Is Our Food Safe From Attack?

Food DefenseCourtesy of Food Technology magazine, from "Defending the Food Supply," August 2005, Vol. 59, No.8. Food Technology is a publication of the Institute of Food Technologists, www.ift.org.

In a Food Preparation and Service Setting1

On Sept 11, 2001 the U.S. was attacked2No one had ever imagined an attack of that magnitude. The events of Sept. 11, 2001 have focused attention on terrorism and the potential for future acts of terror.

No other terrorist event has ever killed more people or caused more economic damage. Nearly 3,000 people were murdered and over 80 million dollars in losses were incurred. This number represents direct costs of medical and clean-up. There are many indirect costs beyond that such as increased security in airports and other public venues across the nation.

The U.S. government has declared the food and agriculture sector to be one of 17 critical national infrastructures vulnerable to intentional attack.

3Congress passed the Bioterrorism Act of 2002 which expands governmental authority to prevent, detect, and respond to an attack.

The U.S. Food supply Chain produces about 13% of the nations gross domestic product and accounts for 18% of domestic employment. Weapons of Mass Destruction or other contaminants could be used, or their use could be threatened against our nations food supply. An attack on the food and agriculture sector, or merely the threat of an attack could cause havoc with the food supply chain and have far reaching consequences with health, economics and consumer confidence.

There are 31 documented cases of terrorism (threats or actual contamination) involving agriculture. Of those 10 were on livestock (5 biological, 4 chemical, and one toxin). Sources:Food Technology 7-06 p.34-42

What Type of Harm Could Occur?Intentional delivery of a harmful biologicalor chemical agent to the food supplysystem could cause:

Physical harm (illness or mortality)Economic disruptionDirectIndirectInternationalPolitical unrestPsychological harm loss of confidence in food supply

See pages 4-5 in MU Extension Guide MP914 Food Defense: Protecting the food supply from intentional harmThere are several reasons why the Food and Agriculture sector is vulnerable to attack. Damage to the food supply system could cause a multitude of problems, from death and illness to economic damage, political unrest and psychological harm. There are groups violently opposed to imprisonment and exploitation of animals, use of meat and fur, and animal by-products, use of meat from genetically modified animals, and use of meat from animals that have consumed antibiotics. There are also many extremist groups both domestic and foreign that could choose to target food and agriculture, for economic or political reasons. Awareness of this vulnerability is a big part of reducing the risk. The goals of an individual or groups wanting to intentionally contaminate the food supply are varied. They may wish to cause any or all of the following:Physical harm: Morbidity (illness) or Mortality injury through contamination of food could be caused to a few individuals or large numbers of people, depending on the contaminant and level of contamination. Economic disruption: Contamination or even the threat of contamination in our food supply could cause major damage economically. Food and Agriculture account for140 billion in revenues, 13% of U.S Gross Domestic Product and 18% of U.S. employment.a. Direct economic losses include costs associated with the response to the act of contamination which include:medical costs: related to death, illness and recovery, and any preventative measure taken to assure the health of animals and humans at risk.wages: both those lost by workers at affected facilities and also extra wages incurred by those responding to the act (security, emergency personnel, etc.)containment: quarantine of infected food or humans, tracking of contaminated food already shipped, storing contaminated food until cleared or disposed of. decontamination: removing any contaminant residue from food production or rocessing, clean-up of hazardous material (over million dollars was spent to decontaminate one postal facility contaminated with anthrax). Decontamination of some facilities may not be possible depending on the contaminant and the type of facility.disposal: contaminated carcasses must be disposed of in a safe manner (ie, burying, burning, burial at sea). Columbia locals may remember an issue related to improper disposal of hot dog casings. From 1995 through 1999, Kraft subsidiary Columbia Foods Co., maker of Oscar Mayer hot dogs, contracted with Wayland and Basnett to pick up and transport used casings for disposal. The casings were made of wood-cellulose fiber, gelatin and water. Over that period of time 9,000,000 lbs. of casings were dumped on a private farm. The DNR cited Kraft for violations of the Solid Waste Management Plan and the Water Pollution Control Program. All this fuss, and imagine how much worse the problem would be if it involved product contaminated with a hazardous material. b. Indirect multiplier effects include losses not directly associated with the response, effects that will add up down the line. Government programs that will food producers/processors for the food destroyed, losses for ancillary businesses such as suppliers, shippers, distributors, etc. If some of the ancillary businesses are dependent on that one large client, they may go out of business.c. International costs include losses associated with a loss in confidence by our international trading partners. C.Political change: The Rajneeshees tried to influence election results by poisoning salad bars to reduce voting.D.Psychological harm: Contaminations, or threats of contamination can cause a loss of consumer confidence, but also cause panic among consumers.Sources:Columbia Tribune archives http://archive.columbiatribune.com4Missouri Restaurant Industry:Over 13,000 locations in the state2007 projectionsemployment = 273,500sales = $8.1 billionEach $1 spent in MO restaurants = $1.38 in sales for other industriesEach $1 million spent in MO restaurants = 43.7 jobs

