Is Our Food Safe From Attack?

Food DefenseIn a Swine Production SettingCourtesy of Food Technology magazine, from "Defending the Food Supply," August 2005, Vol. 59, No.8. Food Technology is a publication of the Institute of Food Technologists, www.ift.org.

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Is Our Food Safe From Attack?2The events of Sept. 11, 2001 have focused attention on terrorism and the potential for future acts of terror.

No other terrorist event has ever killed more people or caused more economic damage. Nearly 3,000 people were murdered and over 80 million dollars in losses were incurred. This number represents direct costs of medical and clean-up. There are many indirect costs beyond that such as increased security in airports and other public venues across the nation.

The U.S. government has declared the food and agriculture sector to be one of 17 critical national infrastructures vulnerable to intentional attack.3The evaluation of critical infrastructures was motivated by the attack on 9-11-2001. Following the evaluation congress passed the Bioterrorism Act of 2002 which expands governmental authority to prevent, detect, and respond to an attack. The U.S. Food supply Chain produces about 13% of the nations gross domestic product and accounts for 18% of domestic employment. Weapons of Mass Destruction or other contaminants could be used, or their use could be threatened against our nations food supply. An attack on the food and agriculture sector, or merely the threat of an attack could cause havoc with the food supply chain and have far reaching consequences with health, economics and consumer confidence. Dec. 2, 2004, then secretary of Health and Human Services Tommy Thompson drew public attention to the vulnerability of the food and agriculture sector when he said I cannot understand why the terrorists have not targeted our food supply, because it is so easy to do.Sources:Food Technology 7-06 p.34-42

Will this Effect Missouri?Missouri ranks 2nd in the nation for number of farms.7th in the nation for hogs and pigs

4Yes, of course this will effect Missouri. Agriculture continues as a solid base for the economy of Missouri which is one of the leading livestock states in the nation.105,000 farms, 5% of the national total.hogs and pigs 2,750,000, 4.5% of the national totalSources:Missouri Farm Facts www.nass.usda.gov/Statistics_by_State/Missouri/Publications/Farm_Facts/2006/Rank

Show Me the MoneyMissouri farms rank 15th nationally for cash receipts.

Missouri farms have estimated cash receipts of 5.82 billion dollars per year.

5Missouri farms rank 15th nationally for cash receipts with over 5 billion dollars. This represents 2.4% of the U.S. total. Over half of Missouris farm income is from livestock and poultry. Hogs represent 11% of Missouri farm receipts. Sources:National Ag Statistics Service NASS:MO field office 2004 dataUnited States Economic Research service www.ers.usda.gov/StateFacts/Case Study: Bitter Harvest1973 Fire retardant (PBB) accidentally mixed into feed rations for cattle.Over a year later sickness in animals, and humans is linked to PBBs.Cattle, pigs, sheep, chickens, and contaminated commodities are destroyed and buried.97% of humans living in Michigan during that time have PBBs in their system.

6Polybrominated biphenyl (PBB), a fire retardant chemical was mistaken for MgO and accidentally mixed into livestock feed in 1973. The contaminated livestock feed was fed to cattle and other livestock which exhibited symptoms including death and loss of productivity. The chemical also caused sickness in humans that consumed the animal products. Humans experienced headaches, dizziness and sore joints. PBB was not identified as the source of the symptoms until 1974. Levels of PBB tolerance were set and farms were quarantined based on testing, but euthanasia of livestock was not required. Condemned cattle carcasses were reprocessed as protein supplement for other animals which further compounded the problem. The chemical company involved fought to allow animal products to be sold even with some levels of contamination.

By the end of 1975, 28,900 cattle, 5,920 pigs, 1.5 million chickens, and nearly 5 million eggs had been destroyed; buried with them were 865 tons of animal feed and 27 tons of various dairy products. The PBBs in those carcasses and products are still buried there with them.

Testing in the late 1970s revealed that 97% of humans in Michigan at the time of the contamination were had some level of PBBs in their bodies. PBBs were found in breast milk and so children born after the contamination was discovered were exposed. PBBs are stored in adipose (fat) tissue, and so contamination does not diminish over time.

