FDA on High Alert for Food-Related Bioterrorism

Countermeasures can range from merely a government agency providing guidance to industry to enhanced testing or working with industry to apply a seal to protect a node from a dangerous agent.

“It’s the responsibility of FSIS to perform vulnerability assessments and develop countermeasures as dictated by HSPD-9,” Maczka cites.

What does it cost industry to allow the FSIS to perform these vulnerability assessments and develop countermeasures? Nothing, besides the time it takes to navigate through the assessment and become educated. FSIS is required to perform vulnerability assessments for at-risk food producers twice per year, but the agency encourages industry to use the tools it learns from the FSIS to perform vulnerability assessments more often. Read the Strategic Partnership Program on Agroterrorism (SPPA) First Year Status Report (www.usda.gov/homelandsecurity/8-1006%201%20yr%20report%20SPPA%20agroter5.pdf) to see how your vulnerability assessments and countermeasures stack up against others in the industry.

Shipping and Customs

So now you’ve examined your internal production systems down to every last node. Don’t forget to ensure the security of your product after it leaves your facilities.

Customs Trade Partnership Against Terrorism (C-TPAT) is a voluntary government-business initiative that has been put in place to build cooperative relationships that strengthen and improve overall international supply chain and U.S. border security. C-TPAT recognizes that U.S. Customs and Border Protection (CBP) can provide the highest level of cargo security only through close cooperation with the ultimate owners of the international supply chain such as importers, carriers, consolidators, licensed customs brokers and manufacturers. Through this initiative, CBP is asking businesses to ensure the integrity of their security practices and communicate and verify the security guidelines of their business partners within the supply chain.

Private firms, like Chicago-based Riggle & Craven International Trade & Customs Law, help industry certify their imports under C-TPAT, which helps food shipments, get through customs with fewer requirements. “If or as soon as we have a terrorist attack on these shipments, those in industry who are not members of C-TPAT may see impediments to their shipments,” says David A. Riggle, managing partner

In performing a C-TPAT certification, all of the different possibilities where a shipment could have a problem are analyzed. Terrorists may find an opening to attack your shipment after your food shipment is loaded and sealed.

“You often think of security for your manufacturing plant and for once your shipment reaches the U.S., if you are shipping from outside the U.S., but during the transportation is when there is also potential for attack,” according to Riggle. Many foreign ports are already online with the C-TPAT guidelines.

Riggle says that unsealed, fresh food is most vulnerable at this stage, since it is most easily contaminated. To make sure that your fresh food is not contaminated, you should choose a foreign exporter with a tight chain of security through all of their transportation networks.

“Price is always a concern for companies, but sometimes you don’t want to go with the cheapest partnership option. You want a foreign exporter with the best security procedures,” he continues. “It’s a fact of our modern world that food producers need security for their shipments.”

Get Registered

The U.S. government requires all food producers in the U.S. and food producers that aim to distribute in the U.S. to register with the FDA (see /www.cfsan.fda.gov/~furls/ovffreg. html). If you are not sure your company is registered, check immediately. This is the best way for you to take the first step toward protecting your production system and products and allow the government to help you protect them. You also need to have a 24-hour telephone number to register with the FDA, so that the agency can get in touch with you regarding products you’ve put into the food supply. If you ship goods either to or from the U.S., register with C-TPAT. www.cbp.gov/xp/cgov/import/commercial_enforcement/ctpat/.