Will this Effect Missouri?5Restaurants generate economic growth, sales and tax revenues. Restaurants will likely add 2 million people by 2017. 32% of American adults get their first job experience in a restaurant.

9 out of 10 restaurants donates food, time, facilities and more to charitable causes.

Missouri ranks approximately 14th in restaurant sales

Sources:National Restaurant Association www.restaurant.orgMissouri Restaurant Association www.morestaurants.org

Case Study: Polonium 210November 23, 2006 Alexander Litvinenko died of acute radiation poisoning due ingesting a large dose of Polonium 210.1st person to die of acute -particle radiation effectsMost likely mixed into teaHighly toxicDifficult to find and identify

6Po210 is naturally occurring, but manufacturing enough to kill a person takes expertise and a nuclear reactor. Polonium is incredibly toxic.5 million times more toxic than H-cyanide. In theory 1g of Po210 could poison 100 million people, of which approximately 50 million would die. Po210 emits -particles which are taken up by a wide variety of cells. Other radiological compounds tend to target certain tissues such as bone and are more likely to cause cancer years down the road than a more immediate dysfunction, as is caused by the Po210. Po210 emits very few gamma rays and is therefore difficult to find and identify. The epidermis is not penetrated by the -particles and so the only danger comes from internal exposure, through food and water, aerosol inhalation, or entry through a wound.Sources:

Supplies7Supplies such as ingredients, chemicals, or packaging materials are vulnerable to intentional contamination. They may be contaminated prior to arrival, while in the warehouse, or during shipping. Processors must be confident in the security of their suppliers, and have strict standards for delivery and unloading of the supplies.Grapes of WrathA terrorist group claimed to have contaminated Chilean grapes with cyanide.Fruit was removed from U.S. stores, consumers stopped purchasing Chilean fruit. Only 2 grapes were found to have possible contamination.The threat caused $200-300 million in damages.

8There is a documented case, in which, a threat was made that had an impact on both the US and South American economies. In March 1989, an anonymous threat was called in to the US Embassy in Santiago, Chile, by a terrorist group claiming to have contaminated Chilean grapes with cyanide. March 12, 1989, the FDA found only 2 suspicious grapes on a dock in Philadelphia PA, but supermarkets throughout the US had pulled Chilean fruit off the shelves. Fruit that could not be returned for inspection was ordered destroyed. US consumers had been warned not to eat Chilean fruit. Besides grapes, most of the available blackberries, blueberries, pears, plums, melons and green apples available at the time were imported from Chile, and the incident ruined an entire season of fruit sales from Chile. 65% of Chilean fruit exports are bound for the US, and other countries such as Denmark also pulled Chilean fruit off the market. Although the US ban on Chilean fruit only lasted 2-3 weeks, the cost was $200-300 million dollars and a loss of consumer confidence that was slow to return. Sources:USDA FSIS www.fsis.usda.gov

Distribution9Distribution of product after processing often includes some type of storage. Some food products need refrigeration, or are stored and distributed as frozen product. Food products can be vulnerable to contamination during storage or distribution (which includes loading and unloading).