Farmers whose livestock was contaminated above 0.3 ppm were eventually compensated by insurance companies, but no compensation existed for farmers whose animals had lower levels of exposure. Many farmers with livestock contaminated below 0.3 ppm destroyed their cattle or other livestock because they felt it not ethical to sell animal products with any level of PBB contamination. Many of those farmers suffered severe economic losses.

Some buildings and soil are still testing positive for PBBs, years later and disposal sites remain contaminated today.Sources:The Michigan PBB Disaster, Everything 2, 1-3-2006And Now, Cattlegate, Time Magazine 5-10-1976

What Type of Harm Could Occur?Intentional delivery of a harmful biologicalor chemical agent to the food supplysystem could cause:

Physical harm (illness or mortality)Economic disruptionDirectIndirectInternationalPolitical unrestPsychological harm loss of confidence in food supply

There are several reasons why the Food and Agriculture sector is vulnerable to attack. Damage to the food supply system could cause a multitude of problems, from death and illness to economic damage, political unrest and psychological harm. There are groups violently opposed to imprisonment and exploitation of animals, use of meat and fur, and animal by-products, use of meat from genetically modified animals, and use of meat from animals that have consumed antibiotics. There are also many extremist groups both domestic and foreign that could choose to target food and agriculture, for economic or political reasons. Awareness of this vulnerability is a big part of reducing the risk. The goals of an individual or groups wanting to intentionally contaminate the food supply are varied. They may wish to cause any or all of the following:Physical harm: Morbidity (illness) or Mortality injury through contamination of food could be caused to a few individuals or large numbers of people, depending on the contaminant and level of contamination. Economic disruption: Contamination or even the threat of contamination in our food supply could cause major damage economically. Food and Agriculture account for140 billion in revenues, 13% of U.S Gross Domestic Product and 18% of U.S. employment.a. Direct economic losses include costs associated with the response to the act of contamination which include:medical costs: related to death, illness and recovery, and any preventative measure taken to assure the health of animals and humans at risk.wages: both those lost by workers at affected facilities and also extra wages incurred by those responding to the act (security, emergency personnel, etc.)containment: quarantine of infected food or humans, tracking of contaminated food already shipped, storing contaminated food until cleared or disposed of. decontamination: removing any contaminant residue from food production or rocessing, clean-up of hazardous material (over million dollars was spent to decontaminate one postal facility contaminated with anthrax). Decontamination of some facilities may not be possible depending on the contaminant and the type of facility.disposal: contaminated carcasses must be disposed of in a safe manner (ie, burying, burning, burial at sea). Columbia locals may remember an issue related to improper disposal of hot dog casings. From 1995 through 1999, Kraft subsidiary Columbia Foods Co., maker of Oscar Mayer hot dogs, contracted with Wayland and Basnett to pick up and transport used casings for disposal. The casings were made of wood-cellulose fiber, gelatin and water. Over that period of time 9,000,000 lbs. of casings were dumped on a private farm. The DNR cited Kraft for violations of the Solid Waste Management Plan and the Water Pollution Control Program. All this fuss, and imagine how much worse the problem would be if it involved product contaminated with a hazardous material. b. Indirect multiplier effects include losses not directly associated with the response, effects that will add up down the line. Government programs that will food producers/processors for the food destroyed, losses for ancillary businesses such as suppliers, shippers, distributors, etc. If some of the ancillary businesses are dependent on that one large client, they may go out of business.c. International costs include losses associated with a loss in confidence by our international trading partners. C.Political change: The Rajneeshees tried to influence election results by poisoning salad bars to reduce voting.D.Psychological harm: Contaminations, or threats of contamination can cause a loss of consumer confidence, but also cause panic among consumers.Sources:Columbia Tribune archives http://archive.columbiatribune.com7Case Study: MelamineContaminated Wheat Gluten pet food .Cats and dogs fall ill and some die.Massive recall of pet foodContamination was intentional.Waste pet food fed to hogs in 7 states56,000 hogs quarantined

8Chinese manufacturers of pet and livestock food had for years been adding Melamine to increase the apparent protein content of the feed. The melamine does not give any nutritional value, but neither was it thought to be particularly toxic. It was later found to be toxic to pets. Even if Melamine is not found to be the cause of pet deaths, it is still not approved as an ingredient in pet or livestock food. Addition of any substance that is not approved as a feed ingredient could lead to condemnation of the livestock resulting in euthanasia.

