The need for food defense

in the post-9/11 era

Can the risk be ignored?
Many people are familiar with “food safety.” It has been
recognized for many years as being essential for businesses
that supply food products anywhere in the supply chain.
The term “food defense,” however, is another issue.
Shortly after the tragic events of September 11, 2001,
the U.S. government became concerned that terrorist
organizations might seek to contaminate parts of the
American food supply. In December 2001, the Food
and Drug Administration (FDA) and the United States
Department of Agriculture (USDA) began a dialogue with
a number of security professionals in the food industry
to determine the current state of readiness against an
intentional attack. The information gathered was not
encouraging. Prior to 2001, security departments in the
food industry were mostly concerned with protecting
people and assets. Protecting products was considered
to be mostly the responsibility of a food safety or quality
assurance department. Certainly, many of the physical
security measures put in place, such as access control,
closed-circuit television, locks, and alarms could be
helpful in securing the products. But for some companies,
protecting the product from intentional contamination
was not a priority of the security department, if such a
department even existed in the company.
As awareness increased throughout the U.S. industry, the
role of protection against intentional contamination, or
“agroterrorism,” was called “food security,” but that term
was already in use by the World Health Organization to
describe a country’s ability to sustain its food supply. In
2003, government agencies such as the FDA, USDA, and
the Department of Homeland Security began using the
term “food defense” to describe the efforts to protect
food products from deliberate or intentional acts of
contamination or tampering. By 2010, both the FDA and
USDA had begun using the same “working definitions” of
food safety and food defense in their presentations.
Food safety may be defined as: the protection of food
products from unintentional contamination by an agent
reasonably likely to occur in the food supply (e.g., E.
coli,Salmonella, Listeria).
Food defense may be defined as: the protection of food
from intentional contamination by biological, chemical,
physical, or radiological agents that are not reasonably
2
likely to occur in the food supply.
The key words are obviously “unintentional” for food
safety and “intentional” for food defense. The food
industry has the personnel and infrastructure in place for
food safety, but many in the industry are struggling with
how to approach food defense.
Long before 2001, there was documentation of intentional
food contamination incidents throughout the world. A
study by the Centre of Excellence for National Security
(CENS) in Singapore, written by G.R. Dalzeil, reported that
between 1950 and 2008, there were approximately 398
confirmed incidents of contamination and approximately
125 unconfirmed incidents. The information for this study
was gathered worldwide; however, 42 percent of the
incidents occurred in the U.S.; the U.S., UK, and Australia
combined accounted for 60 percent of the incidents.
One recent example of intentional contamination of the
food supply occurred in July 2012, when needles were
found in sandwiches served on a U.S.-based international
airline on four separate flights. These incidents, and others
like it, underline the risks that a food defense-related
incident may pose to a company. The reputation of the
brand and the company may be at risk, which could then
become an enterprise risk, should their customers and
the general public lose faith in their ability to protect their
products. A company may could face heavy scrutiny from
the press, public, and regulators, and market capitalization
may also be affected.
What are the regulatory requirements related to
food defense?
Until late 2010, neither the USDA nor the FDA had direct
regulatory authority over preventive measures for food
defense. Several efforts were undertaken to provide
guidance and requirements and to manage and encourage
their adoption. The Food Safety Modernization Act (FSMA)
of 2010 is the first regulatory law to use the term “food
defense” and to provide the FDA with that direct regulatory
authority. The regulations to explain and support the FSMA
as it relates to food defense have not yet been forthcoming
from the FDA. The current efforts by both agencies related
to food defense can be found on the FDA and USDA food
defense websites. The USDA Food Safety Inspection Service
has developed a voluntary food defense program for the
food companies they regulate, providing a general food
defense plan template on its website. The FDA has training
tools for managers and line workers to assist the industry
with evaluating specific vulnerabilities.
Food defense is an issue the industry should take seriously.
The risk of an internal contamination event to a company’s
product could very well present an enterprise risk, which
may threaten not only the consumer, but also the company
itself. Even though the regulations for food defense under
the FSMA have not yet been proposed, there are a number
of basic security tools and programs that should be put
in place and may provide an increased level of protection
against intentional contamination incidents. An evaluation
of an organization’s food defense preparedness may
serve to highlight the vulnerabilities in physical, human,
process and/or product protection, and also identify good
mitigation strategies.

How can you mitigate your risk?

Food defense planning cannot be generic or one size fits all;
each facility that grows, manufactures, processes, stores, or
distributes food products may present its own security and
food defense challenges. However, there are some basics to
consider in a facility:
1. Maintain control of the facility. Entrances should be
secured against unauthorized and undetected intrusion.
2. Establish a system of vetting people who work in a
facility, or are permitted in a facility unescorted and are
considered trustworthy.
3. Identify the vulnerabilities to the products and processes
that exist in the facility, how much risk they pose, and
what the applicable mitigation strategies might be to
lower or abate those risks.
4. Identify the vulnerabilities in your supplier base, evaluate
how much risk they pose, and what are the applicable
mitigation strategies to lower or abate those risks.
5. Develop policies, procedures, and training to support
the food defense program, which may likely include a
method for investigating, reporting, and mitigating the
causes of a security breach.

The case for change 3

References
G.R. Dalzeil, “1950-2008: A Chronology and Analysis of Incidents Involving the Malicious Contamination
of the Food Supply Chain,” CENS, Singapore, 2009.
http://www.rsis.edu.sg/cens/publications/reports/RSIS_Food%20Defence_170209.pdf
Richard Esposito and Mark Schone, “Needles Found in Sandwiches on Four Delta Flights,” ABC World News, July 2012.
http://abcnews.go.com/Blotter/needles-found-sandwiches-delta-flights/story?id=16790585
“Melamine Pet Food Recall,” U.S. Food and Drug Administration, 2009. (In 2007, the FDA found contaminants in vegetable proteins imported into the
United States from China and used as ingredients in pet food.)
http://www.fda.gov/AnimalVeterinary/SafetyHealth/RecallsWithdrawals/ucm129932.htm
“The New Food Safety Modernization Act,” U.S. Food and Drug Administration.
http://www.fda.gov/Food/FoodSafety/FSMA/default.htm
“Public Meeting on Economically Motivated Adulteration,” U.S. Food and Drug Administration, May 1, 2009.
http://www.fda.gov/NewsEvents/MeetingsConferencesWorkshops/ucm163619.htm
“Better Coordination Could Enhance Efforts to Address Economic Adulteration and Protect the Public Health,” United States Government Accountability
Office, GAO-12-46, October 2011.
http://www.gao.gov/assets/590/585861.pdf
“Food Defense & Emergency Response,” U.S. Food and Drug Administration. (List of tools and resources.)
http://www.fda.gov/Food/FoodDefense/default.htm
Tools & Resources
http://www.fda.gov/Food/FoodDefense/ToolsResources/default.htm
FDA-Food Defense and Acronym List- 2007
http://www.fda.gov/Food/FoodDefense/EducationOutreach/ucm296330.htm

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