Food Service10Meat products are vulnerable to intentional contamination during food service. Cooking destroys some, but not all contaminants. Pre-cooked meat could be vulnerable, especially in a buffet line or a salad bar.

NEXT SLIDE IS A CASE STUDYNo Bleu Cheese Please!In 1984, members of an Oregon cult intentionally contaminated restaurant salad bars with Salmonella bacteria.They were attempting to influence an election.751 individuals became ill, 45 were hospitalized.

11In 1984, members of an Oregon cult headed by Bhagwan Shree Rajneesh used cultivated Salmonella bacteria to contaminate salad bars in 10 restaurants, and produce in 1 grocery store in The Dalles Oregon. The plan was developed by Ma Anand Puja the secretary and treasurer of the Rajneesh Medical Corporation and vice President of the Rajneesh church. They had obtained salmonella and other more dangerous bacterial agents from a commercial supply house. The cult had taken over one small town and wished to take over Wasco County Oregon. If they made enough citizens sick, they would not be able to vote and the Rajneesh candidates would be elected. Salmonella typhimurium was chosen as the contaminant because the symptoms are easily confused with those of food poisoning and it was not traceable back to the cult. The attack was not intended to kill, but if a few deaths occurred, the cult members deemed that acceptable. The bacteria was suspended in a brownish liquid and sprinkled on produce in the grocery store. It was added to the bleu cheese salad dressing, fruits, vegetables and coffee creamers at the restaurants. . Although 751 people became ill, and 45 needed hospitalization, the attempt to take over the county government failed. Local authorities initially thought the illness was due to poor food sanitation practices, and it took the FBI a year to connect the attack to the cult. The leader Bhagwan Shree Rajneesh was deported on other charges and died in India, Ma Anand Puja was convicted of the poisoning. The cult has disbanded. Sources:U.S. FDA www.fda.gov/ora/training/orauArticle by Scott, March 21, 2006 The Dalles Oregon- 1984 Rajneeshee Bioterror attack www.GoSleepGo.com

What is Food Defense?Food Defense focuses on security, protecting the food supply from intentional contamination. Courtesy of Food Technology magazine, from "Defending the Food Supply," August 2005, Vol. 59, No.8. Food Technology is a publication of the Institute of Food Technologists, www.ift.org. 12There are many government agencies that are tasked with assisting in the defense of our food supply, but in the end who is responsible? National and State governments can advise and guide preparedness, but the effected industries are, in the end, responsible for planning and prevention. Response to an incident will be fastest at the local level and developing a plan for response and communication will establish a base for an effective response.

All stakeholders should be involved in the efforts of planning and prevention. Local first responders, and industry links such as feeder, transporters, veterinarians, and cooperatives, need to be part of the team.

Is Food Defense Different than Food Safety?Food Defense focuses on protecting the food supply from intentional contamination.

Food Safety (HACCP) focuses on protecting the food supply from unintentional contamination. It can help with, but is not a substitute for food defense.

13There are differences between intentional and unintentional contaminations, beyond the obvious.

Who Might Intentionally Contaminate an Food Service Facility?Disgruntled employee/former employeeContract or temporary employeeMembers of terrorist or extremist groupsTruck driverAffiliate of a competing facilityVisitor to facility

14Intentional contamination can originate inside the targeted facility. Many attacks are orchestrated by disgruntled employees or disgruntled former employees. Thus far, these 2 groups have perpetrated most of the known incidents of food contamination. Examples include:1. A former hospital lab worker sneaked back into the lab and issued an e-mail invitation to former colleagues to enjoy some pastries (that she had contaminated with dysentery).2. A supermarket worker that contaminated ground beef in an attempt to get a supervisor in trouble.