Xuzhou Anying Biologic Technology Development Center, advertised on the internet for scrap melamine in 3-06 and was later identified as one of the Chinese companies supplying Melamine tainted wheat gluten to Menu Pet Foods of Canada.

56,000 Hogs were quarantined in CA, KS, NC, SC, IL, NY, and UT on 4-26-07. Subsequent testing revealed that the melamine did not stay in the meat and the hogs were released 2-3 weeks later.

80, 000 chickens in IN were placed on hold due to consumption of salvaged pet food. They were eventually cleared.

Producers were compensated for costs associated with holding the livestock. Sources:Filler in Animal Feed is Open Secret in China New York Times 4-28-07 by David Barboza and Alexei BarrionuevoBrownfield Ag News by Bob MeyerUSDA approves processing of hogs exposed to melamine USA Today, by Elizabeth Weise, 5-15-07USDA APHIS

-Farrow to Finish Operation9Farrow to Finish Operation-Animals on farm are vulnerable to intentional contamination through the water supply, feed and other supplies purchased off-farm, animals brought on-farm and visitors.

-Feeder Pig Operation10Feeder Pig Operation- Should stock arrive in the facility contaminated, depopulation followed by decontamination could cause loss of contracts and jeopardize the future of the facility.

Concentrated Animal Feeding OperationCAFO11Whitetail MO CAFO

Hog farms may have 10,000 hogs or more.

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Sources:FEMA 2002

-Boar SemenArtificial Insemination (AI) is an important part of the swine industry. It is also an area that is vulnerable to contamination.

12Boars kept in a facility the produces semen for artificial insemination are vulnerable, as is the semen after it has been collected. Contaminated semen or semen from contaminated boars has the potential to contaminate many sows and their litters.

-Supply Chain13Supplies used for feeding, bedding etc. are vulnerable to intentional contamination. They may be contaminated prior to arrival, while in the warehouse, or during shipping. Producers must be confident in the security of their suppliers, and have strict standards for delivery and unloading of the supplies.

-Feed Mill14Intentional contamination of the livestock food supply could be one way to execute a terrorist attack against the agricultural economy. Feed Mills, especially large ones could be sabotaged as a point source. Distribution of a contaminant could be widespread in a relatively short period of time.

-Transportation

-Transportation15Animals are vulnerable to intentional contamination during or prior to transport. Animals are not always fed and watered during transport, but the trailers are open to the air and easily accessed during rest or refueling stops.

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-Buying Station16Swine in the buying station, are vulnerable to intentional contamination via water, feed, humans in the facility or contaminated animals on site. Contamination occurring at a large buying station can be spread rapidly as contaminated animals come into contact with healthy animals prior to shipping.

What is Food Defense?Food Defense focuses on security, protecting the food supply from intentional contamination. Courtesy of Food Technology magazine, from "Defending the Food Supply," August 2005, Vol. 59, No.8. Food Technology is a publication of the Institute of Food Technologists, www.ift.org. 17Is Food Defense Different than Biosecurity?Food Defense focuses on protecting the food supply from intentional contamination.

Biosecurity and Food Safety (HACCP) focus on protecting the food supply from unintentional contamination. They help with, but are not a substitute for food defense.

18An animal facility with an excellent Biosecurity program is still vulnerable to intentional contamination. Biosecurity programs are not intended to reduce the risk of intentional contamination.Who Might Intentionally Contaminate an Animal Production Facility?Disgruntled employee/former employeeContract or temporary employeeMembers of terrorist or extremist groupsTruck driverAffiliate of a competing facilityVisitor to facility

19Intentional contamination can originate inside the targeted facility. Many attacks are orchestrated by disgruntled employees or disgruntled former employees. Thus far, these 2 groups have perpetrated most of the known incidents of food contamination. Examples include:1. A former hospital lab worker sneaked back into the lab and issued an e-mail invitation to former colleagues to enjoy some pastries (that she had contaminated with dysentery).2. A supermarket worker that contaminated ground beef in an attempt to get a supervisor in trouble.

Attacks could also be carried out by the cleaning crew, or contract and temporary employees. These workers may not have loyalty to the company and might be bribed or influenced by outside sources to participate in an attack.

