PNS/BAFPS 134:2014 ICS 67.020
Food defense guidance for industry
BUREAU OF PRODUCT STANDARDS Member to the International Organization for Standardization (ISO) Standards and Conformance Portal: www.bps.dti.gov.ph
PHILIPPINE NATIONAL
STANDARD
PHILIPPINE NATIONAL STANDARD PNS/BAFPS 134:2014
Food defense guidance for industry
Foreword Food defense is a collective term used to describe efforts to prevent intentional contamination of food products by biological, chemical, physical or radiological agents that are not reasonably likely to occur in the food supply. It is different from the concept of food safety, which involves efforts to protect food products from unintentional and naturally occurring contamination by agents reasonably likely to occur in the food supply. More often, food defense is confused with food safety. This Food Defense Guidance for Industry was developed in order to provide a general overview of the food defense concepts, principles, elements and procedures. This document will eventually assist the food industry in complying with future regulatory requirements of importing countries such as the United States and national regulatory requirements such as that of the National Meat Inspection Service. In 2013, Republic Act (RA) 10536 ammended the Meat Inspection Code of the Philippines (RA 9296), to include a division at the National Meat Inspection Service (NMIS) on “Enforcement and Food Defense.” This division shall be responsible for the enforcement of policies against hot meat and adulterated or misbranded meat products, and the protection of meat products from hazardous contaminants.
A Technical Working Group (TWG) was created through Special Order Nos. 106 and 201 Series of 2013 to develop the draft Food Defense Guidance for Industry. The TWG represented the relevant agencies of the Department of Agriculture (DA), Department of Health (DOH), University of the Philippines (UP), and the private sector. Public consultations were conducted in Davao, Cebu, and the National Capital Region (NCR), which represented the major exporting regions in the Philippines. Comments and recommendations were solicited from the relevant government agencies, academe, private sector and non-government organizations. Therefore, this Guidance Document is the final output of the public-private sector collaboration between and among the TWG and the relevant stakeholders who participated in the public consultations.
PHILIPPINE NATIONAL STANDARD PNS/BAFPS 134:2014
Food defense guidance for industry
1. Introduction
Food defense is a collective term used to describe efforts to prevent intentional contamination of food products by biological, chemical, physical or radiological agents that are not reasonably likely to occur in the food supply. It is different from the concept of food safety, which involves efforts to protect food products from unintentional and naturally occurring contamination by agents reasonably likely to occur in the food supply.
After the September 11 attack in 2001, the United States (US) signed into law the Bioterrorism Act of 2002 which aimed to improve the capacity of the United States to prevent, detect and respond to terrorist acts. Concern for the food safety of the food supply, which can be a target of terrorist attacks, also came into the fore. With it came a basic understanding to better secure the food supply. In 2002, the Homeland Security Act provided the basis for the Department of Homeland Security to be responsible for protecting critical infrastructure, including food and agriculture. In 2003, Homeland Security Presidential Directive 9 established the policy of improving intelligence, emergency response, mitigation strategies and vulnerability assessments to defend food and agriculture against terrorism, major disasters and other emergencies. Food terrorism, as defined by the World Health Organization (WHO), is an act or threat of deliberate contamination of food for human consumption with chemical, biological, radionuclear agents for the purpose of causing injury or death to civilian populations and/or disrupting social, economic and political instability. Physical hazards may similarly be intentionally introduced to a food system by a perpetrator. Since then, the term food terrorism has evolved and was replaced by food defense. Food defense has now become a part of an even larger concept of food protection, which also encompasses food safety and food quality. Currently, the US Food Safety Modernization Act (FSMA) requires the US Food and Drug Administration (USFDA) to issue regulations to protect against the intentional adulteration of food. The following sections of FSMA relate to intentional adulteration or food defense:
Section 103: Hazard Analysis and Risk-Based Preventive Controls –“identify and evaluate hazards that may be intentionally introduced, including by acts of terrorism”
Section 105: Standards for Produce Safety – “consider hazards that occur naturally, may be unintentionally introduced, or may be intentionally introduced, including by acts of terrorism”
Section 106: Protection Against Intentional Adulteration – “issue regulations and guidance to protect against intentional adulteration of food”
Section 108: National Agriculture and Food Defense Strategy – “a strategic planning document that is in the process of development”
The Asia-Pacific Economic Cooperation (APEC) likewise identified food defense as having potential impact on trade and measures were recognized as integral to protecting the food supply. APEC endorsed a set of nine (9) Food Defense Principles in 2007 and created an
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APEC Food Defense Pilot Program in 2008 in an effort to put the principles into practice. The Philippines was one of the four (4) pilot economies of the APEC Food Defense Pilot Program conducted in 2011.
In 2012, the Department of Agriculture, with the Bureau of Agriculture and Fisheries Product Standards (BAFPS) as Technical Secretariat, created a private-public sector Food Defense Technical Working Group (TWG) and conducted a food defense awareness seminar-workshop series to continue the information dissemination initiatives started by APEC. The Food Defense TWG will also provide recommendations on sustainable national initiatives related to food defense.
In 2013, Republic Act (RA) 10536 amended the Meat Inspection Code of the Philippines (RA 9296), to include a division at the National Meat Inspection Service (NMIS) on “Enforcement and Food Defense.” This division shall be responsible for the enforcement of policies against hot meat and adulterated or misbranded meat products, and the protection of meat products from hazardous contaminants.
In view of the national and international concerns on food defense, this guidance document and its annex was drafted for the Philippine food industry, with the purpose of providing a general overview of the food defense concepts, principles, elements and procedures. This document will eventually assist the food industry in complying with future regulatory requirements of importing countries such as the United States and national regulatory requirements such as that of NMIS.
2. Objective and Scope This guidance document is designed to aid farmers/producers and processors of food to understand the basic concepts and principles of food defense and develop a food defense plan within their establishment. Specifically, it aims to:
a. Provide a general overview of food defense; b. Introduce the concept and process of conducting a vulnerability assessment; and c. Assist in developing a basic food defense plan or improving an existing food defense
plan.
This guidance document can be used by all sectors in the food supply chain, including farms particularly those engaged in retailing of fresh produce or minimally processed products, aquaculture facilities, fishing and holding vessels, meat establishments, transportation operations/facilities, processing, packing and warehousing facilities. It is not intended as guidance for retail food stores and food service establishments.