Attacks could also be carried out by the cleaning crew, or contract and temporary employees. These workers may not have loyalty to the company and might be bribed or influenced by outside sources to participate in an attack.

Terrorist and extremist groups are always a concern. Their members may seek employment at a facility they intend to attack.1. Al Qaeda perpetrated the deadliest terrorist act, and may at any time be looking to top that. 2. PETA members have been quoted as, not engendering such an attack, but if it happened, that it could be in the best interest of the food animals and the health of the American public (ie, encourage vegetarianism). Members of this group frequently enter premises under false pretenses to shoot video tape.3. Religious extremist groups (cults) are capable of violence against themselves and others the Rajneeshees poisoned salad bars in Oregon in order to influence a county wide election.

4. March 1970, an Alabama group of KKK poisoned cattle with cyanide in order to get Black Muslims who had purchased property to sell out.

1996 Chlordane is intentionally added to components of cattle feed that was in turn distributed to 4,000 farms in 4 states. Product was recalled and raw materials destroyed. Losses to the company were $ 2.5 million dollars and total impact to the agricultural system was $250 million. The contamination was perpetrated by the owner of a competing livestock feed processing facility.Rats!Businessman poisons food of rival noodle shop with Tetramine.Poisoning sickens 400 kills 49 (soldiers and school children)Owner of rival Kindergarten contaminates lunch with TetraminePoisoning effects 70 kindergarteners and 2 teachers

Rival Chinese Businesses use banned rat poison containing Tetramineto harm a competitors business 15Eastern China: Chen Zhengping admitted placing rat poison in the pastries of the Heshengyuan Soybean Milk Shop in Tangshan near Nanjing in Jiangsu province . Hundreds of construction workers and boarding school students fell ill after eating fried dough sticks, sticky rice balls, and sesame cakes. Symptoms included dizziness, vomiting, seizures, foaming at the mouth and loss of consciousness or death. Zhengping ran a rival, less successful shop and was jealous of his competitor. He sneaked into the rival establishment and added rat poison to the water, and noodles. The poison used was Du Shu Qiang or strong rat poison which was banned by the Chinese government in 1991. The active ingredient is Tetramine (Tetramethylene Disulfotetramine), the lethal dose of which can be as small as 5 mg. More than 400 became ill and as many as 49 (many school children) died as a result of the poisoning.Sources:New York Times by Erik Eckholm 9-18-2002EINet News Briefs Archives 9-27-02Chinadaily.com

Southeast China Wuchuan, South China's Guangdong Province. 11-25-02, 70 Kindergarteners and 2 teachers fell ill after a school lunch of corn porridge laced with rat poison . Huang Hu had sneaked into the kitchen of the rival Anle Kindergarten in Huangpo town, the night before and put the rat poison in the salt. There were no fatalities, and Huang was arrested 3 days later.

Source:Peoples Daily Online www.Englishpeopledaily.com.cnPotential Contaminants

Biological Agents: Injure by causing disease, or producing toxin.

Chemical Agents: Injure through toxicity to biological systems, or chemical burns to tissue.

Radiological Agents: Injure externally with radiation burns and potentially deadly acute radiation sickness. Injure internally by causing damage to internal organs.

16Category A: Easily to use, high death rateBacillus anthracis (Anthrax)Clostridium botulinum toxin (Botulism)Category B: Moderately easy to use, moderate illness, low death rate, hard to diagnoseE. coli O157:H7Salmonella spp.(Salmonellosis)Shigella spp.(Dysentery)Not categorized: Naturally occurring, can cause symptoms in humans.Listeria monocytogenes (Listeriosis)Campylobacter jejuni

Bacillus anthracis

Clostridium botulinumBiological Agents of Concern

E. coliCampylobacter jejuni17Chemical AgentsBiotoxin (Ricin or Abrin) disrupt protein synthesisAconitine-AmanitinMetal (Arsenic) damages blood cellsBlood Agent (Cyanide) disrupts oxygen usage.Nerve Agent (Sarin) prevents nerves from controlling muscle contractions

