By: Jim Armstrong, MS, RS, Program Manager, Environmental Public Health Services, Cuyahoga County Board of Health
Importance of Food Defense
In 2004, Tommy Thompson, former director of the Department of Health and Human Services, famously said, “I, for the life of me, cannot understand why the terrorists have not attacked our food supply, because it is so easy to do.” According to the U.S Department of Homeland Security (DHS), the food and agriculture sector is composed of an estimated 2.1 million farms, 935,000 restaurants, and more than 200,000 registered food manufacturing, processing, and storage facilities. As pillars of our society, food and agriculture accounts for about 20% of the nation’s economic activity. Also concerning is that DHS named the food and agriculture sector one of 16 national critical infrastructures vulnerable to attack.
Given this backdrop, the U.S. Food and Drug Administration (FDA) issued the “Food Safety and Modernization Act (FSMA) Final Rule for Mitigation Strategies to Protect Food Against Intentional Adulteration” in 2016. According to the FDA, this final rule is “aimed at preventing intentional adulteration from acts intended to cause wide-scale harm to public health, including acts of terrorism targeting the food supply. Such acts, while not likely to occur, could cause illness, death, and economic disruption of the food supply, absent mitigation strategies.”
Under this rule, each foreign and domestic food company required to register with the FDA as food facilities under the Federal Food, Drug, and Cosmetic (FD&C) Act must identify its vulnerabilities to intentional adulteration, and write a food defense plan designed around mitigation strategies to reduce the likelihood of an attack.
Terrorists may not distinguish between maliciously attacking large food companies that have implemented food defense strategies, and retail food businesses, which are among the softest of targets, with little to no security measures. Therefore, local health departments should begin having discussions with retail food businesses to assess intentional adulteration vulnerabilities, and implementing simple, low-cost food defense mitigation strategies.
The Cuyahoga County Board of Health develops food defense with its licensed retailers and the FDA
Like other local health departments, the Cuyahoga County Board of Health (CCBH), located in northeast Ohio, has traditionally worked with retail food businesses to ensure that food is protected from unintentional contamination, including poor personal hygiene or improper holding temperatures. In the past several years, CCBH has also partnered with its food retailers and the FDA to establish retail food defense in order to prevent intentional contamination of the local food supply.
Intentional contamination, also known as intentional adulteration, first became a critical issue for CCBH in 2011 after receiving reports of local imposter ‘sanitarians’ entering restricted areas of local food businesses. Although no evidence of intentional adulteration was uncovered following these reports, food defense became a primary issue for CCBH. This was followed by food terrorism preparedness planning prior to the 2016 Republican National Convention (RNC), which took place in Cuyahoga County.
CCBH worked with the FDA as well as stakeholders from local restaurants, grocery stores, and institutions to practically address intentional adulteration. Supported by two FDA food defense grants from 2012 to the present, CCBH has conducted a series of covert field vulnerability assessments within local retail food operations to identify intentional adulteration vulnerabilities. Four basic food defense areas of concern were found: restricted area intrusion, identity verification measures, escorting within restricted areas, and retail staff vigilance.
Foods and chemicals are typically unpackaged, and most exposed to contamination in bulk quantities within restricted, or employee-only areas of food businesses. Consequently, intentional adulteration within these areas may be more attractive to would-be contaminators. Restricted area security measures create the first line of defense that protects restricted areas against intrusion by such individuals.
During CCBH’s initial field assessments, and with the cooperation of local police, “covert” CCBH sanitarians that were unfamiliar and un-badged to retailers conducted intrusion tests, attempting to enter restricted areas of 78 retail food businesses through interior and exterior doors. Doors leading to restricted areas were found to be propped open, left unlocked to the exterior, or unattended at many food businesses, allowing easy intrusion.
After these results were presented to local retailers and security experts, it was determined that simple security measures that direct workers to not leave restricted area doors unsecured were obviously needed. Prior to the RNC, these measures were established through targeted food defense training of retail staff, and reinforced through restricted entry security signage. The installation of self-closing and locking doors was also supported by stakeholders. Follow-up covert intrusion assessments by CCBH focusing on grocery stores determined that the vast majority of restricted area doors were secured.
In order to further protect food from intentional contamination, it is important to ensure that only authorized persons are within restricted areas of food businesses. This is where identity verification and escorting measures – both strong deterrents to intentional contamination – can truly help.
During initial field assessments, covert CCBH sanitarians found that most retail food employees they encountered did not ask for ID or escort assessors, which allowed unfettered access within restricted areas.
In response, CCBH offered targeted training and food defense policy templates to help empower retail employees to implement ID verification and escorting measures for restricted areas. Food defense placards were also distributed by CCBH to reinforce these behaviors within facilities prior to the RNC.
Follow-up field assessments conducted by different covert CCBH sanitarians focusing on grocery stores determined that ID requirements in restricted areas rose by an astonishing 320%. Moreover, these unfamiliar “intruder” sanitarians were also escorted by store staff for 25% longer than during initial assessments.
In addition to the food defense activities leading to the 2016 Republican National Convention, CCBH has provided food defense presentations and toolkits for its partners at local, state and national (including NACCHO) conferences. Food defense has also been added to CCBH’s routine food safety trainings within its jurisdiction. In the future, CCBH will continue to evaluate food defense during mandated food safety inspections. To learn more about what CCBH is doing, check out this Q&A.
- CCBH Food Defense Materials: http://www.ccbh.net/posters-fact-sheets-signs/.
- FDA Food Defense Mitigations Strategies Database: https://www.fda.gov/Food/FoodDefense/ToolsEducationalMaterials/ucm295898.htm
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