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3. Definition of Terms
For the purpose of this document, the following terms are operationally defined:
Adulteration – refers to an act which leads to the production of food which:
(a) bears or contains any poisonous or deleterious substance that may render it injurious to the health of the public;
(b) bears or contains any added poisonous or deleterious substance in amounts exceeding established maximum limits or standards for good manufacturing practice;
(c) contains in whole or in part filthy, putrid or decomposed substance that is unfit for human consumption;
(d) has been prepared, packed or held under unsanitary conditions; (e) in whole or in part, is the product of a diseased animal which has died through ways
other than slaughter; (f) is in a container having in whole or in part poisonous or deleterious substance; (g) has been intentionally subjected to radiation unless the use of radiation is in
conformity with an existing regulation or exemption; (h) becomes injurious to health because of the omission or abstraction of a valuable
constituent; or if any substance has been substituted wholly or in part, or if damaged or made inferior which has been concealed in any manner; or if any substance has been added thereto or mixed or packed therewith so as to increase its bulk or weight or reduce its strength or to make it appear better or greater than it is;
(i) has not been prepared in accordance with current acceptable manufacturing practice as promulgated by way of regulation; and
(j) uses expired ingredients.
Agent – a biological, chemical, physical or radiological poison, which may be used for intentional or terrorist acts.
CARVER + Shock - a vulnerability assessment tool that can be used to assess and prioritize the vulnerabilities within a system or infrastructure in the food industry. CARVER + Shock is an acronym for six attributes used to evaluate the attractiveness of a target for attack, namely criticality, accessibility, recognizability, vulnerability, effect, recuperability and shock.
Critical Node – specific point in the food supply chain where intentional contamination has the greatest potential to cause economic and public health harm.
Counterfeit - to make imitation of something else with the intent to defraud or deceive.
Diversion - the act of turning something aside from its intended course or purpose.
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Economically Motivated Adulteration - an economic gain or increase in profit resulting from malicious/ fraudulent, intentional addition/substitution of a substance in a product to increase the value of the product or reduce the cost of production.
Food – refers to any substance or product whether processed, partially processed or unprocessed that is intended for human consumption. It includes drinks, chewing gum, water and other substances which are intentionally incorporated into the food during its manufacture, preparation and treatment.
Food Defense - effort to prevent intentional contamination of food products by biological, chemical, physical, or radiological agents that are not reasonably likely to occur in the food supply.
Food Defense Plan - a written plan used to record practices implemented to control/reduce the potential for an intentional contamination event and thereby reduce the overall vulnerability of the assessed food operation.
Food Safety – refers to the assurance that food will not cause harm to the consumer when it is prepared or eaten according to its intended use. It also refers to efforts to protect food products from unintentional and naturally occurring contamination by agents reasonably likely to occur in the food supply.
Food Supply Chain – refers to all stages in the production of food from primary production, post harvest handling, distribution, processing and preparation for human consumption. Preparation is the cooking or other treatments to which food is subjected prior to its consumption.
Food Terrorism - an act or threat of deliberate contamination of food for human consumption with chemical, biological, radionuclear agents for the purpose of causing injury or death to civilian populations and/or disrupting social, economic and political instability.
Hazard - a biological, chemical, radiological, or physical agent, in or condition of, food with the potential to cause an adverse health effect.
Hot Meat – the carcass or parts of a carcass or food animals which were slaughtered from unregistered/unaccredited meat establishments and have not undergone the required inspection. It also includes undocumented, illegally shipped and unregistered carcass and meat products coming from other countries and those that are classified as hot meat by NMIS.
Meat Establishment – premises such as slaughterhouse, poultry dressing plant, meat processing plant, cold storage, warehouse and other meat outlets that are approved and registered by NMIS in which food animals or meat products are slaughtered, prepared, processed, handled, packed or stored.
Mitigation Strategy - science-based procedures, practices, or processes that would be employed to significantly minimize or prevent the vulnerabilities identified in a vulnerability assessment.
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Prevention - actions taken to avoid an incident or to intervene to stop an incident from occurring.
Prioritize - process of using the results of the vulnerability assessment to identify where the reduction of risk is needed and has to be reinforced.
Radiological – involving radioactive materials.
Radionuclear/radionuclide - a chemical substance that exhibits radioactivity.
Recovery - return-to-service activities that industry and government must undertake to assure consumers the products will be safe and secure following an event. The development, coordination and execution of service and site-restoration plans for impacted communities and the reconstitution of government operations and services through individual, private sector, non-government and public assistance programs.
Response - activities that address the short-term, direct effects of an incident (e.g. save and limit loss of life and property, meet basic human needs, execution of emergency plans, apply intelligence to lessen consequences, immunizations, law enforcement operations).
Risk - a function of the probability of an adverse health effect and the severity of that effect, consequential to a hazard(s) in food.
Risk Assessment – a scientifically based process consisting of the following steps: (i) hazard identification, (ii) hazard characterization, (iii) exposure assessment, and (iv) risk characterization.
Sabotage - destruction of the employers property or the hindering of manufacturing by discontented workers/perpetrators.
Tainted - to affect with decay or putrefaction; spoiled; contaminated.
Tampering - to interfere with the food in a harmful way by adding or influencing it with something else.
Vulnerability - a weakness in the design, implementation or operation of an asset or system that can be exploited by an adversary.
Vulnerability Assessment- process of identifying and prioritizing the weaknesses (vulnerabilities) in a food operation. The process is used to identify specific points in the food supply chain where intentional contamination has the greatest potential to cause economic and public health harm.
4. Food Defense Principles and Concepts
There are generally two (2) types of food contamination: (1) unintentional/accidental and (2) intentional as shown in Figure 1. Food defense is the protection of food products from intentional contamination by biological, chemical, physical, or radiological agents that are not reasonably likely to occur in the food supply. Human intervention is the source of
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intentional contamination. Food defense encompasses intentional contamination, economic adulteration, disgruntled employees/sabotage, and counterfeiting/diversion/tampering.
On the other hand, food safety is the protection of food products from unintentional contamination by agents reasonably likely to occur in the food supply. Nature and environment are the main sources of unintentional contamination.
*Denotes mode of human interference with wrongful intent
Figure 1. Spectrum of Food Contamination (USFDA, 2011)
Table 1 summarizes the major differences between food safety and food defense. Differences depend upon the outcome, contaminants/agents used, methods of analysis, prevention and control strategies, decontamination and disposal and communication considerations.