18Radiological AgentsPolonium 210PlutoniumUranium 238 (U-238)

19Radioactive materials produce ionizing radiation, which can damage living tissue, by breaking chemical bonds or removing electrons from atomsRadiological Exposure can occur via:inhalationingestiondirect exposureFor defense purposes concern is for those experiencing acute exposure. This means short term exposure to high levels of radiation. Cancer patients receive this type of exposure, but under controlled conditions. Persons unknowingly experiencing acute exposure may exhibit symptoms such as burns and radiatin sickness. The symptoms of radiation sickness include, nausea, weakness, hair loss, and diminished organ function. If the dose is fatal, death will usually occur within 2 months.

Children and fetus are especially sensitive to radiation effects, due to the relatively rapid cell division.

Sources:www.epa.gov/radiationWhat Makes an Attractive Agent of Intentional Contamination?Long Incubation periodHighly effective (Potent, toxic, virulent)History of use (increases future chance of useAvailable (easily produced in adequate quantity)Low traceability

20Many who would intentionally contaminate food want the contamination to be discovered long after the initial contamination. Agents with a long incubation period will become more toxic after the contamination event and will be more difficult to trace. Agents with a delayed effect, such as radiation poisoning are difficult to diagnose and symptoms do not occur immediately after contamination. This delays identification of the contaminant and can make locating the source nearly impossible.

Highly toxic agents will be used by those wishing to cause a high rate of morbidity and/or mortality.

Once an agent has been used, it is more likely to be used again. Many of the deadly agents are pesticides used to kill other life forms and can also be used against humans or livestock.

Agents must be stable within the food they are contaminating. If conditions in the food cause a breakdown of the chemical the effect may be lost.

Agents are more likely to be used if they are easily available. Some like Ricin and Abrin can be isolated from plants. Agents isolated or produced by the contaminating person are less likely to be traced back than those which are purchased.

Whatever the form of the agent, be it gas, liquid or solid, it must not alter the appearance, odor, texture etc. of the food product.

Most groups planning an intentional contamination will chose a contaminant that will not be easy to trace back to them. When the Rajneeshees contaminated the salad bars in Oregon, the Salmonella poisoning was thought to be food born and it was not traced back to the cult for nearly a year.

What Do Consumers Think About Food Defense?Following several major food recalls in the US, consumer surveys were conducted.Courtesy of Food Technology magazine, from "Defending the Food Supply," August 2005, Vol. 59, No.8. Food Technology is a publication of the Institute of Food Technologists, www.ift.org. 21There are many government agencies that are tasked with assisting in the defense of our food supply, but in the end who is responsible? National and State governments can advise and guide preparedness, but the effected industries are, in the end, responsible for planning and prevention. Response to an incident will be fastest at the local level and developing a plan for response and communication will establish a base for an effective response.

All stakeholders should be involved in the efforts of planning and prevention. Local first responders, and industry links such as feeder, transporters, veterinarians, and cooperatives, need to be part of the team.

Consumer Confidence in Food Defense Systems After National Food Recalls

Stinson et al., 2008From: Thomas F. Stinson, Ghosh K., Kinsey, J. and Degeneffe, D. Do Household Attitudes About Food Defense and Food Safety Change Following Highly Visible National Food Recalls? Amer. J. Agr. Econ. 90 (number 5, 2008): 1272-1278

Surveys were conducted following national food recalls :

Between 2005 and 2007, there was an increase in the number of consumers considered to be not very confident about food defense.