Terrorist and extremist groups are always a concern. Their members may seek employment at a facility they intend to attack.1. Al Qaeda perpetrated the deadliest terrorist act, and may at any time be looking to top that. 2. PETA members have been quoted as, not engendering such an attack, but if it happened, that it could be in the best interest of the food animals and the health of the American public (ie, encourage vegetarianism). Members of this group frequently enter premises under false pretenses to shoot video tape.3. Religious extremist groups (cults) are capable of violence against themselves and others the Rajneeshees poisoned salad bars in Oregon in order to influence a county wide election.

4. March 1970, an Alabama group of KKK poisoned cattle with cyanide in order to get Black Muslims who had purchased property to sell out.

1996 Chlordane is intentionally added to components of cattle feed that was in turn distributed to 4,000 farms in 4 states. Product was recalled and raw materials destroyed. Losses to the company were $ 2.5 million dollars and total impact to the agricultural system was $250 million. The contamination was perpetrated by the owner of a competing livestock feed processing facility.Potential Contaminants

Biological Agents: Injure by causing disease, or producing toxin.

Chemical Agents: Injure through toxicity to biological systems, or chemical burns to tissue.

Radiological Agents: Injure externally with radiation burns and potentially deadly acute radiation sickness. Injure internally by causing damage to internal organs.

20Biological Agents of Concernin a Swine Production FacilityDiseasesPorcine Reproductive and Respiratory Syndrome (PRRS)Foreign Animal Disease (FAD)Foot and Mouth Disease (FMD)Classical Swine Fever (Hog Cholera)Zoonotic DiseasePseudorabiesSwine Vesicular Disease (SVD)

21BSE US, Great BritainNYC West Nile virus.Nipah virus in AsiaFMD in great Britain, indigenous in Africa and areas of South America

FAZD Center estimates that an FMD outbreak in the U.S. would cost the economy $ 2.3 million per hour.

Diseases can be used as Biological weapons and most countries have the capacity to do this. 18 countries are believed to have done this, including some that may support terrorism. In 1979 the Soviet Union accidentally released Anthrax spores from a military research facility. 66 people died from anthrax contamination.

Foreign Animal Diseases are Non-indigenous diseases, or those that have been eradicated. They can be artificially introduced/reintroduced. Increasing urbanization and global traffic has minimized geographic barriers that once restricted movement.

There have been 66 criminal events and 55 terrorist events involving biological agents between 1960 and 1999. Most of those have been in recent years.

Zoonotic agents may be amplified in host species.Case Study: This Little Piggy1998, Malaysia cases of pigs dying were not immediately recognized as outbreakOct. 1998 Pig farm workers suffer possible encephalitis epidemic(265 cases, 105 deaths)Identified as new virus now called NipahOver a million pigs from nearly 1,000 farms were destroyed. Pig production is reduced from 2.4 million to 1.32 million, and farms from 1885 to 829.22The illness in the workers was initially diagnosed as Japanese encephalitis (JE), which is zoonotic, but does not kill pigs. Pigs in other areas began dying, but the diagnosis was not changed even thought JE should not kill pigs. Typical control measures for JE did not work. Singaporean abattoir workers were infected after coming into contact with the Malaysian pigs.

New virus was finally discovered and named Nipah after one of the areas in Malaysia where it occurred. Nipah was responsible for illness in pigs and humans.

They began culling (eradicating) all pigs in infected areas. Later a test was able to indicate which farms were infected and there were 50 positive farms. The epidemic was successfully controlled in May 1999. 1,073,978 pigs from 946 farms were destroyed, and in the long term the number of pig farms was reduced by over half and the number of pigs by nearly half.Sources:A Tale of Two cities and the Trojan Horse: Lessons in Biological Defense. Journal of the Singapore Armed Forces v26, #4, (Oct.-Dec. 2006)Chemical AgentsAny Chemical not approved for use on the animals, or in their feed would be considered a contaminant. Chemical agents used in acts of terrorism against livestock include:ArsenicCyanide saltPesticides

23Whether or not the chemical is harmful to the animals or humans consuming the animals, contamination could result in quarantine and/or euthanasia of the animals. Contaminated animals would produce adulterated meat or other products which could not legally be sold.Chemicals are more stabile than most microorganisms and so are easier to store and transport. Technical expertise is not necessary for handling the chemical or carrying out the contamination. It has been thought that large quantities of chemical would be necessary to generate toxic effects, but in fact many chemicals are toxic in the ppm or even ppb range. Once an incident is uncovered, the contaminated feed must be quickly be recalled and destroyed to prevent further injury.