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Table1. Differences Between Food Safety and Food Defense (adopted from Maczka, 2008)
Parameters Food Safety (Unintentional/Naturally Occuring Contamination)
Food Defense (Intentional Contamination)
Outcomes May involve many illnesses but few deaths
Has potential to result in many deaths
Contaminants/Agents a. Biological E. coli O157:H7 in hamburger ,
Salmonella in peanut butter, Listeria monocytogenes in berries
Heat Resistant: Bacillus anthracis (anthrax), Clostridium botulinum Heat Sensitive: Yersinia pestis (plague), Vibrio cholerae
b. Chemical Pesticide residues Cyanide Veterinary drug residues
Heat Resistant: arsenic, rat poison Heat Sensitive: ricin
c. Physical Metal, bone, rodent droppings Nails d. Radiological Plutonium-238, Cesium-137
Method of Analysis Risk assessment Vulnerability assessment Prevention and Control Strategies
Good Agricultural Practices (GAP), Good Animal Husbandry Practices (GAHP), Good Aquaculture Practices (GaqP), Good Hygienic Practices (GHP), Good Manufacturing Practice (GMP), Sanitation Standard Operating Procedures (SSOP), Hazard Analysis and Critical Control Points (HACCP)
Measures or actions taken to reduce the impact of intentional food contamination at vulnerable points in a facility (e.g. personnel and physical security) as well as government or industry-wide measures (e.g. surveillance, outreach training)
Decontamination and Disposal
Can be cooked or sent to landfill. Sanitation procedures should be sufficient for cleaning the facility before resuming food production.
Contaminated food may be hazardous waste. Need to identify decontamination techniques and confirm facility is free of residual contaminant before resuming food production.
Communication Food safety education needed for general public and good risk communication strategies needed by industry and government.
Much public concern, therefore extra consideration is needed when developing risk communication and public education messages
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In recent years, the more prominent type of intentional contamination is Economically Motivated Adulteration (EMA). EMA is the malicious/fraudulent, intentional substitution or addition of a substance in a product to increase the value of a product or reduce the cost of production. EMA can take many forms such as concealment, counterfeiting, unapproved enhancements, mislabelling or substitution. Cases of EMA have been documented worldwide (i.e. melamine in milk, unapproved dyes in spices) which cost the global food and consumer products industry billions of dollars each year. Contributing factors that lead to EMA are the expanding global marketplace with companies having less control over processes. Tighter economic conditions and global food shortages, which create imbalance, can also drive fraudulent activities.
The food supply is a soft target, thus it is difficult to protect. Deliberate contamination could occur at any point in the food supply chain where a variety of people can have access to. These people can include, but not limited to, disgruntled employees, cleaning crew, temporary employees, members of extremist group posing as employees, suppliers, truck drivers, visitors, organized extremist or activist group contractors.
Intentional contamination can cause significant public health consequences and widespread public fear. It can have devastating economic impacts and loss of public confidence in the safety of food and in the effectiveness of government to protect consumers. It also generally disrupts trade and can increase food insecurity.
Food defense supports safety and quality initiatives. It can also reduce cost of security lapses such as theft, vandalism and unethical business practices. Likewise, more buyers are now requiring a Food Defense Plan from their suppliers. A Food Defense Plan also prepares the industry for potential regulatory requirements of both importing and exporting countries.
A Food Defense Program is built upon four (4) major activities - prevention, preparedness, mitigation response and recovery. It requires cross-sectoral collaboration among government, food industry, public health systems, academe and the international community. Government can develop guidance, resources/tools, training programs, research and emergency preparedness. The academe can train new and existing workforce and conduct research. Private industries can share best practices and sample food defense plans. Government and industry can collaborate to develop policies to protect the food supply.
5. Developing a Food Defense Plan A Food Defense Plan is a written plan to reduce the risk of intentional contamination with low-cost or no-cost mitigation measures. It assesses the risk of an attack and identify control measures to minimize the risk. A Food Defense Plan achieves the following:
Helps protect product and customers Maintains a safe working environment for employees Increases establishment preparedness and facilitates appropriate response to an
emergency
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Enhances establishment security Helps protect a company’s bottomline
An effective Food Defense Plan starts with well-implemented prerequisite programs (ex. GMP and SSOP programs). Some information that will be used to create a Food Defense Plan may already exist in a company’s SSOP, Food Recall and HACCP Plans. A Food Defense Plan does not require the development of another HACCP-type document. However, a HACCP plan should not be used as a substitute for a Food Defense Plan because not all of the critical control points will be the same, considering the differences between food safety and food defense.
A functional Food Defense Plan may be developed following these steps:
1. Development of a Food Defense Plan by conducting vulnerability assessment; 2. Implementation of the Food Defense Plan by using the defense measures
identified; 3. Testing the Food Defense Plan by periodic monitoring of the effectiveness of the
defense measures; 4. Periodic assessment of the Food Defense Plan by reviewing the plan and
revising as necessary especially if new risks are discovered; and 5. Maintaining and sustaining the implementation of the Food Defense Plan to
ensure that defense measures are being implemented and are effective.
Prior to developing a Food Defense Plan, a self assessment may be conducted using the sample templates provided by the US Department of Agriculture Food Safety and Inspection Service (USDA- FSIS) for food processing plants (http://www.fsis.usda.gov/wps/wcm/connect/63fb5993-97ac-4414-b5d6-f9c329d13c74/Food_Defense_Plant_Brochure_Slaughter.pdf?MOD=AJPERES) and for meat and poultry slaughtering and processing plants (http://www.fsis.usda.gov/shared/PDF/Food_Defense_Plan.pdf).
5.1 The Basic Food Defense Plan The Basic Food Defense Plan has four (4) base components. Each base component has sub-components as may be applicable to your company. They are as follows: 1. Outside Security 1.1 property perimeter
1.2 building perimeter 1.3 vehicles 2. General Inside Security 2.1 facility/plant 2.2 utilities 2.3 laboratory 2.4 process computer systems
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3. Logistics, Production and Storage Security 3.1 suppliers and vendors 3.2 shipping and receiving 3.3 incoming shipments 3.4 processing and production 3.5 live animals 3.6 outgoing shipments 3.7 returned products/goods 3.8 ice/water/processing aids 3.9 storage and warehouse 3.10 hazardous materials/chemicals 4. Management 4.1 personnel security 4.2 food defense plan A gap assessment should be done to evaluate the facility’s existing food defense measures in the components/areas listed above. Designated personnel who are competent, understand the principles of food defense and have considerable knowledge about the company should conduct the gap assessment. Weaknesses in processes, infrastructures and security measures which provide risks for intentional food contamination are identified. These gaps may allow possible access of persons with ill motives and introduce agents that are hazards to food safety.
