The US Dept. of Agriculture’s Food Safety and Inspection Service defines food defense as: “Having measures in place to reduce the chances of someone intentionally contaminating the food supply in order to kill or hurt people, disrupt our economy or ruin your business.” As part of a voluntary food defense program, FSIS recommends that the plants it inspects (including meat and poultry procession operations) voluntary develop and implement security measures for food defense.
Protecting the nation’s food supply from acts of terrorism has long been a high priority for the food industry. After 9/11, however, it instantly shot to a red-hot-button issue. Since then, leading processors, working alongside multiple government agencies and health officials, have made strides in managing risks and minimizing vulnerabilities throughout the food chain.
The World Health Organization in 2002 acknowledged the threat and defined “food terrorism” as: “An act or threat of deliberate contamination of food for human consumption with chemical, biological or radionuclear agents for the purpose of causing injury or death to civilian populations or disrupting social, economic or political stability.” In May 2002, the US Dept. of Agriculture’s Food Safety and Inspection Service issued its FSIS Security Guidelines for Food Processors, addressing specifically how meat, poultry and egg processors could enhance their efforts to protect their food supply and ensure food security. The following year, the voluntary guidelines were supplemented when the agency issued the “FSIS Safety and Security Guidelines for the Transportation and Distribution of Meat, Poultry and Egg Products.” A critical part of the guidelines included recommendations that processing facilities create and implement a Food Security Plan for each operation.
Planning for security
In early 2011, Springdale, Ark.-based Tyson Foods sent each of its customers a letter assuring them that the company has implemented a food-defense system at all of its facilities. The letter, signed by Dean Danilson, Tyson’s vice president of food safety and quality assurance, says the company bases its food defense efforts by focusing on restricting access to its facilities and conducting surveillance. The extent of those efforts is determined by the level of vulnerability of the operations at and within each facility. The goal, according to Danilson’s letter, is to limit access to only authorized personnel and vehicles and protect the products using trailer seals, surveillance cameras and further restricting vulnerable areas within plants. Employees are also expected to be vigilant and aware of any suspicious activity and report it to supervisors, the letter states.
As part of its “Model Food Security Plan for Meat and Poultry Processing Facilities,” published in 2005, FSIS spells out the difference between food safety and food security, with the primary distinction being food safety addresses “accidental” contamination of food products whereas food defense focuses on preventing, identifying and responding to “deliberate” contamination. Food defense plans address biological, chemical and radiological-based threats involving criminal and willful acts of harm. Food safety, on the other hand, focuses on accidental incidents of contamination caused by pathogens, chemical and foreign objects. While Hazard Analysis and Critical Control Point programs are effective in controlling food safety risks, FSIS maintains a plant’s HACCP plan should not serve as a replacement for a food defense plan, although both should focus on prevention, as opposed to reaction.
Prevention and response, however, must work hand in hand when developing a food defense strategy. As recently as this past month, FSIS revised its directive on Food Defense Verification Procedures and National Terrorism Advisory System (NTAS) Alert Response for its personnel in the field. The directive spells out actions to be taken by inspectors if the US Department of Homeland Security issues an NTAS alert and how information will be communicated. It also provides criteria for inspectors to help them determine whether or not a plant’s food defense plan is functional.
OSI adopts video auditing
This past month, officials with Aurora, Ill.-based OSI Group announced plans to implement a video-based food-defense system at all five of its processing facilities in the US.
In 2005, OSI became one of the first food companies to use third-party, remote-video auditing to ensure the shipping compartments of trucks were equipped with tamper-evident seals. Video evidence of the practice is gathered by auditors using web-based video technology developed by Arrowsight Inc. Any deviations or non-compliance is noted by auditors and plant personnel are notified electronically and by phone of any breaches. Each year since 2005, OSI steadily expanded the use of remote video auditing throughout its US operations to increase productivity, enhance food-safety practices, ensure employee welfare and prevent foreign object contamination in products. In 2011, the company’s attention turned back to food defense.
Arrowsight’s food defense-focused surveillance and third-party auditing service ensures OSI workers are only in areas of the processing plant where they are authorized and that areas most susceptible to tampering or contamination are only accessed by approved employees. This program and service is being implemented at all of the company’s US plants and will be operational in the next six months.
“OSI has been working with Arrowsight since 2005 to innovate new solutions using RVA services and is proud to continue to drive new standards in the critically important area of food defense,” said David McDonald, president and COO of OSI Group, one of the largest suppliers of meat products to fast-food giant McDonald’s Corp.
Opportunities for improvement are revealed by addressing variances between what internal audits depict in a processing plant vs. what third-party, remote video auditing bring to light. Using RVA technology, processors “can really get after those variances, which is where we think the potential for the biggest risks are for both food safety and food defense,” says Adam Aronson, CEO of Arrowsight Inc., Mount Kisco, NY (www.Arrowsight.com). He adds that interest from other processors interested in addressing food defense is on the rise. Wichita, Kan.-based Cargill Meat Solutions is preparing an RVA food defense pilot project to determine applicability for its North American meat business.
Dr. Justin Ransom, OSI’s assistant vice president of food protection and government affairs, says food security has become a growing issue for the company. Using RVA as a management tool, Ransom says, “gives us greater confidence in what is going on in our plants.”
The benefits of the widespread adoption of RVA technology gives OSI the opportunity to improve food safety and quality while safeguarding the food products and ingredients against tampering during shipment, unloading and in storage areas.
As a supplier of beef and pork products for many well-known food brands, including McDonald’s, protecting the brand integrity of those customers is vital for OSI.
“Everything we do is critical to ensuring their long-term success,” Ransom says.
