The U.S. Dept. of Homeland Security (DHS), the U.S. Dept. of Agriculture (USDA), and the Food and Drug Administration (FDA) are sufficiently concerned about potential terrorist threats to agriculture and food processing that they have devoted significant portions of their recent budgets to various aspects of the issue. It is well-known that inadvertent contamination of food already causes significant numbers of cases of disease and death each year. What if someone maliciously sabotages our food? What can be done to prevent this?
Ann Draughon, Professor and Co-director, Food Safety Center of Excellence at the University of Tennessee, Knoxville (phone 865-974-7425), has documented known instances of agro-terrorism and helped develop good practices for food plant security. Several instances of known sabotage involving food have been instigated by disgruntled employees, according to Draughon. These are especially insidious because the employees know the plant and processes and are not usually considered suspicious.
Employees are one of the first lines of defense against contamination of foods, whether deliberate or accidental. They know that their jobs may be at stake if something goes wrong. Knowing who belongs where and challenging those out of place is fundamental to good security practices.
Plants are training their employees to look for identification badges and to challenge those without them, including visitors without escorts. Different-colored uniforms are issued for those working in different areas so people who are out of place are obvious.
Plant-issued uniforms usually do not have pockets, primarily so that objects do not fall out and into food, but the same practice makes carrying and delivering a contaminant more difficult. Tools such as temperature indicators, stop watches, and samplers are typically carried in holsters hung from belts.
In general, employees are trained to know who and what is normal and to be proactive and confident in reporting deviations.
A perimeter fence with strictly controlled entry can be a significant line of defense. Personal vehicles, trucks, and pedestrian access should be limited and guarded. Many plants now have personal vehicle parking at a distance from the plant.
Trucks should be sealed at the point of loading, and seals must match bills of lading to ensure that ingredients and supplies have not been tampered with en route. Out-going products are likewise sealed after loading.
Remotely operated cameras on the periphery and in internal passages are another useful tool, according to Draughon. Cameras not only discourage malicious acts but also assist criminal investigators in identifying likely suspects after the act. Access through closed doors should be by passcodes rather than magnetic badges, because badges are easy to steal. ID tags are useful and recommended but are notoriously easy to fake.
Visitors should be escorted, and truck drivers should be restricted to a lounge area with their own rest rooms.
Ingredients should be obtained from trusted suppliers who have an effective security plan, and chain of custody of ingredients should be routinely documented. If letters of guarantee are not provided, ingredients should be held until their suitability is confirmed. Testing is typically for identity and conformance to specifications. Many agents of interest for food defense are difficult to detect, so improvement of rapid testing is a major area of research.
During processing, food should not be exposed to the environment unless necessary. This may require adding covers to conveyors and putting lids on totes.
The National Center for Food Protection and Defense (NCFPD), funded by DHS, is conducting research in several areas concerning food safety and security. According to NCFPD Director Frank Busta, Past President of IFT and Professor Emeritus of Food Science at the University of Minnesota, St. Paul (phone 612-624- 2164), one area is impact of ordinary food preservation processes on biological contaminants other than those usually targeted. These biological agents include common foodborne organisms, such as virulent Escherichia coli, but also potential biological weapons such as Bacillus anthracis (anthrax) spores and Botulinum toxin.
The behavior of some agents of interest is known from government agency research but is classified, and so may be redetermined by academic researchers. It is suspected that certain select agents can survive the normal pasteurization process for milk, so the dairy industry has been advised to increase its thermal treatment of fluid milk. One result is that some processors observe a perceived reduction in quality, while others note beneficial shelf life impacts. Others have found that incremental changes in processes are more consumer-acceptable than sudden changes.
Researchers at NCFPD have developed a model of disease spread and agency response for various scenarios of deliberate contamination. One example Busta uses is intentionally contaminated ice cream mix that is shipped around the country from the Midwest. Because of the wide dispersion of the product, it takes days before consumers begin to feel ill enough to seek a doctor or emergency room. Cases are scattered, so suspicion does not immediately fall on the contaminated product. By the time government agencies realize there has been an incident, a large portion of the product is out of distribution centers and in the hands of consumers. The only remedy is to alert medical personnel and recommend treatment.
Cleaning up a plant contaminated by various agents may be a challenge. As seen in the anthrax episodes of 2001, ordinary cleaning is not sufficient. Chlorine dioxide is evidently effective against spores, as is irradiation. But irradiation is impractical for equipment and facilities, and some current food plants and processes are not usually designed for easy fumigation. Chlorine dioxide, for example, is highly corrosive and can damage electrical equipment. New plants and equipment should be designed with some consideration for how they would be decontaminated if necessary.
Disposing of large quantities of contaminated food or agricultural material is also a concern. Burying food with viable microorganisms may not prevent subsequent contamination of the water supply. Incineration could cause air pollution. During a simulation of response to an outbreak of foot-and-mouth disease, which is not a threat to humans but spreads rapidly among herds, one response suggested was to destroy about 50 million cattle—at which point, someone asked where to get 50 million bullets! The point of that exercise was to challenge the assumed reaction to such a threat, recognizing that the instinctive response might do more harm than good. In the case of foot-and-mouth disease, which has not occurred in the United States, eradication could be economically devastating. One suggestion is to learn to live with it, as South American countries have done.
The broader point is that our planned response to potential incidents may need some creative thinking.
A major concern of researchers thinking about various possible threats is the loss of confidence in our otherwise enviously safe food system. Thus, remediation refers not only to treating sick people, recovering contaminated products, and sanitizing contaminated plants, but also to restoring trust. As seen in some accidental events, the economic impact may be even greater than the health impact.
NCFPD and its partner institutions recognize that research to prevent and recover from deliberate food contamination will benefit food processors even if the feared event never occurs. The same policies necessary to ensure that ingredients are not contaminated will also ensure that they are safe and correct. The same policies and training that have employees watching for strangers also help prevent cross-contamination by careless workers wandering around. Closing up equipment to prevent easy access to food in process also prevents contamination from dripping condensate and dust.
Understanding thermal and nonthermal preservation processes, and making them more severe in some cases, should extend shelf life while providing another line of defense against deliberate contamination. Of course, preservation processes directed at biological agents may have no effect against chemical contaminants, such as pesticides and other poisons. Fortunately, it takes significant quantities of such chemicals to cause widespread harm, so precautions against unauthorized access and other measures offer protection. For example, pesticides and cleaning chemicals needed in a plant should be stored in locked rooms or closets with restricted access. Quantities should be limited, and users should be trained and carefully supervised.
Measures taken to confirm employee identity and suitability, such as background checks and eligibility for work, should be current policy anyway and help to avoid difficulties with government agencies, especially regarding undocumented workers. With rapid turnover among workers in many food plants, there is concern about infiltration by terrorists. Measures taken to reduce turnover may provide the dividend of improving security as well.
Food plants are required by the Bioterrorism Act of 2002 to register with the federal government and to comply with notification procedures for imported foods and ingredients. The normal concerns about food safety are reason enough to apply the practices and policies that also help to protect against deliberate acts of sabotage.
by J. Peter Clark,
Consultant to the Process Industries, Oak Park, Ill.