Food defense is a broad term that seeks to tackle risks to the food system from food terrorism. As food systems in the US and globally continue to increase in scale and complexity, the need for comprehensive programs that address risks to food systems has also increased. Protecting the food supply is a matter of public health and national stability, but there is often some confusion about what food defense encompasses and how best to tackle it within some parts of the industry.
After 9/11, both the United States and the World Health Organization (WHO) began to examine food infrastructure through the lens of national security. Many in the federal government directly addressed the concern that a terrorist organization could, in some cases, very easily disrupt critical points of the supply chain or could cause illness or death in large or vulnerable segments of the population.
Throughout the early 2000s, the US government brought in experts from the government and from the private sector to assess the current state of food security and develop plans designed to build or reinforce food defense mechanisms. During the last ten years, the FDA has implemented the Food Safety Modernization Act (FSMA), and food defense is a significant component of this series of laws. Seven major rules comprise FSMA, and these rules acknowledge that many entities share responsibility for ensuring food safety.
What Is the Meaning of Food Defense?
There are a number of actions and definitions that comprise the entirety of food defense. Food safety and food defense are not interchangeable terms; the FDA broadly defines food defense as the effort to safeguard the food supply from intentional harm and adulteration. Every aspect of food, from the crops in the fields to how facilities process food and the supply chains that move food in various stages around the country or the globe, is included in the food defense purview. Intentional adulteration could be behaviorally or ideologically motivated, and the National Center for Food Protection and Defense identifies three types of risk:
- Industrial sabotage
- Economically-motivated adulteration
What Is an Example of Food Defense?
In 1996, a love triangle led to a multi-million dollar recall of contaminated dairy and animal products. Disposal of the contaminated products alone cost over $4 million. The total economic impact added over $250 million as the targeted feed producer destroyed hundreds of thousands of pounds of product. Nearby farms and facilities also suffered from the intentional contamination. Apparently, a competitor of the targeted facility was accused of contaminating the products. As the story goes, there was a romantic relationship between the competitor’s wife and someone at the targeted facility. This was considered an act of domestic terrorism by the Wisconsin secretary of agriculture.
When something threatens the food supply, it is common for people to direct anger and displeasure toward manufacturers and the government immediately. People want to assume that their food is safe every time they access it from a store or manufacturer. One problem is that it can often take a significant amount of time to determine the origin of the threat of contamination. A food defense plan is an excellent example of how a manufacturer, transporter, or food-handling facility can take a proactive approach to safeguard against intentional adulteration.
How Does Food Defense Differ from Food Security?
In 1981, a food scandal of horrific magnitude rocked Spain. Over 350 people died, and more than 10,000 were hospitalized. At least 20,000 people suffered some sort of clinical disease ranging from respiratory problems to deformities, and for many, the illnesses resulted in permanent injury. Testing revealed that the olive oil was heavily adulterated with industrial-grade rapeseed oil. However, a judge ruled in 1989 that most of the defendants who distributed the oil did not intentionally harm consumers. The ruling caused a widespread uproar, and survivor organizations continue to protest the ruling to this day. Many experts consider the most extensive occurrence of food poisoning in Europe in modern history to have been economically-motivated adulteration or food fraud. Was this an example of a food security issue or food defense?
The FDA focuses on the intent when discussing food defense versus food security. Like food defense, food safety is an umbrella term that includes all the ways of addressing unintentional adulteration of a food supply. The goal of food safety measures is to safeguard against any contaminants that are reasonably likely to happen. The Hazard Analysis Critical Control Point (HACCP) approach helps many facilities ensure food safety.
Food defense concerns efforts to harm the food supply intentionally, motivated by some desired outcome, and there are specific food defense strategies separate from HACCP. There are many things that could motivate an individual or organization to intentionally harm a food supply, including:
- Causing widespread illness or even death
- Creating consumer fear
- Driving consumer loss of confidence in the food system
- Producing economic damage
- Sparking psychological damage
When an entity introduces biological, physical, chemical, or radiological elements to a food supply unintentionally, it is a matter of food security, and when it is intentional for one or more of the reasons mentioned above, it is a matter of food defense. However, both can result in illness, death, or destabilization. Applying both food safety and food defense regulations is crucial; while they are two different programs, both rely on the same workforce to protect public health from the beginning to the end of the food journey.
What Are the Food Defense Principles?
The FDA has identified many ways in which facilities and companies can prevent intentional adulteration. Security is a critical component of food defense and includes securing equipment, cleaning supplies, air vents, and entry or exit points. Facilities can also mitigate risk by installing security systems, fencing, adequate lighting, and alarms. The FDA has based its examples on the four food defense principles and views the examples as versatile and applicable to a broad swathe of the food industry. There are four categories of food defense examples:
- Uniformly mixed products or batches: Comprised of uniformly homogenized products, this category includes baked goods, processed meats, ground beef, or other similar processed foods.
