food defense at the retail regulatory state and local level
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Combined Effect: Enhancing Food Defense Strategies through Integration of Food Safety Practices at the State and Local Level. Food Defense at the Retail Regulatory State and Local Level. Gary W. Elliott, MA, REHS April 30, 2014. Overview. FIRST. - PowerPoint PPT PresentationTRANSCRIPT
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Combined Effect: Enhancing Food Defense Strategies through Integration of Food Safety Practices at the State and Local LevelFood Defense at the Retail Regulatory State and Local Level
Gary W. Elliott, MA, REHSApril 30, 2014
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OverviewFIRST
Primary Retail Regulatory Focus - Food Safety or DefenseSECOND
FSMA and Proposed Rules
THIRD
AFDO, State and Local Perspectives
FOURTH
Exploring the integration of food safety practices with food defense principles
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PRIMARY FOCUS
ORFOOD SAFETY
FOOD DEFENSE
1
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Primary FocusFood Safety = Preventing Foodborne Illness Related Risks
Regulations or Rules Based On
Prevention of Risk from:
• Unintentional and
• Intentional
Contamination
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Sub-Primary FocusFood Defense = Prevention Focus on
Intentional Contamination Threats
• Terrorism• (International and Domestic Groups)
• Disgruntled Employee, Customers, Competitors
• Economic Sabotage
• Criminals
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DEFINING
ENSESAFETYFOOD
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Food defense has been defined as “a collective term to encompass activities associated with protecting the nation's food supply from deliberate or intentional acts of contamination or tampering. This term encompasses othersimilar verbiage (i.e., bioterrorism, counter-terrorism, etc.) (FDA, 2008).”
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Food Defense Concerns Are RealThreats Are Real
Documents Found in Afghanistan Caves during Operation Anaconda in 2002 (From: Williams, 2005).
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A History Of Threats
A Global Chronology of Incidents of Chemical, Biological, Radioactive and Nuclear Attacks: 1950-2005Hamid Mohtadi and Antu Murshid*July 7 2006
http://cns.miis.edu/cbw/foodchron.htm
http://www.ncfpd.umn.edu/Ncfpd/assets/File/pdf/GlobalChron.pdf
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The impact of a major agricultural/food-related disaster in the U.S. would be enormous and could easily extend beyond the immediate agricultural community to affect other segments of society. It is possible to envision at least three major effects that might result—mass economic destabilization, loss of political support and confidence in government, and social instability. (Chalk, 2001)
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“An enemy bent on victory at any cost could and will make the food supply of a populace a main target” (ShoahEducation.com, 2003).
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Psychological Fears• Probability of intentional contamination of the food
supply is thought by some to be low
• Fact remains that the food/agricultural infrastructure and food supply remain targets of interest for terrorist organizations
• Survey by Stinson, Kinsey, Degeneffe, and Ghosh, (2007) published in the Homeland Security Journal
• High percentage among U.S. respondents polled (4,260 persons) were concerned about the possibility of deliberate contamination of the food supply
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Psychological Fears
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Psychological Fears• Preliminary survey results about perceptions that
Americans have toward homeland security conducted by Stanford University and NPS/CHDS professor Jim Breckenridge (Breckenridge, personal communication, 2008)
• 400 polled individuals
• 23.2 percent of the respondents polled saw contaminated food problems as a matter of great concern.
• The concern about protection of the food supply ranked third on a list of homeland security concerns related to fears of attack by terrorists.
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FSMAand theFDA
PROPOSED RULES
2
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Food Safety Modernization ActFocus On Specific Sections
Sec. 108. National agriculture and food defense strategy.
Sec. 110. Building domestic capacity.
Section 205(c)2 of the Food Safety Modernization Act (FSMA) requires a review of state and local capacities in order to enhance the development primarily of strategies required under 205(c)1, but also sections 108, 110, 209 and 210.
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Food Safety Modernization ActFocus On Specific Sections
Sec. 209. Improving the training of State, local, territorial, and tribal food safety officials.
Sec. 210. Enhancing food safety.