Radiological AgentsLivestock can be exposed to radiation via inhalation, ingestion of contaminated feed, or direct exposure. Polonium 210PlutoniumUranium (U-235 or U-238)Iodine 131 (I-131)

24Radioactive materials produce ionizing radiation, which can damage living tissue, by breaking chemical bonds or removing electrons from atomsRadiation can be emitted as alpha, or beta particles and gamma radiation.Alpha particles are only harmful once they are inhaled, ingested or enter a body through a wound. Once inside a body, alpha particles damage or destroy genetic material within cells. They often cause cell death and scarring of vital organs such as lung, kidney and liver. A small dose of something such as Polonium 210 can be fatal. 1g of Polonium 210 could theoretically affect 100 million humans of which 50 million would die.Polonium, Plutonium and Uranium decay as alpha particles and Iodine as beta particles with gamma radiation. The danger with I-131 is that it is soluble in water and the radioactivity is expressed in the milk of animals that have ingested it.For defense purposes concern is for those experiencing acute exposure. This means short term exposure to high levels of radiation. Cancer patients receive this type of exposure, but under controlled conditions. Persons unknowingly experiencing acute exposure may exhibit symptoms such as burns and radiation sickness. The symptoms of radiation sickness include, nausea, weakness, hair loss, and diminished organ function. If the dose is fatal, death will usually occur within 2 months.

Young animals and fetus are especially sensitive to radiation effects, due to the relatively rapid cell division.

Sources:www.epa.gov/radiationWhat Makes an Attractive Agent of Intentional Contamination?Long incubation period/delayed effectHighly effectiveHistory of useAvailable (easily produced in adequate quantity)Low traceability

25Many who would intentionally contaminate livestock want the contamination to be discovered long after the initial contamination. Agents with a long incubation period will become more toxic after the contamination event and will be more difficult to trace. Agents with a delayed effect, such as radiation poisoning are difficult to diagnose and symptoms do not occur immediately after contamination. This delays identification of the contaminant and can make locating the source nearly impossible.

Highly effective agents will be used by those wishing to cause a high rate of morbidity and/or mortality. Highly effective agents will be those that are so contagious or dangerous that contaminated animals will need to be destroyed.

Once an agent has been used, it is more likely to be used again. Pesticides used to kill other life forms can also be used against livestock.

Agents are more likely to be used if they are easily available.

Most groups planning an intentional contamination will chose a contaminant that will not be easy to trace back to them. The Rajneeshees contaminated 10 salad bars in Oregon, the Salmonella poisoning was thought to be food born and it was not traced back to the cult for nearly a year.

What Do Consumers Think About Food Defense?Following several major food recalls in the US, consumer surveys were conducted.Courtesy of Food Technology magazine, from "Defending the Food Supply," August 2005, Vol. 59, No.8. Food Technology is a publication of the Institute of Food Technologists, www.ift.org. 26There are many government agencies that are tasked with assisting in the defense of our food supply, but in the end who is responsible? National and State governments can advise and guide preparedness, but the effected industries are, in the end, responsible for planning and prevention. Response to an incident will be fastest at the local level and developing a plan for response and communication will establish a base for an effective response.

All stakeholders should be involved in the efforts of planning and prevention. Local first responders, and industry links such as feeder, transporters, veterinarians, and cooperatives, need to be part of the team.

Consumer Confidence in Food Defense Systems After National Food Recalls

Stinson et al., 2008From: Thomas F. Stinson, Ghosh K., Kinsey, J. and Degeneffe, D. Do Household Attitudes About Food Defense and Food Safety Change Following Highly Visible National Food Recalls? Amer. J. Agr. Econ. 90 (number 5, 2008): 1272-1278

Surveys were conducted following national food recalls :

Between 2005 and 2007, there was an increase in the number of consumers considered to be not very confident about food defense.