- Large batch size: Many foodservice products are batched in large volumes and would include tanker trucks or storage silos.
- Short shelf-life products: Perishable items that may need to be refrigerated and last for a limited time.
- Easily accessible entry points: It is critical to identify all the points of entry and exit in the facility and determine what food defense tactics can help secure the entry points.
Developing a Food Defense Plan
While developing a food defense plan on top of a HACCP plan or other safety measures can seem like a burden, it is, in fact, a smart way to identify actionable steps for reducing risk. A food defense plan could even prove to be highly cost-effective, as large-scale recalls and product destruction can cost millions of dollars, as well as damage public trust and confidence in the product. A food defense plan has both proactive and reactive elements to provide a wraparound system to protect the food supply. Additionally, crafting a food defense plan could be a more straightforward process than HACCP plans using these four steps:
- Assess for vulnerabilities: Examining potential areas for vulnerability to both external and internal threats. It may help to think about how a malicious or disgruntled person would look for weak spots. Imagine what points in the current operation they could most easily exploit if a politically motivated group wanted to create widespread disruption or illness. A vulnerabilities assessment worksheet can aid in focusing on the areas that a facility should incorporate in the food defense plan.
- Write out the plan: The plan should address accessibility, training, security, and shipping and receiving operations and include details about who is responsible for what and timelines that fit with industry regulations. When it comes to vulnerable elements, preparing simple, economical, and practical measures should be the starting point for containment.
- Prepare to act: The risk of intentional adulteration may seem low, but it is never zero. Whether it’s a single disgruntled employee, or a coordinated attack from an organized group, preparing a plan of action can save critical time and possibly avoid the loss of lives and product. If there is a possible instance of intentional adulteration, then follow the plan to contain, diagnose, recall, and dispose of affected products.
- Actively manage the food defense plan: A plan isn’t helpful if it isn’t current, accurate, and practical. Facilities should review the food defense plan periodically and whenever there is a change to operations or industry regulations to ensure the plan aligns with the needs of the facility and the risk level. A food defense plan cannot be set in stone because of the types of risks, as well as available technology and software changes.
Whether a facility is preparing a food defense plan for the first time or revising an outdated plan, it’s essential to gather some key documents, such as:
- HACCP, SOPs, and other operational procedures
- A detailed map
- Existing procedures for security training, or pre-employment screening and the onboarding process
There should be training for employees with regular revisions to reflect changing technology and risks. Employees are a valuable resource and may hear and see things, so it is vital to have a way for employees to report anything suspicious or unusual. A food defense plan is most successful when everyone, from operator to enterprise-level, is invested in it.
The Food and Drug Administration (FDA) implemented the final rule for Mitigation Strategies to Protect Food Against Intentional Adulteration in 2016. The Intentional Adulteration (IA) Rule of the Food Safety Modernization Act (FSMA) requires every employee of facilities that fall under the rule to receive food defense training. Additionally, a facility must appoint a Food Defense Qualified Individual (FDQI) to oversee certain activities, such as the creation and implementation of a Food Defense Plan.
5 Free Food Defense Plan Resources
If your facility has yet to pursue food defense training, be sure to explore the following free resources for food defense training soon.
- Food Defense Awareness Training: This free online course offered by the Food Safety Preventive Controls Alliance (FSPCA) satisfies section 121.4 (b)(2) of the IA Rule. It is a brief, 20-minute course which anyone can take.
- Overview of the IA Rule: A second free online training course is the Overview of the IA Rule. This online training course is also available through the FSPCA and explores IA Rule basics like the previous course.
- Key Activity Types (KAT) Training: Also available through the FSPCA, the free version of this training allows users to view slides without any interaction. To receive the certificate for this course, users must pay a fee, but the slides alone can provide helpful background information on conducting a vulnerability assessment using KATs. Identifying KATs is an essential aspect of building a comprehensive Food Defense Plan for each facility.
- Identification and Explanation of Mitigation Strategies: This course offers both fee-based and free enrollment options like the KAT training. Again, slides are available for free to help participants understand the mitigation strategies that manufacturers can use to prevent inside attackers from compromising food sources. In order to receive a certificate, however, participants must pay a fee and must satisfy the interactive components of the course.
In addition to these training options, food manufacturing professionals can also use the FDA’s Food Defense Plan Builder to begin familiarizing themselves with basic food defense requirements now. Keep in mind that v2.0 will reflect IA Rule, and the FDA implemented it in 2019. If your facility is just beginning to think about food defense training, don’t wait any longer to get started. The largest companies that fall under the IA Rule must have had their Food Defense Plan in place by July 26, 2019. No matter which route you choose, some type of training is necessary for all employees, especially the FDQI, who will be responsible for preparing a site-specific Food Defense Plan.