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Food Safety Modernization ActFocus On Specific Rules
Food Defense Plan
• Each facility covered by this rule would be required to prepare and implement a written food defense plan, which would include:
Proposed Rule: Focused Mitigation Strategies to Protect Food Against Intentional Adulteration
Docket Number: FDA-2013-N-1425December 2013
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• Actionable process steps
• Focused mitigation strategies
• Monitoring
Focus On Specific Section Of Rule
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• Corrective actions
• Verification
• Training
• Recordkeeping
Focus On Specific Section Of Rule
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AFDOSTATE
AND LOCAL
PERSPECTIVESREGULATORY
3
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Perspectives
• How does the new rule on intentional adulteration apply to the retail regulator and retail industry
• Importance of integrating food defense within the broader IFSS concept
• State food regulatory programs are important partners for FDA and industry
• Importance of an effective implementation strategy with clear roles and responsibilities for agencies, industry, academic institutions, and other entities
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Perspectives
• Lots of loose ends aren’t addressed in the rule – FDA needs to work closely with stakeholders to fill in these gaps in practical ways
• Importance of education and outreach – for the larger firms falling directly under the rule and for others that may be indirectly impacted by market forces
• Alliances have been successfully used to meet the educational, training, and technical assistance needs in the past
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Perspectives
• Importance of education and outreach – for the retail food industry that may indirectly impacted by market forces
• How can the FDA work with state and local agencies on a variety of FSMA issues including food defense from a realistic grass roots retail perspective
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The Retail industry, unlike the manufactured food industry, while supportive of the concept of food defense generated after September 11, may still have:• Difficulty embracing a separation
between food safety and food defense especially with multiple agencies
• Industry stakeholders may believe that without information suggesting an increased level of intentional threat that current safety precautions are sufficient to protect the food products that they produce
Perspectives
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EXPLORE
INTEGRATIONOF FOOD SAFETY
4
AND FOOD DEFENSE
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Explore Innovative Strategies
With reduced resources and limited budgets, which receives a higher focus?• Food Safety or Food Defense??
Priorities!!
• Create Value Propositions and Value Innovations
• Between Food Defense Principles and Food Safety Smart Practices at the Retail Level
Is there a proactive way to still have both at the same time?
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Integrate Innovative Strategies • Look for common threads between food
safety and food defense
• Use common sense value innovations and avoid complication
• Be Proactive about Active Managerial Control linked to Situational Awareness
• Educational and training inspections from a Food Defense and not a Food Safety viewpoint
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Innovation Sense-Making Tools
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TOPI
CSU
MMARYFOCUS – FOOD SAFETY AND DEFENSE
FSMA AND PROPOSED RULES
AFDO, STATE AND LOCAL PERSPECTIVES
EXPLORE/INTEGRATE/SMART PRACTICES
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Final Added Overall Thoughts
• A focused and combined regulatory approach to food safety/defense efforts can be established for the sector, retail and manufactured
• Continue to establish a more focused mechanism for research of food and agricultural pathogens, including emerging pathogens
• Better education at all levels of the farm-to-table continuum on food safety/defense involving all stakeholders
Needs and Beliefs:
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• The fusion of intelligence information pertinent to the food and agricultural sector, would provide a clearer perspective of existing and emergent problems and provide a path to strengthen outcome solutions.
• Explore a workable solution or policy for information sharing between the regulatory system, DHS, the intelligence community, and ultimately, the state and local regulatory systems to analyze probabilities of attack and prevent terrorist threats against the sector.
Needs and Beliefs:
Final Added Overall Thoughts
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Chris Bellavita (2005) wrote in Homeland Security: The Issue-Attention Cycle, “In the absence of an active national consensus that terrorists are a clear and present threat to the lives of average Americans, the dynamics of the Issue-Attention Cycle are as inevitable as the seasons.”Anthony Downs argued that certain
issues follow a predictable five stage process: pre-problem, alarmed discovery, awareness of the cost of making significant progress, gradual decline of intense public interest, and the post problem stage.
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In The Cycle of Preparedness: Establishing a Framework to Prepare forTerrorist Threats, (2005), Willam Pelfrey used the word “cycle… as a proxy for a dynamic, flexible, and continuous process of interaction and integration, and functioning as a self-organizing mechanism that improves preparedness for anticipated events and for the unimagined events.”
He goes on to say that a “…‘cycle’ implies a repetitiveness, in sum as well as in parts, that is consistent with ‘preparedness.’
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Preparedness cannot be proclaimed or finished; it is an ongoing process with constituent parts or phases working in, or being available to work in concert.” Pelfrey also acknowledges the great importance of “prevention” in preparedness, along with awareness, response and recovery as part of the four phases of the cycle.
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Questions/Comments/Thoughts/Ideas
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http://handle.dtic.mil/100.2/ADA514142
NAVALPOSTGRADUATE
SCHOOLMONTEREY, CALIFORNIA
WHO’S ON FIRST: UNRAVELING THE COMPLEXITY
OF THE UNITED STATES’ FOOD AND AGRICULTURAL
REGULATORY SYSTEM IN THE REALM OFHOMELAND SECURITY
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Gary W. Elliott, MA, REHS
AFDO Food Protection and Food Defense CommitteeCo-Chairman
[email protected](803)804-0564
South CarolinaDepartment of Health and
Environmental Control (DHEC)[email protected]
(803) 896-0733
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