The Food Defense Plan Builder is a user-friendly software program developed by the USFDA designed to assist food facilities in the development of their individual Food Defense Plans. The tool utilizes the existing USFDA tools, guidance, and resources on food defense. The Food Defense Plan Builder can be downloaded using this link: (http://www.fda.gov/Food/FoodDefense/ToolsEducationalMaterials/ucm349888.htm).
A Basic Food Defense Plan should detail the basic information about the company and the basic food defense mitigation measures. Records of implementation of these controls should be generated. Monitoring and verification of implementation should likewise be done through reviews, assessments and audits. Food Defense Plans should be tested for effectiveness. Where plans are weak in preventing intentional food contamination, improvements should be carried out. A General Food Defense Plan developed by the USDA –FSIS can be accessed at: http://www.fsis.usda.gov/wps/wcm/connect/99f95182-0c9e-4214-9762-e98197f54ebf/General-Food-Defense-Plan-9-3-09+_2_.pdf?MOD=AJPERES. 5.2 Vulnerability Assessment Vulnerability assessment is the process of identifying and prioritizing the weaknesses (vulnerabilities) in a food operation. It allows evaluation of individual unit operations in the process to identify those that might be at greatest risk. The specific point in the food supply chain where intentional contamination has the greatest potential to cause economic and public health harm is called a critical node.
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In conducting a vulnerability assessment, the following general steps are followed: 1. Sketch a detailed flowchart of the operation, validate for correctness by conducting
a walk-through in the facility; 2. Identify major process, storage and distribution steps; 3. Identify vulnerabilities based on a number of criteria, or depending on the
vulnerability assessment tool applicable; 4. Rank the unit operation/s based on vulnerability scores or risks; and 5. Establish mitigation measures for the unit operation/s most vulnerable to attack.
Vulnerability assessment requires the active participation of all members of the Food Defense Team, with everyone contributing to a democratic decision-making. A Food Defense Team should represent all the departments in the facility and should be multi-functional. The size of the Food Defense Team depends on the size of the facility and availability of resources. While assessment of the contributions of people and physical structure on vulnerability of a commodity to intentional contaminations may be easily done and addressed using the earlier discussed Food Defense Plan Builder tool for gaps assessment, vulnerability assessment of the food processing operation entails a more rigorous process, tracing each step of the process flow, and including all sub-processing facilities found within the same area. For example, if a particular ingredient is manufactured in the same facility where a product is processed, the process flow for that particular ingredient should similarly be subjected to vulnerability assessment. While a technology-intensive and fully-automated process may have few or no vulnerability, a labor-intensive and highly manual process exposed to human contact may have too many. Aside from identifying the vulnerabilities of the process, there is therefore a need to determine the relative importance of the identified weaknesses, so the Food Defense Team can prioritize the more significant (or more vulnerable) steps that need immediate mitigation. Vulnerability in a process flow is a weakness in any of the unit operations where intentional contamination can take place. These operations include handling and storage of raw materials, ingredient mixing, finished product packaging, and dispatch and distribution. 5.2.1. Facilitators of Intentional Contamination Intentional contamination may be facilitated by agents such as (1) people, (2) process and procedure, and (3) physical structure of the facility. People include in-house personnel who have constant direct access to the process flow, delivery personnel who can intentionally introduce hazards to raw materials or finished products during transport, contract cleaners and pest control service providers who have access to the processing facility before, during and/or after food processing; and visitors who may have limited time to introduce contaminants but may successfully do the job if there are weaknesses in the security in the processing area.
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The nature of a process step or procedure can also affect the ease of introducing contaminations to the food product. A highly manual unit operation that requires long contact time with a food handler is significantly more vulnerable to intentional contamination, compared to a unit operation that is fully automated and with minimal human intervention. Furthermore, a unit operation that is thoroughly and uniformly mixed, and involves large volumes of food materials, is an ideal target for intentional contamination, as successful hazard introduction may not be easily detected, and may result to more consumer exposure, respectively. Finally, the physical structure of the food processing area may contribute to vulnerability of the product towards intentional contamination. Physical barriers preventing entry to the processing area include doors and windows, vents, fences and gates. Even light and CCTV installations within and outside the processing area can influence product vulnerability to attacks. 5.2.2. Factors Contributing to Unit Operation Vulnerability In general, factors that contribute to high vulnerability and accessibility are the following:
1. Large batch size. Successful contamination of large batch size may similarly result in a large number of population that will consume the tainted product.
2. Uniform mixing. A unit operation that involves constant, uniform mixing is an attractive point of attack since the contaminant shall be homogenously distributed within the food system, ensuring large number of tainted products.
3. Serving size. A product with a serving size small enough to be consumed in one sitting, containing harmful dose of an agent, is ideal for an attack since it will ensure maximum harm to consumers.
4. Short shelf-life. A product with short shelf-life is preferred since these are immediately consumed in large numbers that could similarly result in large number of affected consumers.
5. Ability to disguise the contaminant. A contaminant not easily detectable in the food
system is ideal for an attacker.
6. High impact consumer such as children and elderly. Successful attack of products consumed by children and elderly shall result in greater damage to public morale.
7. Lack of processing/preparation steps to inactivate or reduce the harmful agent. Some biological and chemical agents may easily be inactivated by heating and other processing steps.
USFDA conducted vulnerability assessments for selected food products/categories. Vulnerability assessment results showed that common vulnerabilities exist regardless of
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particular food product. Common vulnerabilities can be organized into several broad activity types:
1. Activity Type I (coating, mixing, grinding and rework) - effect of these steps would be the even distribution of a contaminant
2. Activity Type II (ingredient staging, ingredient preparation and ingredient addition) – open process steps with access to product stream
3. Activity Type III (bulk liquid receiving and bulk liquid loading) – high probability of uniform mixing
4. Activity Type IV (bulk liquid holding and non-liquid holding and surge tanks) – tanks are often agitated to prevent separation; often in isolated areas of facility
5.2.3. The CARVER + Shock Tool for Vulnerability Assessment One of several tools that can be used in the identification and prioritization of process-related vulnerabilities is the CARVER + Shock program. In this document, this tool shall be used as a model due to its systematic evaluation of potentially vulnerable unit operations. Poore (2010) described that the CARVER + Shock has been adapted from the military-based CARVER program, which was originally developed as a targeting tool for the US Special Operations Forces to thoroughly analyze enemy infrastructure and identify critical nodes. In military term, a critical node or target critical damage point is an element, position or command and control entity, which when disrupted immediately degrades the ability of the enemy to conduct combat operations. Hence in the food processing environment, a critical node is that particular unit operation that when successfully attacked, could result in significant public health and economic impact.