Between 2005 and 2007, there was a decrease in the number of consumers considered to be very confident about food defense.22Who Do Consumers Believe is Responsible for Food Defense?Stinson et al., 2008From: Thomas F. Stinson, Ghosh K., Kinsey, J. and Degeneffe, D. Do Household Attitudes About Food Defense and Food Safety Change Following Highly Visible National Food Recalls? Amer. J. Agr. Econ. 90 (number 5, 2008): 1272-1278

Over 50% of consumers believe that government or manufacturers and processors should be responsible for food defense.23Who do Consumers Believe Should Pay for Food Defense?Stinson et al., 2008From: Thomas F. Stinson, Ghosh K., Kinsey, J. and Degeneffe, D. Do Household Attitudes About Food Defense and Food Safety Change Following Highly Visible National Food Recalls? Amer. J. Agr. Econ. 90 (number 5, 2008): 1272-1278

Most consumers do not believe they should bear the cost for food defense.24Products That Consumers Believe Most Likely to be Intentionally Contaminated

Stinson et al., 2008From: Thomas F. Stinson, Ghosh K., Kinsey, J. and Degeneffe, D. Do Household Attitudes About Food Defense and Food Safety Change Following Highly Visible National Food Recalls? Amer. J. Agr. Econ. 90 (number 5, 2008): 1272-1278

When surveyed about which products were most likely to be intentionally contaminated, Meat, Produce, Dairy, and Seafood were the areas they were most concerned about. 25Food Defense PlanDefense plans are encouraged but not required for farms and most food establishments.Courtesy of Food Technology magazine, from "Defending the Food Supply," August 2005, Vol. 59, No.8. Food Technology is a publication of the Institute of Food Technologists, www.ift.org.

26Food defense refers to reducing the risk of an intentional contamination of our food supply. Not all attacks can be prevented, but implementation of a food defense plan can minimize the risk of an intentional contamination. All food facilities should develop a plan specific to their product and operating conditions.

USDA FSIS and FDA both strongly encourage all food facilities (regardless of size) to develop a Food Defense Plan.Facilities Currently Required to Participate in Food DefenseAll vendors providing food for USDA feeding programs must now be in compliance with the Food Defense System.

27Sources:www.ams.usda.gov/fv/ppb.htmlFour Steps for Developing a Food Defense PlanAssess the vulnerabilities

Write a plan

Evaluate the plan

Maintain the plan

28Food processing/distributing facilities should implement those measures applicable to their particular operation.

The plan should include:1. Emergency planning-a. Planning for emergency evacuation (maintain floor/flow plan off site).b. 24 hour contacts for local law enforcement, and FDA or USDA, whichever is appropriate, posted , listed in order of contact in case of incident.2. Employee supervision planning-a. Plans to increase staff awareness/trainingb. Schedules for supervision/security checks3. Recall planning- secure handling and disposition of returned product 4. Investigation planning-investigation of threats, or suspected incidents, coordinating with law enforcement5. Evaluation planning- review plan (at least annually), mock recalls, random inspections, add new countermeasures as needed. Assess the vulnerabilitiesGather a team of key personnel to make the assessment.Use FDA Guidelines: Guidance for Industry Retail Food Stores and Food Service Establishments: Food Security Preventive Measures Guidance http://www.cfsan.fda.gov/guidance.html.Think like someone who wants to harm your operation.Look for areas where contamination would be spread through normal operations and areas that are not frequently observed.

29The process for assessing vulnerability endorsed by the FDA, FSIS, FBI, and Department of Homeland Security is CARVER + Shock. CARVER + Shock is a tool used to asses the value and vulnerability of potential targets. CARVER + Shock was initially used by the military (Department of Defense), but has been modified for the food/agriculture industry. It considers vulnerability and human ingenuity which are unique to an intentional attack. CARVER is an acronym which stands for the 6 basic attributes. A 7th attribute is added in the version modified for the Food and Agriculture sector.Criticality (public health, economic impacts)Accessibility (access to and egress from a target)Recuperability (system recovery potential)Vulnerability (ease of access)Effect (amount of direct loss suffered)Recognizability (ease of identifying a target)SHOCK (psychological effects)A particular food product for example, would be ranked based on scales developed for each of the 7 categories. Combining rankings from each of the attributes would allow a food product, process, or facility to be ranked on a scale from 1-10 (1 is low, 10 is high) for attractiveness as a target.

