Food Defense and Protection

Much of the focus on food safety has been on preventing unintentional or accidental contamination of products and ingredients by bacteria and other naturally occurring pathogens and agents. But specialists in government, industry, and academia are quietly exploring ways to protect the nation’s food supply against intentional contamination and adulteration from sabotage, terrorism, economic fraud, and other illegal actions.

In some ways, their task is made harder because intentional contamination can occur when insiders—company officials, disgruntled employees, or terrorists who have infiltrated the workforce—perpetrate their crimes as they go about everyday activities. “It’s very difficult to prevent an employee at a company manufacturing high-risk foods from engaging in terrorism because they have access to the facility and adding ingredients may be part of their job,” says David Acheson, director of the food and import safety practice at Leavitt Partners and a former FDA associate commissioner of foods.

The spectrum of intentional food contamination ranges from extremist groups (terrorism), to disgruntled employees (sabotage), to company officials engaged in economically motivated adulteration (counterfeiting and fraud). Examples of the latter include unapproved enhancements, such as the addition of melamine to milk to increase its apparent protein value; mislabeling, such as selling sunflower oil as olive oil; and substitution, such as using beet sugar in place of honey. A 2010 study by A.T. Kearney for the Grocery Manufacturers Association placed worldwide losses from economic adulteration and counterfeiting of food and consumer goods at $10 to $15 billion annually. One adulteration incident alone can slash a food company’s annual revenue by 2 to 15 percent, the report said.

Devastating Food Terrorism

While counterfeiting and food fraud extract their economic and health tolls on consumers, an act of widespread food terrorism could be even more devastating and weaken confidence in the nation’s overall food system. While FDA has had a long interest in food defense, the September 11, 2001 terrorist attacks “seriously ramped it up,” Acheson says. “Food defense moved from being a slow-paced, low-priority project to a high-paced, high-priority one after 9-11,” he says. During those years, the FDA explored ways to help companies understand the importance of identifying and eliminating vulnerabilities in their products and processes. But because a terrorist attack on the nation’s food supply did not materialize, interest in food defense again began to wane—at least until recently.

Things changed with the enactment of the Food Safety Modernization Act (FSMA) in 2011. Section 106 of FSMA requires the FDA to conduct a vulnerability assessment of the nation’s food system, determine the types of science-based mitigation strategies or measures to protect against intentional adulteration of high-risk food, and, in coordination with the Departments of Agriculture and Homeland Security, publish regulations and guidance to implement those strategies and measures.

“FDA will be requiring companies to pay attention to food defense and will be writing rules and regulations around that,” Acheson tells Food Quality & Safety magazine. As with most other regulations required under FSMA, the FDA has not issued those food defense rules on schedule. In fact, they are not expected until after regulations on import safety and the foreign supplier verification program, preventive controls for animal food, and third-party audit certification are published this year. This means the food defense rules may not be issued until 2014.

Assessing Vulnerability

But the FDA has not been neglecting food defense either. In April, the agency met one of the FSMA’s requirements by issuing a report assessing the vulnerability of the nation’s food system. The analysis is based on vulnerability assessments conducted jointly with USDA, FBI, and the Department of Homeland Security of more than 50 food and agriculture products and processes during 2005 to 2008. The goal was to identify processing steps of highest concern, potential mitigation strategies to reduce these vulnerabilities, and gaps in research. A key concern was to do all this without disclosing sensitive information such as vulnerabilities in specific facilities, commodities, or processes.