A Food and Drug Administration proposed rule announced in late 2012 was a positive step in protecting one part of the food supply and a reminder to another segment. The rule, designed to protect the food supply from acts that could result in large-scale harm to public health, justifiably warranted the attention of the FDA because of the risk posed not only to public health, but also to the economy. The rule would require food facilities to identify and address areas of vulnerability in their processes where acts of terrorism would be most likely to occur, not unlike the Hazard Analysis and Critical Control Point programs required to ensure food-safety standards at federally inspected meat and poultry processing plants. The rule was the subject of a public meeting this past month and is available for public comment until March 31, 2014.

When announced in late December, the FDA pointed out that the rule did not apply to farms or food for animals, and that the goal “is to devise an approach that effectively protects the food supply in a practical, cost-effective manner,” according to Michael Taylor, FDA’s deputy commissioner for foods and veterinary medicine. The FDA action is a proactive approach to a looming threat that is all too easy to overlook. Indeed, this action should serve as a wake-up call to the US Dept. of Agriculture and the production and processing segments of the meat and poultry industry, which is at least as vulnerable as the companies overseen by the FDA.

In 2006, I was one of about 800 attendees of the International Symposium on Agroterrorism, where a consortium of government agents from the USDA, FDA, Federal Bureau of Investigation and Centers for Disease Control and Prevention came together with representatives from the food production and processing sectors to address the threat most felt would inevitably become a reality. A theme of teamwork among all the parties resonated at that year’s event, which led to three more symposiums in subsequent years.

At the 2006 event, then-Secretary of Agriculture Mike Johanns said, “The USDA simply cannot do this alone,” when discussing the responsibility of protecting the nation’s food supply. “We have to prepare for the possibility that it could happen anywhere,” he said during a press conference I attended after his presentation. Since then, I have seen efforts to control threats in plants, including limiting access to vulnerable areas of facilities, securing shipments of supplies during transport and at shipping and receiving docks. Steps like these are effective, but vulnerabilities remain and the potential for disaster has not declined, especially in the segments the FDA proposal specifically disclaims: farms and food for animals. Recent estimates of the economic impact of an intentional outbreak of foot-and-mouth disease in the US top $50 billion. Recently, the global impact of other animal diseases, including avian influenza and Porcine Epidemic Diarrhea virus, provide ample proof that vigilance throughout the food supply chain is essential, across agencies, species and food types of all kinds.