CARVER = Shock is not always practical for the small and very small operations. Thus we have come up with a worksheet to guide vulnerability assessment in many different types of operations.

Caf Vulnerability AssessmentCountermeasures are actions taken to shield vulnerable areas, reducing the risk of intentional contamination.

CountermeasuresCountermeasures are actions taken to shield vulnerable areas, reducing the risk of intentional contamination.31As high risk vulnerabilities are identified, counter measures are developed to reduce the risk of intentional contamination of those vulnerable areas.Areas to Consider for Countermeasure DevelopmentProceduresFacilityTechnologyPersonnel

All countermeasures protect: Personnel, product, and property

The most economical changes are generally changes in procedure that improve security. If procedural changes cannot reduce the vulnerability, changes to the facility may be slightly more costly (i.e. locks, gates, fences, signs etc.) and technology is more costly (i.e. surveillance camera), but is less expensive than hiring extra personnel for security.

The following are areas that arent usually considered by small producers and processors and are designed to give them some ideas to start with.32WorkforceShipping and ReceivingVisitors and CustomersMarketingCountermeasures for Procedures

Countermeasures for the workforce include:Screening employees (background check, check references, credit check, ICE check)Supervision of employees (if employees are well supervised they are less likely to cause intentional contamination)Limit access to sensitive areas (lock doors, use signage, use buddy system (no one alone in a sensitive area))Training Give basic food defense information to employees. Use SCAN system, See, Challenge, Ask, Notify (p 15 of guide MP914) or FIRST and ALERT which are provided by FDA free of charge (in several languages). If they are invested in your program they will more fully support it.Shipping and Receiving: Make sure there are designated times for delivery and an employee is present to check that the delivery matches and order and the bill of lading. Be vigilant with new or temporary drivers. Open packages and mail away from processing areasVisitors and Customers: Make sure they are supervised and/ or access is limited to retail area. Identify them (ask for ID), and have them sign a visitor logMarketing: Check security in the place your product will be sold. Who has liability in the case of an intentional contamination. Challenge would be contaminators by adding layers of packaging or using other ways to creatively limit touching.33

Light it

Lock it

Limit AccessCountermeasures for Facility

These 3 basic principles can be applied to increase the physical security of the facility.

Light it can mean adding outside lights such as dusk to dawn lights or motion sensor lights. The basic idea is to increase visibility, especially at night. Part of increasing visibility can be trimming or removing landscaping that limits visibility. Input from a retired peace officer or your county emergency manager may be valuable to determine where the lighting or landscape changes would do the most good.

Lock it refers to all exterior and interior openings such as doors, windows or ventilation screens that could be used to enter the building or a sensitive room. They should all be locked whenever possible and there needs to be a key inventory system. Keys should be retrieved immediately from dismissed employees. There should be a system for a specific person to check locks at the end of the shift or day.

Limit access means reducing the number of people with access to sensitive areas. This can be done with perimeter fences that limit access to the facility itself. Signage within the building or on the perimeter of the facility can be posted to indicate who has permission to enter. Authorized personnel only is useful only as long as everyone knows who is authorized. 34Write the PlanDevelop a countermeasure to defend each vulnerable point identified as high risk.Create a written plan including those countermeasures that are reasonable for the situation.Identify the individual who will implement the countermeasure.Set a timeline to implement the countermeasure.

35A countermeasure designed to reduce the risk of intentional contamination should be developed for each area identified as high risk. Common sense needs to be maintained in designing countermeasures. Economical feasibility also needs to be considered. Constructing a perimeter fence may be too expensive for a small facility to afford. Some countermeasures may not be physically possible. There may be more than one countermeasure that would work for any one area of high risk. Choose the counter measure which is best for a particular situation. Countermeasures may also be phased in over time to ease any economic burden they might impose.