CARVER is an acronym for the six attributes namely, “criticality”, “accessibility”, “recognizability”, “vulnerability”, “effect”, and “recuperability”. Each of these attributes can be objectively scored on a scale of 1 (least risk) to 10 (greatest risk). Refer to Annex 1 for the matrices for the systematic evaluation of these attributes. Comparisons of combined scores from all seven (7) attributes of a unit operation in a process flow allows the Food Defense Team to identify critical nodes that need immediate mitigation.
1. Criticality measures the economic and public impact of an attack to the food system. 2. Accessibility refers to the ease of physical access and egress from the target food
system or unit operation. 3. Recognizability refers to the ease of recognizing the target unit operation. 4. Vulnerability measures the ease of accomplishing the intentional contamination of a
food system. 5. Effect measures the economic impact of an attack from loss in production. 6. Recuperability assesses how a particular manufacturing system recovers from an
attack, should it survive. 7. Shock assesses the health, economic and psychological impacts of the attack.
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5.3 Mitigation Strategies/Measures Mitigation strategies are preventive measures the companies may choose to implement in an effort to better protect the facility, personnel and operations from identified vulnerabilities. Mitigation strategies could reduce product exposure, unseen personnel movement, accessibility for direct or indirect contamination of food and ease of addition of contaminants/agents. The USFDA mitigation strategies database can be accessed in: http://www.accessdata.fda.gov/scripts/fooddefensemitigationstrategies/. USDA FSIS has a similar database for the meat, poultry, and processed eggs industries: http://www.fsis.usda.gov/wps/portal/fsis/topics/food-defense-defense-and-emergency-response/preparation-and-prevention/guidance-documents/risk-mitigation-tool/ct_index 6. Resource Requirements The basic requirements may already be in place but are not intentionally used for food defense issues. These are relatively low-cost investment and readily available such as:
signages padlocks identification cards logbooks/forms/time logs color-coded working outfits additional lighting roving guards alarm system CCTV perimeter fence
7. Training Tools and Resources Training program should be defined to ensure that personnel are aware of the Food Defense System and understand their responsibilities in its effective implementation. Several training tools were developed by the USFDA that may be used as reference. Employees FIRST is a USFDA training program designed to educate frontline workers on the first line of defense in preventing intentional contamination of the food supply. FIRST is the acronym for five (5) rules on food defense:
Follow company food defense plans Inspect your work area and surrounding areas Recognize anything out of the ordinary Secure all ingredients, supplies and finished product Tell management if you notice anything unusual or suspicious
ALERT initiative is a training program intended to raise awareness of state and local government agencies and industry representatives on food defense issues and
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preparedness. It applies to all aspects of the farm-to-table continuum. It identifies five (5) key food defense points:
A- How do you ASSURE that the supplies and ingredients you use are from safe and secure sources?
L- How do you LOOK after the security of the products and ingredients in your facility?
E- What do you know about your EMPLOYEES and people coming in and out of your facility?
R- Could you provide REPORTS about the security of your products while under your control?
T- What do you and who do you notify if you have a THREAT on issue at a facility, including suspicious behavior?
USFDA developed Food Defense 101 training, a vulnerability assessment software tool (CARVER+Shock), a mitigation strategies database, the Food Related Emergency Exercise Bundle (FREE-B) kit, and a food defense plan builder, all are available online, and can be downloaded for free. The following Food Defense Industry Guidance documents have likewise been developed by USFDA for the following stakeholders which is available in the USFDA website (http://www.fda.gov/fooddefense):
Food Producers, Processors and Transporters Importers and Filers Retail Food Stores and Food Service Establishments Dairy Farms, Bulk Milk Transporters, Bulk Milk Transfer Stations and Fluid Milk
Processors Similarly, FSIS of the USDA, developed Food Defense Guidance for food processors, importers, transporters, and distributors that can be accessed at http://www.fsis.usda.gov/wps/portal/fsis/topics/food-defense-defense-and-emergency-response
Food Defense Guidelines for Slaughtering and Processing Establishments, Warehouse and Distribution Centers
FSIS Safety and Security Guidelines for the Transportation and Distribution of Meat, Poultry and Egg Products
Guidelines for the Disposal of Intentionally Contaminated Food Products and the Decontamination of Food Processing Facilities
8. Assessment of Effectiveness, Audits and Corrective Actions The facility should establish internal quality audit to verify the effectiveness of the Food Defense Plan. Internal audit will help give objective evidence/proof that the Food Defense Plan is carried out effectively in the facility. Records of internal audit and noted non-conformities shall be given attention by the management for continuous improvement, assess capability of facility processes, etc. Audit findings will serve as evidence or
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benchmark data for the effectiveness of the policy, procedure or requirement. Verification of the corrective actions should be made to ensure conformity to the requirements. 9. Food Defense Documents and Records Some recommended documents and records to effectively carry out the Food Defense Plan include the following: Documents
Vicinity Map Floor Plan Emergency Evacuation Plan Crisis Management/Contingency Plan Human Resource (HR) Training Program Traceability and Recall Program Personnel Security Measures
Records
Hourly Security Roving Report Training Attendance Record Daily Attendance Record Visitor/Suppliers Entry Slips Loading/Unloading Inspection Report Product Recall Exercise Form Chemical/Hazardous Material Control Log Food Defense Plan Review Form Record of Food Defense Plan Testing CCTV Recordings
10. Annex
Annex 1 –Sample Vulnerability Assessment Exercise
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Annex 1: Sample Vulnerability Exercise
Milk in Gable-Top Cartons: A Sample Vulnerability Assessment Exercise
(Adapted from Poore, 20101)
The following is an example of a vulnerability assessment (VA) exercise that uses the CARVER +
Shock as a VA tool. As previously discussed in the Food Defense Guidance for the Industry of the
Bureau of Agriculture and Fisheries Product Standards, VA is an important part of coming up with a
Food Defense Plan since it allows the processor to determine which particular unit operation/s or
step/s (or node/s) in the process is/are most vulnerable to attack. This example borrowed from
Poore (2010) uses one of the many VA tools available. The choice for CARVER + Shock is due to its
simplicity and the systematic method with which each of the unit operations in a particular process
may be evaluated.
