Bioterrorism Threats Fuel Food Defense at the Federal Level

The areas of an establishment listed below, at minimum, are the sections of the establishment that are to be observed and documented by inspection personnel during a declared color elevated threat. Each of the headings contains sub-categories for plant inspectors to follow including instructions of communication and suggested activities:

• O8S14 – Water System
• O8S15 – Processing/Manufacturing
• O8S16 – Storage Areas
• O8S17 – Shipping & Receiving

In addition, the directive instructs the establishment IIC to notify the USDA district office in the event there is a direct attack on the establishment or surrounding areas. The district office then notifies appropriate local authorities which may include the FSIS Management Committee through the Office of Field Operations under OFDER.

Section IX of the directive spells out the purpose of an Emergency Food Defense Verification, noting that “procedures are to identify and mitigate to the maximum extent possible potential vulnerabilities in the security of an establishment that could lead to deliberate contamination. Examples of potential vulnerabilities include uncontrolled access to a restricted ingredient area: unrestricted access to a processing room; or unrestricted access to water systems.”

Section VIII indicates that “establishments should develop a functional food defense plan to set out control measures to prevent intentional adulteration of product. Although not required, FSIS encourages establishments to have a food defense plan.”

The directive also states that “an establishment is not obligated to provide a copy of its written plan to inspection personnel. If an establishment does provide a copy, inspection program personnel may use the plan when performing the food defense verification activities.”

“Do not make copies of the written plan. Inspection program personnel are not to show or share the plan with any outside source because it may contain sensitive security information.” the directive concludes.

Contrary to the FSIS present requirements concerning mandatory food defense programs, there is another regulatory appendage of the USDA that does require a written and verifiable program; the Livestock and Seed Program, (LS Program). The Commodity Procurement Branch of the LS Program purchases and supplies raw meat and cooked items including pork and fish for underprivileged children, disadvantaged families, charitable institutions, the elderly, the homeless and schools nationwide.

Pre-approved USDA inspected establishments that participate in the LS Program are audited once a month by another federal agency, the Audit, Review, and Compliance Branch (ARC) of the USDA’s Agricultural Marketing Service (AMS). These audits include not only ISO based food safety standards but also mandatory food defense requirements. The food defense audit also involves, if applicable, offsite storage of packaging materials that would be used in the program as well as independent freezers for the storage of commodities. Thus, the commodity supplier is responsible for not only the security at their processing plant(s) but also their dry packaging vendor, offsite temporary storage facilities, freezer storage and the security of the said products while in transit.

In June 2005, a Checklist/Report for Food Security Plans was issued by the AMS for their auditors to utilize during their monthly inspections. The categories below are similar to the FSIS/USDA April 2005 version reviewed earlier:

• Food Security Plan Management
• Outside & Inside Security
• Slaughter & Processing Security
• Shipping & Receiving Security
• Storage Security
• Water & Ice Supply Security
• Mail Handling Security
• Personnel Security
• Controlled Access to Production and Storage Areas.

If any of the above areas are found to be seriously deficient by an auditor, it could result with the supplier being issued a critical non-compliance notice and suspended from continued participation in the LS Program until approved rectifications are made and approved by the AMS.

Dissimilar to the FSIS inspectors who have received only food defense training, AMS auditors have extensive criminal background checks and other security clearances by federal agencies, including food defense training prior to performing their food defense audits associated with the LS Program.