate topical training to perform the task according to regulation and guidance.
What Can Food Companies Do Now?
Compliance with the IA rule for many food companies will be required in July 2019. To prepare, companies should take time in the next 12 months to strategize and initiate activities that will be required for compliance. One approach is to start small by taking a single food product and considering the following:
Assess: How much information is already available through past food safety and food defense planning? Identify and document where action may be needed.
Understand Hazards: Select a food product and document the hazards that may affect this product. Think outside the typical safety hazards. What could cause harm beyond the normal concerns you have? Consult incident reports, published literature, and known cases. Have you considered introduction of pesticides, undeclared allergens, or cleaning and sanitizing agents?
Assess the Supply Chain: Map the supply chain of the food product including the supply chain of ingredients. Where is the product coming from? Indicate how it travels and where there are inspection points. Can you document all the way back to “farm”?
Plan: Do you have a food defense plan? If yes, evaluate to see that it meets the requirements of the IA rule. Does it consider all hazards identified above the transportation network? Determine the last time the plan was challenged or exercised; was it more than a year ago? If no, find a resource to aid your planning (e.g., FDA Food Defense Plan Builder, U.S. Department of Agriculture, FPDI). Determine who within the food company can initiate a food defense plan and start identifying and prioritizing where vulnerabilities need to be mitigated first. Create a timeline for development and review.
Conduct Vulnerability Assessments: Evaluate the production of the food product to determine where it may be susceptible to intentional adulteration.
Determine Actionable Process Steps: From the vulnerability assessment, identify the processes during food production where mitigation strategies can be applied and are essential to substantially minimize or prevent the significant vulnerability.
Mitigate: Identify mitigation strategies for each actionable process step based on your assessment. FDA has a database of mitigation strategies13 that may be helpful. Next, determine the cost of those strategies and prioritize what strategies should be implemented first. Finally, initiate a plan to implement selected strategies.
Educate and Train: Different team members need various levels of training or awareness. Identify who will have a role in food defense and align the appropriate training. There are many training opportunities already available at the FDA Food Defense website. In addition, FPDI offers a variety of in-person food defense trainings14 as well as a food defense awareness online training15 for those looking to be trained from the comfort of their home.
The Food Protection and Defense Institute
In 2004, the Department of Homeland Security (DHS) created the FPDI. The institute was formerly known as the National Center for Food Protection and Defense. It was one DHS Center of Excellence established to evaluate and research the terrorist threat to the homeland. Over the past decade, the work at FPDI has evolved to consider food system disruption regardless of motivation. Today, FPDI operates with a mission of “Providing the highest impact innovation, education, and outreach to defend the global food supply.” By taking a comprehensive farm-to-table view of the food system, encompassing all aspects from primary production through transportation and food processing to retail and foodservice, FPDI’s work addresses both the vulnerabilities requiring assessment by the IA rule and vulnerabilities throughout the food system.
FPDI’s research and education programs aim to reduce the potential for contamination at any point along the food supply chain as well as the mitigation of potentially catastrophic public health and economic effects of such attacks. FPDI’s programs incorporate cutting-edge research across a wide range of disciplines, including supply chain management, logistics, epidemiology, risk assessment, economics, molecular biology, food microbiology, biomedical engineering, toxicology, information sharing, supply chain security, cyber security, and risk analysis.
FPDI education professionals and subject matter experts have extensive experience in designing, developing, and delivering a continuum of food defense training. FPDI also offers in-person programs developed to address food defense needs at all levels within an organization—entry level to C-suite—and across a variety of disciplines: national to local government, law enforcement, food manufacturing and retail, supply chain and logistics, and foodservice, catering, and restaurants.
In addition, a variety of training opportunities and course offerings are available that address FSMA IA training requirements, FSMA Preventive Controls requirements regarding EMA, increasing awareness of food defense on a global scale, understanding and applying food defense principles, identifying food defense vulnerabilities, creating tailored food defense plans, and challenging preparedness and response planning. FPDI’s programming supports industry, government agencies (law enforcement, emergency responders), nongovernmental organizations, international partners, undergraduate and graduate students, and educators. FPDI strives to provide strategies for prevention, mitigation, response, and recovery from potentially catastrophic public health and economic effects of attacks on our food supply.
Food defense is a critical aspect of ensuring the availability of safe, nutritious food on a global scale. Our food systems are a global, complex, interconnected system of systems. Defending this system, the integrity of the food produced by it, and the health of the public it feeds, from malevolent actors—both terrorist and criminal—requires engaged collaboration from all stakeholders, including domestic and international food producers, academic researchers, nongovernmental organizations, and many government agencies. This collaboration must include sharing information and robust discussion about 1) the latest scientific advances in detection, risk and vulnerability assessment, and prevention and response methods; 2) analysis of emerging threats and important evolutions in long-standing ones; and 3) emerging regulatory and policy issues. These activities, accomplished through work initiated at FPDI, are critical for advancing food defense knowledge and achieving the coordination of effort required to successfully protect the food supply and public health.
The Food Protection and Defense Institute (FPDI), formerly known as the National Center for Food Protection and Defense, was officially launched as a Department of Homeland Security Center of Excellence in July 2004 at the University of Minnesota. Developed as a multidisciplinary and action-oriented research consortium, FPDI addresses the vulnerability of the nation’s food system. FPDI takes a comprehensive, farm-to-table view of the food system, encompassing all aspects from primary production through transportation and food processing to retail and foodservice.