Like most processors, OSI relies on audits to understand and improve its processes. Besides internal audits (first- and second-party), OSI also utilizes third-party audits to verify that it is matching the high levels of performance assessed by the internal audits. This is in addition to the RVA process, which is random and gives employees no indication when an audit is occurring.
“The technology available now really changes our perception about how well we’re doing, especially on our internal audits,” Ransom says, adding that his team quickly learned that “employees improve their performance when they know they’re being audited.”
With the full suite of RVA offerings throughout its plants, OSI managers all have access to real-time footage of operations at any given time. They receive electronic alerts if a problem (including suspicious activity) is identified by any of the Arrowsight auditors, whether it is related to a food security risk or a quality issue. Plant operators are also regularly issued reports and data that quantify performance at all points of its production. “This information has been very critical in terms of improving our processes,” Ransom says. The goal of the food defense system, he says, is to create a process that cannot be circumvented and prevents anything from slipping through the cracks of the manufacturing operation.”
To protect OSI’s most vulnerable processes and restricted areas in the plant, Arrowsight auditors randomly check in-plant footage to ensure processing and food-safety features are followed and only authorized workers are given access to certain parts of plants.
“The Arrowsight audits allow us to have a greater confidence that what we say is going to happen, actually happens,” Ransom says.
OSI also uses the system of cameras, digital video recorders and a web-based software program to monitor and manage food-safety practices at the plant. This includes everything from handwashing to making sure the right people are working at the right stations with the right equipment on.
The technology is also used to monitor and measure performance on the quality front. Unlike RVA, in-house audits by QA technicians are easily detectable by plant operations workers and, not surprisingly, they follow procedures to the number while the auditor is there. The company additionally uses the technology as a traceability tool. Each box of product receives a time stamp that can be traced back and linked to video footage with a similar time stamp.
“RVA has proven to be very effective in verifying procedures are being followed,” Ransom concludes. “And to help us identify what we need to be working on in terms of training employees and closing the gaps in our processes.
A looming threat
Connecting the dots between all of the essential players involved in preventing, identifying and responding to threats of agroterrorism and opening the lines of communication throughout the food-supply chain is a key message at each year’s International Symposium on Agroterrorism conference. Presented by the Federal Bureau of Investigation and the Heart of America Joint Terrorism Task Force, conferences have been held in Kansas City, Mo., in 2005, 2006, 2008 and this past April. Typically drawing more than 1,000 attendees from more than 22 countries, the conference brings together private industry, law enforcement authorities, government agencies, scientists, academics, public health and medical professionals with a common goal of protecting the food supply. OSI’s Ransom and Arrowsight’s Aronson were among the presenters at this year’s event. One of the conference’s organizers leading the effort, Special Agent Craig Watz, says awareness about the threat posed by bioterrorism often wanes over time, but that complacency can be costly and dangerous. As time goes on and no other incidents occur, there is often a false sense of security that the threat has diminished. “People tend to relax a little bit. That’s just the nature of who we are as a human race,” he says. However, he warns, the people who intend to strike are not resting on their laurels. Instead, “they are preparing and planning.”
Watz and his legions of counterparts throughout the country have not had cause for relaxing their collective position. “We’ve always been concerned because we are so vulnerable,” he says of the food-supply chain. He acknowledges there has been tremendous progress made since 9/11, especially in the communication between all of the players involved in protecting the nation’s food supply, but more work remains.
Watz says the weakest links are not only the nation’s farms and ranches, where the only thing protecting many feedlots or herds of grazing cattle and rows of crops might be a rusty barbed wire fence. “The entire process is vulnerable,” he says. The threat of having foot-and-mouth disease or a harmful plant introduced at the farm is just the beginning. Transportation of crops, animals or products provides ample opportunities for evil-doers as well as in processing plants during the manufacturing process. A strategically embedded terrorist posing as an employee is a possibility all food processors should be aware of, Watz says. “If they’re determined to do so and you don’t have the proper measures in place, it can happen.”
Effectively monitoring all parts of the food chain can pose a challenge, but technology, including video cameras show promise, especially at the processing plant level, where productivity can be an advantageous by-product of ongoing surveillance. “Anytime you can put in place a system that monitors the process,” Watz says, specifically when it monitors workers’ activities, “you are going to allow those employees to focus more on their job.” Meanwhile, if an intentional contamination were to occur and a video surveillance system was in place, investigators can go back and trace exactly what occurred.
Since the first ISA event in 2005, anti-agroterrorism groups across the country have developed and lines of communication between private industry, local and federal law enforcement and public-health officials have been opened wide.
Since 2005, agencies including the DHS, USDA, FDA and FBI have worked together to develop the Strategic Partnership Program Agroterrorism (SPPA) Initiative to provide risk assessments of companies volunteering to participate. Using the CARVER+Shock tool (assessing Criticality, Accessibility, Recuperability, Vulnerability, Effect, Recognizability and Shock) the program is designed to audit food manufacturing facilities and assess their vulnerabilities. In the Midwest, a meat processing plant in Western Kansas participated in the program as did a dairy production facility based on the East Coast and many others. This program, Watz says, helps foster a mindset of “how can we best work together to protect the food we consume on a regular basis.”
There is clear evidence that progress is being made on the anti-bioterrorism front. For example, about five years ago, a contamination scare threatened the hog industry in Kansas, testing the system, Watz recalls. A well-orchestrated system of communication was utilized involving state agriculture officials, the farm operator and public health department officials in response to the threat. “We were able to coordinate a very refined response,” Watz says, to what ended up being a false alarm initiated by a “poisoned pen letter,” written as an idle threat from one party to threaten another. Nevertheless, “It gave us hope that if we had a real event we would know who to call, how the response would be made and that we would be able to work well together to properly contain the contaminant, mitigate the affect, properly respond and work together in the investigation."