Between 2005 and 2007, there was a decrease in the number of consumers considered to be very confident about food defense.27Who Do Consumers Believe is Responsible for Food Defense?Stinson et al., 2008From: Thomas F. Stinson, Ghosh K., Kinsey, J. and Degeneffe, D. Do Household Attitudes About Food Defense and Food Safety Change Following Highly Visible National Food Recalls? Amer. J. Agr. Econ. 90 (number 5, 2008): 1272-1278

Over 50% of consumers believe that government or manufacturers and processors should be responsible for food defense.28Products That Consumers Believe Most Likely to be Intentionally Contaminated

Stinson et al., 2008From: Thomas F. Stinson, Ghosh K., Kinsey, J. and Degeneffe, D. Do Household Attitudes About Food Defense and Food Safety Change Following Highly Visible National Food Recalls? Amer. J. Agr. Econ. 90 (number 5, 2008): 1272-1278

When surveyed about which products were most likely to be intentionally contaminated, Meat, Produce, Dairy, and Seafood were the areas they were most concerned about. 29Who do Consumers Believe Should Pay for Food Defense?Stinson et al., 2008From: Thomas F. Stinson, Ghosh K., Kinsey, J. and Degeneffe, D. Do Household Attitudes About Food Defense and Food Safety Change Following Highly Visible National Food Recalls? Amer. J. Agr. Econ. 90 (number 5, 2008): 1272-1278

Most consumers do not believe they should bear the cost for food defense.30Food Defense PlanDefense plans are encouraged but not required for farms and most food establishments.Courtesy of Food Technology magazine, from "Defending the Food Supply," August 2005, Vol. 59, No.8. Food Technology is a publication of the Institute of Food Technologists, www.ift.org.

31Food defense refers to reducing the risk of an intentional contamination of our food supply. Not all attacks can be prevented, but implementation of a food defense plan can minimize the risk of an intentional contamination. All food facilities should develop a plan specific to their product and operating conditions.

USDA FSIS and FDA both strongly encourage all food facilities (regardless of size) to develop a Food Defense Plan.Facilities Currently Required to Participate in Food DefenseAll vendors providing food for USDA feeding programs must now be in compliance with the Food Defense System.

32Sources:www.ams.usda.gov/fv/ppb.htmlFour Steps for Developing a Food Defense PlanAssess the vulnerabilities

Write a plan

Evaluate the plan

Maintain the plan

33Food processing/distributing facilities should implement those measures applicable to their particular operation.

The plan should include:1. Emergency planning-a. Planning for emergency evacuation (maintain floor/flow plan off site).b. 24 hour contacts for local law enforcement, and FDA or USDA, whichever is appropriate, posted , listed in order of contact in case of incident.2. Employee supervision planning-a. Plans to increase staff awareness/trainingb. Schedules for supervision/security checks3. Recall planning- secure handling and disposition of returned product 4. Investigation planning-investigation of threats, or suspected incidents, coordinating with law enforcement5. Evaluation planning- review plan (at least annually), mock recalls, random inspections, add new countermeasures as needed. Assess the vulnerabilitiesGather a team of key personnel to make the assessment.Think like someone who wants to harm your operation.Look for areas where contamination would be spread through normal operations.Look for sensitive areas that are not frequently observed.

34The process for assessing vulnerability endorsed by the FDA, FSIS, FBI, and Department of Homeland Security is CARVER + Shock. CARVER + Shock is a tool used to asses the value and vulnerability of potential targets. CARVER + Shock was initially used by the military (Department of Defense), but has been modified for the food/agriculture industry. It considers vulnerability and human ingenuity which are unique to an intentional attack. CARVER is an acronym which stands for the 6 basic attributes. A 7th attribute is added in the version modified for the Food and Agriculture sector.Criticality (public health, economic impacts)Accessibility (access to and egress from a target)Recuperability (system recovery potential)Vulnerability (ease of access)Effect (amount of direct loss suffered)Recognizability (ease of identifying a target)SHOCK (psychological effects)A particular food product for example, would be ranked based on scales developed for each of the 7 categories. Combining rankings from each of the attributes would allow a food product, process, or facility to be ranked on a scale from 1-10 (1 is low, 10 is high) for attractiveness as a target.

CARVER = Shock is not always practical for the small and very small operations. Thus we have come up with a worksheet to guide vulnerability assessment in many different types of operations.