The following is a step-by-step example that can be used to guide the readers to conduct their
own VA, in the development of their own Food Defense Plans.
1. Assembling the Food Defense Team
Before conducting the VA, it is essential that a Food Defense Team be constituted. A company
may already have a Food Safety Team with members that can also be recruited in the Food Defense
group. The team should include skilled and educated personnel with working knowledge on
microbiology, chemistry, food science, engineering, etc. Since personnel are significant agents of
intentional attack, which is the concern of Food Defense, the Human Resource manager should also
be included in the team. Apart from these professionals, it will be best to include trusted hourly
personnel who are most familiar with the unit operations in the processing line.
2. Conducting the Analysis
2.1. Determine the Parameters
In conducting the VA, the following questions should first be addressed, as the answers to the
following shall drive entire analysis:
1. Determine what are you trying to protect, and from what or whom.
2. What is the food you are trying to protect?
3. What is the concern – foodborne illness, death, or economics?
4. Who or what does the attacker look like? A politically motivated outside person, a disgruntled employee, or a disgruntled employee with ties to outside person(s).
1 Poore, D. (2010). Protecting Your Food Supply: A Practical Approach. Food Safety Magazine, February-March
2010. http://www.foodsafetymagazine.com/article.asp?id=3536&sub=sub1
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5. What agent will be used in the scenario/attack? This is perhaps the most difficult aspect of the analysis. Careful consideration should be given to the whole process in choosing the appropriate agent. Choose the worst case; assume that successful attack is highly possible.
Once these questions have been answered, do not be tempted to change them in the middle of the VA. If the team decides to do so, they should start from the beginning of the analysis.
2.2. Develop a Flowchart
In conducting a VA, development of a well-documented diagram or flowchart of the various unit operations in a particular process is prerequisite. The flowchart should include all subsystems, and complex pats of the system. There may be sub-processing in the facility that produces ingredients or parts of the finished food product. It is important to include even the smallest detail in the flowchart e.g., holding time and temperature, and elements such as kettles, hoppers, small vats, liquefiers, fillers, ingredient injectors, small bins, etc. The following is an example of a detailed process flowchart for pasteurized milk (Kennedy, 2011). The final flow chart should be checked for consistency and accuracy by conducting a walk-through in the processing facility.
Aside from the details found in the flowchart, the Food Defense Team should have access to other information such as those related to product distribution and sales, consumers, market share in the areas where the product is distributed, even Good Manufacturing Practices (GMP) implemented in the processing facility.
Figure 1. An example of a detailed flowchart/process diagram for pasteurized milk (Kennedy, 2011)
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2.3. Scoring and Evaluation
After each of the unit operations in the process flow diagram has been checked and validated,
the VA can proceed by evaluating each unit operation using the CARVER + Shock tool. In the
CARVER + Shock method for VA, each unit operation or node is systematically evaluated and scored
(using a scale of 1-10) for criticality, accessibility, recognizability, vulnerability, effect,
recuperability, and shock. The rating given to each of the nodes should be based on team decision.
The following is an example of a step-by-step CARVER + Shock evaluation of a node in a pasteurized
milk processing facility.
i. Criticality. A unit operation or node is critical when an agent can be introduced and cause significant health or economic impact. In evaluating Criticality, always consider successful introduction of the agent. The Criticality may be evaluated by first filling up the following worksheet.
Worksheet 1. Worksheet for the determination of Criticality value of a particular unit
operation/node
As an example, consider a fluid milk processing facility in Figure 1, making 8-ounce,
gable-top cartons, utilizing a pasteurized silo with constant agitation, holding 10,000
gallons of milk. Conducting a VA for this plant will involve subjecting all unit operations
or nodes in the process flowchart (Figure 1) to CARVER + Shock evaluation.
For this particular example, consider the following. These information shall be used in
the entire CARVER + Shock analysis.
i. Pasteurized silo as the successfully attacked unit operation/node
ii. Ricin as the agent of attack, with a harmful level of 2.0 mg per serving
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iii. 87% of all the units (8 oz. milk in carton) were sold before the attack was discovered, and the warning came out
iv. 50% of the sold units were consumed, one unit was consumed by one person
v. The mortality rate is 50%
vi. Product distribution is through retail outlets in areas near colleges or universities
vii. The market share for this company’s milk is 75% in the area
viii. The plant that was attacked is one of five in the corporation. There are three fluid milk plants, one ice cream plant, and one cultured products plant
Using these information, a filled worksheet for Criticality will be as shown in
Worksheet 2. Based on the analysis in Worksheet 2, refer to Table 1 for Criticality
scoring.
Worksheet 2. Filled worksheet for the determination of Criticality value of a particular unit
operation/node
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Table 1. Criticality score scale
Criticality Criteria Score
Loss of more than 10,000 lives OR loss of more than $100 B.
(*Note: If looking on a company level, loss of > 90% of the total economic value for
which you are concerned.)
9-10
Loss of life is between 1,000 and 10,000 OR loss of $10B to $100B.
(Note: If looking on a company level, loss of between 61% and 90% of the total
economic value for which you are concerned.)
7-8
Loss of life is between 100 and 1,000 OR loss of $1B to $10B.
(Note: If looking on a company level, loss of between 31% and 61% of the total
economic value for which you are concerned.)
5-6
Loss of fewer than 100 lives OR loss of $100M to $1B.
(Note: If looking on a company level, loss of between 10% and 30% of the total
economic value for which you are concerned.)
3-4
No loss of life OR loss of less than $100M.
(Note: If looking on a company level, loss of <10% of the total economic value for
which you are concerned.)
1-2
*Note: The economic loss could depend upon different factors. If your facility is part of a large multinational
organization, the financial impact may not be as severe when compared to a regional organization that has a
couple of local plants.
Note that the Criticality scale should not imply that a certain loss of life is ‘acceptable,’
but should be used to determine the impact of an attack on certain nodes within the
process. Therefore, based on the Criticality worksheet analysis in Worksheet 2, the
attack will be very successful, and based on the score scale in Table 1, the Team should
give this unit operation/node (pasteurized silo) a score of 10.