A copy of the Food Defense Plan should be kept in a secure area within the facility and also off-site in case an evacuation should be necessary.

Plans will vary in their level of complexity. Variation can be attributed to size of facility, and also type and number of products produced.

Caf Food Defense PlanWhat if the Food Supply is Intentionally Contaminated?Should such an event occur a timely and efficient response will be critical to minimizing the damage.

37Attacks, or incidents of intentional contamination cannot be prevented 100% of the time. A determined attacker will more than likely overcome preventive measures. Food facilities must be prepared with a planned response. Instructions for response to an incident should be included in the food defense plan.Develop a Written Response PlanPlan for handling of contaminated productEmergency PlanningFacility MapEmergency Contact Phone ListVisitor LogSupplier/Customer ContactsEmployee Emergency Information

38Security of potentially contaminated product:Set up a strategy for food recall should an incident occur. FDA or USDA will need to be notified in case of recall.Product as well as unused ingredients, unused packaging material, storage are, and equipment may need to be secured pending investigation.

Emergency Contact list needs to be kept current and be available 24/7First call local emergency responders, local police, or sheriffState Contact numbers: State office of Homeland SecurityFederal Contact Numbers: FDA Office of Emergency Operations (24 hours) 1-301-443-1240 for food products (except meat and eggs, see below) or animal feedOr FSIS The office of Food Security and Emergency Preparedness (24 hour) 1-800-333-1284 for meat poultry and egg products

Lesions or signs of foreign animal diseases on carcasses should be reported to USDA Animal and Plant Health Inspection Service (APHIS) specifically AEOC (APHIS Emergency Operations Center).AEOC integrates and provides overall monitoring and operations support during an emergency and serves as the Secretary of Agricultures primary point of coordination. The AEOC has been activated and used to support the following APHIS emergency incidents: 1. The detection of Exotic Newcastle disease (END) in the Southwest in 2003; 2. The detection of a bovine spongiform encephalopathy (BSE) infected cow in Washington State in 2003; 3. A small outbreak of highly pathogenic avian influenza in Texas in 2004;

Handling of Contaminated ProductHold any food you suspect may be contaminatedRetained or recalled product will need to be stored prior to disposalStorage will need to be separate from non contaminated productPrepare a plan for disposal, to be reviewed by FDA and state authoritiesFDA will witness the execution of the plan39

Caf Containment and Disposal Plan40Facility MapName, address, and phone of owner/proprietorRelationship of the facility to adjacent properties and/or structures.Road access including transportation routesPerimeter boundaries, include fences, and gates (with dimensions)41To be stored on and off site in case of emergency. The information contained in the facility map will be vital to responders in case of an intentional contamination. It can also be useful in other emergency situations.Facility Map continuedBuildings, outbuildings, doors, windows, AC/heating, ventilation Utilities (water, gas, electric, phones) location and shutoff Septic System and drainage areas with direction of flowWeb sites such as Google Earth www.earth.google.com42

Utility shut offsOwner :Hal Hashslinger1745 Crepe CircleCookstown, MO 65xxxH2OH2OH2OH2OH2OH2OH2OH2O Facility MapH2OH2OH2OExterior doorH2OH2OExterior doorInterior doorInterior doorInterior doorInterior doorExterior doorThis map should be labeled so that in an emergency situation it would be useful to emergency responders who are not familiar with the premises.43

Caf Emergency Phone List

Caf Supplier Contact List

Caf Employee Emergency ContactsReferenceswww.fsis.usda.govwww.cfsan.fda.govwww.bt.cdc.gowww.morerestaurants.org

47Chart111.9319.635.3

Aug 2005June 2007very confidentnot very confident

Sheet1very confidentnot very confidentAug-0511.931Jun-079.635.3To resize chart data range, drag lower right corner of range.

Chart15047.554.347.326.23234.3

Series 1June 2007

Sheet1Series 1Produce50Dairy47.5Meat54.3Seafood47.3Baked26.2Canned32Boxed34.3