Swine Operation Vulnerability AssessmentElements that are secure do not need to be considered for further action on the food defense plan. If there are specific areas of your operation that are not covered you may add terms to any of the categories that describe your situation.35Countermeasures are actions taken to shield vulnerable areas, reducing the risk of intentional contamination.

Countermeasures36As high risk vulnerabilities are identified, counter measures are developed to reduce the risk of intentional contamination of those vulnerable areas.Areas to Consider for Countermeasure DevelopmentProceduresFacilityTechnologyPersonnel

All countermeasures protect: Personnel, product, and property

The most economical changes are generally changes in procedure that improve security. If procedural changes cannot reduce the vulnerability, changes to the facility may be slightly more costly (i.e. locks, gates, fences, signs etc.) and technology is more costly (i.e. surveillance camera), but is less expensive than hiring extra personnel for security.

The following are areas that arent usually considered by small producers and processors and are designed to give them some ideas to start with.37WorkforceShipping and ReceivingVisitors and CustomersMarketingCountermeasures for Procedures

Countermeasures for the workforce include:Screening employees (background check, check references, credit check, ICE check)Supervision of employees (if employees are well supervised they are less likely to cause intentional contamination)Limit access to sensitive areas (lock doors, use signage, use buddy system (no one alone in a sensitive area))Training Give basic food defense information to employees. Use SCAN system, See, Challenge, Ask, Notify (p 15 of guide MP914) or FIRST and ALERT which are provided by FDA free of charge (in several languages). If they are invested in your program they will more fully support it.Shipping and Receiving: Make sure there are designated times for delivery and an employee is present to check that the delivery matches and order and the bill of lading. Be vigilant with new or temporary drivers. Open packages and mail away from processing areasVisitors and Customers: Make sure they are supervised and/ or access is limited to retail area. Identify them (ask for ID), and have them sign a visitor logMarketing: Check security in the place your product will be sold. Who has liability in the case of an intentional contamination. Challenge would be contaminators by adding layers of packaging or using other ways to creatively limit touching.38

Light it

Lock it

Limit AccessCountermeasures for Facility

These 3 basic principles can be applied to increase the physical security of the facility.

Light it can mean adding outside lights such as dusk to dawn lights or motion sensor lights. The basic idea is to increase visibility, especially at night. Part of increasing visibility can be trimming or removing landscaping that limits visibility. Input from a retired peace officer or your county emergency manager may be valuable to determine where the lighting or landscape changes would do the most good.

Lock it refers to all exterior and interior openings such as doors, windows or ventilation screens that could be used to enter the building or a sensitive room. They should all be locked whenever possible and there needs to be a key inventory system. Keys should be retrieved immediately from dismissed employees. There should be a system for a specific person to check locks at the end of the shift or day.

Limit access means reducing the number of people with access to sensitive areas. This can be done with perimeter fences that limit access to the facility itself. Signage within the building or on the perimeter of the facility can be posted to indicate who has permission to enter. Authorized personnel only is useful only as long as everyone knows who is authorized. 39Write the PlanDevelop a countermeasure to defend each vulnerable point identified as high risk.Create a written plan including those countermeasures that are reasonable for the situation.Identify the individual who will implement the countermeasure.Set a timeline to implement the countermeasure.

40A countermeasure designed to reduce the risk of intentional contamination should be developed for each area identified as high risk. Common sense needs to be maintained in designing countermeasures. Economical feasibility also needs to be considered. Constructing a perimeter fence may be too expensive for a small facility to afford. Some countermeasures may not be physically possible. There may be more than one countermeasure that would work for any one area of high risk. Choose the counter measure which is best for a particular situation. Countermeasures may also be phased in over time to ease any economic burden they might impose.

A copy of the Food Defense Plan should be kept in a secure area within the facility and also off-site in case an evacuation should be necessary.

Plans will vary in their level of complexity. Variation can be attributed to size of facility, and also type and number of products produced.

Swine Operation Food Defense PlanOnly those elements from the vulnerability assessment worksheet that were not secure need to be dealt with on this worksheet. If it is not practical for your operation to develop a countermeasure for a specific vulnerability indicate that by checking no and then no further action will be needed.41What if the Food Supply is Intentionally Contaminated?Should such an event occur a timely and efficient response will be critical to minimizing the damage.