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ii. Accessibility. To evaluate and give Accessibility score to the unit operation/node in question, the Food Defense Team should have information on the location of that particular unit operation, as well as the environmental conditions to which the operation is exposed. For example, in the unit operation earlier evaluated for Criticality, the following information is needed to continue with the VA.
i. The pasteurized silos are in the upper level of the plant without much traffic, but workers pass through this area to access the pasteurizer.
ii. The lighting is kept dim to save energy, and there are no cameras in the area.
iii. The silos are filled from the top and have vents to the side of the fill tubes that are accessible.
iv. There is an attached ladder on the front of the tank, which allows access to the fill tubes and vents.
v. The tanks are only required to be washed every 24 h and can be filled multiple times between washings.
Based on these information, assess the Accessibility of the unit operation/node; and give
a score based on the scale presented in Table 2. Based on the description, the tanks
would be fairly accessible. Proper exclusion practice is not practiced, hence everyone in
the plant could have access to it. However, attacking the silo may not very easy since the
tanks are elevated and an attacker climbing the ladder on the silo will certainly be
noticeable. Based on the scale in Table 2, the team can give it an Accessibility score of 7.
iii. Recognizability. The following additional information shall help the team assess the Recognizability of the unit operation/node in question.
i. The tanks are made of stainless steel, located close to the pasteurization system, and are very large.
ii. Even untrained person shall easily identify the tanks.
iii. A photograph would be adequate to show what a target should look like.
Based on these information, assess the Recognizability of the unit operation/node; and
give a score based on the scale presented in Table 3. The Team can give this unit
operation a Recognizability score of 8.
iv. Vulnerability. The following additional information shall help the Team assess the Vulnerability of the unit operation/node in question.
i. Each of the tanks has a ladder in front of it, and a person has to climb the ladder to introduce the agent.
ii. At the top of the tank, 6 feet from the floor of the platform is a 2.5-inch filling port.
iii. The tanks are not labeled to indicate that they contain pasteurized product, but ‘everyone’ knows the tanks are for pasteurized milk.
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Table 2. Accessibility score scale
Accessibility Criteria Score
Easily Accessible (e.g. target is outside building and there is no perimeter fence).
Limited physical or human barriers or observation. Attacker has nearly unlimited
access to the target. Attack can be carried out using moderate to large volumes of
contaminant without undue concern over detection. Multiple sources of information
about the facility and the target are readily available.
9-10
Accessible (e.g. target is inside building but in an unsecured part of the facility).
Human observation and physical barriers limited. Attacker has access to the target for
an hour or less. Attack can be carried out with moderate to large volumes of
contaminant, but requires the use of stealth. Only limited specific information is
available on the facility and the target.
7-8
Partially Accessible (e.g. inside building in a relatively unsecured but busy part of the
facility). Under constant possible human observation. Some physical barriers may be
present. Contaminant must be disguised, and time limitations are significant. Only
general, non-specific information is available on the facility and the target.
5-6
Hardly Accessible (e.g. inside building in a secured part of the facility). Human
observation and physical barriers with an established means of detection. Access
generally restricted to operators or authorized persons. Contaminant must be
disguised and time limitations are extreme. Limited general information available on
the facility and the target.
3-4
Not Accessible. Physical barriers, alarms, and human observation. Defined means of
intervention in place. Attacker can access target for less than 5 minutes with all
equipment carried in pockets. No useful publicly available information concerning the
target.
1-2
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Table 3. Recognizability score scale
Recognizability Criteria Score
The target is clearly recognizable and requires little or no training for recognition
9-10
The target is easily recognizable and requires only a small of training for recognition
7-8
The target is difficult to recognize or might be confused with other targets or target components and requires some training for recognition
5-6
The target is difficult to recognize. It is easily confused with other targets or components and requires extensive training for recognition
3-4
Notice that it may not be easy to add approximately 320 g ricin (Worksheet 1) through a 2.5-inch port, especially considering that the port is an access point to the pasteurizer for other employees as well. If an attacker is detected, an employee might ask why the individual is adding something to the port. To assess the Vulnerability of the unit operation/node in question, refer to Table 4 for score scale. The Team could give this unit operation an Vulnerability score of 6.
Table 4. Vulnerability score scale
Vulnerability Criteria Score
Target characteristics allow for easy introduction of sufficient agents to achieve aim.
9-10
Target characteristics almost always allow for introduction of sufficient agents to achieve aim.
7-8
Target characteristics allow 30% to 60% probability that sufficient agents can be added to achieve aim.
5-6
Target characteristics allow moderate probability (10% to 30%) that sufficient agents can be added to achieve aim.
3-4
Target characteristics allow low probability (<10% ) that sufficient agents can be added to achieve aim.
1-2
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v. Effect. The following additional information shall help the Team assess the Effect to the company of the successful attack of the unit operation/node in question.
i. The plant is a well-known entity in the area, producing a regional, name-brand product. It has 75% market share for the product that it sells within the region.
ii. The plant would be shut down, and the milk sales would drop to zero.
iii. Other product sales will also suffer greatly.
Assess the Effect and give an appropriate score by referring to Table 5. Based on these
information, the Team could easily give a score of 10.
Table 5. Effect score scale
Effect Criteria Score
Greater than 50% of the system’s production impacted
9-10
25-50% of the system’s production impacted
7-8
25-50% of the system’s production impacted
5-6
1-10% of the system’s production impacted
3-4
Less than 1% of the system’s production impacted
1-2
vi. Recuperability. As described, this scenario is going to be a major disaster to the plant. The concern is to estimate how long it will take for the plant to recover the publicity associated with the contamination. Also, consider how long it will take to clean the facility (should it survive), and how challenging it may be to regain consumer confidence and market share.
Based on the fact that there were so many deaths, it is highly unlikely that the plant or even
the entire organization will ever recover. Referring to Table 6 for score scale, the Team can
give this unit operation a score of 10.
vii. Shock. This attribute is a combined evaluation of individual emotions. Shock is considered on a national level. It is especially dramatic if the event occurs on or close to a holiday, or
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affects children, and the elderly. Consider all of the emotional factors when evaluating Shock. In evaluating Shock, ask, “How would I feel if this were to happen?”
The number of deaths in this particular unit operation/node being evaluated is high, and
could easily be given a score of 10 (Table 7). Consider that it would affect young adults
going to a college or a university. Furthermore, because the product is sold at the retail
level, the incident would affect individuals of all ages. A serving size of 8 oz. could also be
targeted because smaller children also consume this product, as well as elderly who do not
drink a lot of milk.
