Creating a Robust Food Defense Program Through Mitigation Strategies
The purpose of a food defense program is to protect food from rogue acts of tampering where there is an intent to cause harm to consumers. Each year, The FDA recalls almost a hundred million units of food every quarter. Prepared foods are the most recalled food category, followed by baked goods, vegetables, and beverages. Most recalls are due to microbiological contamination. However, the biggest threats to food safety are insider tampering or sabotage by current or former employees (i.e. disgruntled employees) or someone who has a relationship with the business.
Currently, incidents of tampering with consumer products are rare, but they do happen. For example, a former employee of a pizza dough company launched an attack by entering a supermarket that sold the firm’s products. When nobody was watching, the perpetrator inserted razor blades into the pizza dough, putting consumers at risk for severe injury. While only three consumers purchased the tainted dough and found the razor blades before anyone was injured, the case could have been much worse. The perpetrator is now facing a sentence of as long as 10 years behind bars and a fine of as much as $250,000.
However, our collective risk is steadily increasing well beyond disgruntled employees and rogue actors seeking financial gain. Our nation has reached a precarious state of polarization which increases the likelihood of a larger terrorist-style attack through the food system which could cause wide-scale harm to public health. In this type of scenario, the area of highest vulnerability lies inside the facility, and within the employee pool. That’s why it’s critical for every organization to improve its ability to identify a threat and an inside attacker quickly.
Simply establishing or having an existing food defense program for compliance with the FDA IA rule is not enough to protect your company, its products, and consumers from potential harm. Developing effective mitigation strategies to protect food against intentional adulteration is essential. The problem? While the FDA has developed a number of tools and resources to help food facilities prevent, prepare for, respond to, and recover from acts of intentional adulteration of the food supply, most food defense programs are in non-compliance, and awareness of food defense needs to be improved on both the facility and consumer sides.
The largest areas of non-compliance happen through inconsistent application of the site’s food defense program:
- Doors unlocked or open
- Visitors or employees not identified
- Person responsible is not identified
- Challenging the Food Defense Program
- Auditor calibration
Testing the Food Defense System to Identify Vulnerabilities
Conducting a comprehensive food defense plan assessment challenge exercise annually helps identify and highlight areas of vulnerability so that they can be secured. It’s not enough to just walk the perimeter to check that facility doors are locked down—the smarter approach is to see just how far an intruder or adulterator can get into the facility, and then identify ways to stop them and get back to business with minimal damage to consumers and the brand reputation. The best approach is to partner with experienced food safety professionals to launch a full-court press challenge the food defense program plan through immersive crisis management exercises that simulate a real-world problem involving an internal or external security breach.
Of course, timeframes are artificially compressed during these fictitious exercises, and real world scenarios are far less predictable. However, the challenge exercises are designed to run from first notification to escalation, each involving a step up in the threat level and consequences in the particular scenario. Each segment is designed to test how quickly and effectively the facility and staff can identify the area of threat, who should be notified, additional information needed, along with any next steps. The goals are to learn how to efficiently and effectively deal with authorities, media, customers, the public, SQFI, and the certification body, identify the perpetrator, mitigate the issues and the potential impact on the business and consumers, and recovery. These exercises are true challenges to existing food defense programs, and areas of vulnerability will quickly be revealed. From there, mitigation and recall strategies can be improved and areas of vulnerability closed off—making food facilities and consumers safer.
Ready to put your food defense plan to the test? Schedule a consultation today.