42Attacks, or incidents of intentional contamination cannot be prevented 100% of the time. A determined attacker will more than likely overcome preventive measures. Facilities in the food supply chain must be prepared with a planned response. Instructions for response to an incident should be included in the food defense plan.There are many government agencies that are tasked with assisting in the defense of our food supply, but in the end who is responsible? National and State governments can advise and guide preparedness, but the effected industries are, in the end, responsible for planning and prevention. Response to an incident will be fastest at the local level and developing a plan for response and communication will establish a base for an effective response.

All stakeholders should be involved in the efforts of planning and prevention. Local first responders, and industry links such as feeder, transporters, veterinarians, and cooperatives, need to be part of the team.

Develop a Written Response PlanPlan for handling of contaminated animalsEmergency PlanningFacility MapEmergency Contact Phone ListVisitor LogSupplier/Customer ContactsEmployee Emergency Information

43The response plan should include a plan for recall in case of intentional contamination. Product as well as unused ingredients, unused packaging material, storage are, and equipment may need to be secured pending investigation.

Facility map and all emergency contacts needs to be kept current and be available 24/7. they should be kept both on site and off site

Swine Operation Containment and Disposal PlanHaving a plan to deal with a potentially catastrophic problem can speed up the response and get your operation back up an running as soon as possible. The more quickly a damaged operation gets back to normal operations, the more likely it is to survive.44

Handling of Contaminated AnimalsFirst hold all potentially contaminated animalsPotentially contaminated animals will need to be quarantined prior to euthanasia.Quarantine will need to be separate from non contaminated animals.Prepare a plan for carcass disposal, to be reviewed by APHIS and state authorities in case of an intentional contamination.45Contact USDA APHIS 24 hour emergency line 1-800-940-6524Facility MapName, address, and phone of owner/proprietorRelationship of the facility to adjacent properties and/or structures.Road access including transportation routesPerimeter boundaries, include fences, and gates (with dimensions)46To be stored on and off site in case of emergency. The information contained in the facility map will be vital to responders in case of an intentional contamination. It can also be useful in other emergency situations.Facility Map continuedBuildings, outbuildings, doors, windows, AC/heating, ventilation Utilities (water, gas, electric, phones) location and shutoff Septic System and drainage areas with direction of flowWeb sites such as Google Earth www.earth.google.com47

ACWater access

Swine Operation Emergency Phone List49Contacts for local, state and federal responders as well as those providing utilities.

Swine Operation Employee Emergency ContactsEvaluate the planCheck the perimeter regularly.Make unannounced entrances at various times.Check locks in vulnerable areas.Perform a mock quarantine.

51Evaluation may be performed by professionals from outside the company, or knowledgeable employees within the facility. These should be performed at least annually, or as new products and/or processes are introduced at a facility. Evaluations should also be performed randomly. Evaluations may also be indicated if risk to a particular product or process becomes elevated.Maintain the planEnsure that measures implemented continue to be effective.Train the family/employees regarding their effort in:PreventionDetectionResponseRe-evaluate the plan annually or as operations or facilities change.52Monitoring will be needed to make sure that procedural changes are maintained. Security procedures and equipment should be updated as technology advances.Facilities or brand names which experience a significant problem and come off of store shelves for any length of time may never return and the company may go out of business. Make sure that your employees are invested in the process of securing the facility. Training should be provided, and direction given regarding employee efforts in:Prevention: Increased observation, maintaining new countermeasuresDetection: Recognizing and reporting activity out of the ordinary (unusual illness patterns among employees, unknown or unauthorized persons accessing critical areas, etc.)Response: Employees assigned responsibility in case of incident, emergency response plan in place, and known to employees, emergency contact info maintained

Training is available from many different sources. FDA CFSAN, and USDA FSIS have materials available including online courses. Some private companies offer food defense coordinator training.

Sources:www.aibonline.org/courses/ Referenceswww.aphis.govwww.animalagriculture.orgwww.porkscience.org

53Chart111.9319.635.3

Aug 2005June 2007very confidentnot very confident

Sheet1very confidentnot very confidentAug-0511.931Jun-079.635.3To resize chart data range, drag lower right corner of range.

Chart15047.554.347.326.23234.3

Series 1June 2007

Sheet1Series 1Produce50Dairy47.5Meat54.3Seafood47.3Baked26.2Canned32Boxed34.3