Table 6. Recuperability score scale
Recuperability Criteria Score
> 1year
9-10
6 months to 1 year
7-8
3-6 months
5-6
1-3 months
3-4
< 1 month
1-2
3. Consolidate Scores and Identify Critical Nodes
After evaluating all seven (7) CARVER + Shock parameters, consolidate all the scores for each of
the unit operations/node evaluated (Worksheet 3). One can expect several nodes for a complex
processing operation with multiple sub-processes; and fewer nodes for a straightforward
process. Compare the summed scores of all nodes to identify the critical node/s, which can be
prioritized in the establishment of mitigation measures.
CARVER + Shock is a valuable tool that may be used to help protect the food chain ‘from farm to
fork.’ When completing the analysis process, do not forget to consider people, visitors,
contractors, vendors, haulers, records, equipment and supplies, interior and exterior factors, and
all processes from incoming and outgoing products. It has been observed – wisely – that ‘food at
rest is food as risk.’
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Table 7. Shock score scale
Shock Criteria Score
Target has major historical, cultural, religious, or other symbolic importance. Loss of
more than 10,000 lives. Major impact on sensitive subpopulations, such as children
or the elderly. National economic impact more than $100 billion.
9-10
Target has high historical, cultural, religious, or other symbolic importance. Loss of
between 1,000 and 10,000 lives. Significant impact on sensitive subpopulations,
such as children or the elderly. National economic impact between $10 billion and
$100 billion.
7-8
Target has moderate historical, cultural, religious, or other symbolic importance. Loss
of between 100 and 1,000 lives. Moderate impact on sensitive subpopulations, such as
children or the elderly. National economic impact between $1 billion and $10 billion.
5-6
Target has little historical, cultural, religious, or other symbolic importance. Loss of
fewer than 100 lives. Small impact on sensitive subpopulations, such as children or
the elderly. National economic impact between $100 million and $1 billion.
3-4
Target has little historical, cultural, religious, or other symbolic importance. Loss of
fewer than 100 lives. Small impact on sensitive subpopulations, such as children or
the elderly. National economic impact between $100 million and $1 billion.
1-2
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Worksheet 3. Summary sheet for scoring unit operations/nodes across CARVER + Shock
attributes
References PNS/BAFPS 134:2014
http://medical-dictionary.thefreedictionary.com/radionuclide
http://www.accessdata.fda.gov/scripts/fooddefensemitigationstrategies/
http://www.fda.gov/Food/FoodDefense/ToolsEducationalMaterials/ucm349888.htm
http://www.foodsafety.gov/
http://www.fsis.usda.gov
http://www.fsis.usda.gov/shared/PDF/Food_Defense_Plan.pdf
http://www.fsis.usda.gov/wps/portal/fsis/topics/food-defense-defense-and-emergency-response
http://www.fsis.usda.gov/wps/portal/fsis/topics/food-defense-defense-and-emergency-response/preparation-and-prevention/guidance-documents/risk-mitigation-tool/ct_index http://www.fsis.usda.gov/wps/wcm/connect/63fb5993-97ac-4414-b5d6-f9c329d13c74/Food_Defense_Plant_Brochure_Slaughter.pdf?MOD=AJPERES
http://www.fsis.usda.gov/wps/wcm/connect/99f95182-0c9e-4214-9762-e98197f54ebf/General-Food-Defense-Plan-9-3-09+_2_.pdf?MOD=AJPERES.
http://www.meathaccp.wisc.edu/additional_info/assets/Guide%20Food%20Processing.pdf
http://www.merriam-webster.com
http://www.merriam-webster.com/dictionary/diversion
http://www.thefreedictionary.com/radiological
http://www.thefreedictionary.com/tainted
http://www.who.int/foodsafety/publications/general/en/terrorist.pdf www.fda.gov/fooddefense
Mackza, Carol PhD. 2008. Food Safety vs. Food Defense: Differences and Similarities: Protecting the Middle East Supply from Intentional Contamination. Presented in Cairo, Egypt last 29-31 January 2008.
Poore, D. (2010). Protecting Your Food Supply: A Practical Approach. Food Safety Magazine, February-March 2010. (http://www.foodsafetymagazine.com/article.asp?id=3536&sub=sub1 )
Republic Act 10536 - An Act Amending Republic Act 9296, Otherwise Known as the Meat Inspection Code of the Philippines. 15 May 2013.
Republic Act 10611 – An Act to Strengthen the Food Safety Regulatory System in the Country to Protect Consumer Health and Facilitate Market Access of Local Foods and Food Products, and for Other Purposes. 28 August 2013.
Republic Act 9296 - Meat Inspection Code of the Philippines and Its Implementing Rules and Regulations. October 2005.
Department of Agriculture (DA)
Bureau of Agriculture and Fisheries Product Standards (BAFPS)
Core Technical Working Group
Sonny Angelo A. Argao M Lhuillier Food Products, Inc.
Josephine A. del Mundo
Universal Robina Corporation
Alonzo A. Gabriel PhD University of the Philippines Diliman
Dulce M. Flores, PhD
University of the Philippines Mindanao
Emeliza C. Lozada University of the Philippines Mindanao
Claire T. Dinio, Marielle A. Aimee Malinao and Karen Joan A. Figuracion
Royal Breadhouse
Members - Department of Agriculture (DA)
1. Rubina O. Cresencio, DVM - Bureau of Animal Industry (BAI) 2. Orlando C. Ongsotto, DVM - National Meat Inspection Service (NMIS) 3. Clarita M. Sangcal, DVM - NMIS 4. Marvin B. Vicente, DVM – NMIS 5. Consuelo C. Baltazar/Timothy Joseph S. Lazaro - Bureau of Fisheries and Aquatic
Resources (BFAR) 6. Simeona E. Regidor –BFAR 7. Dennis E. Tiotangco - BFAR 8. Sonia T. Hernandez - Bureau of Plant Industry (BPI) 9. Lucita M. Falcatan/Josephine T. Nieva - Philippine Coconut Authority (PCA) 10. Dina B. Masa – PCA 11. Marcelino M. Guevarra - Sugar Regulatory Administration (SRA) 12. Magdalena D. Palanca – SRA 13. Jean Nanette C. Sumagaysay -SRA 14. Alberto R. Cariso Jr./Carmelita V. Alkuino - Food Development Center (FDC) 15. Judith A. Platero – National Dairy Authority
Members - Department of Health (DOH)
16. Ma. Theresa C. Cerbolles - Food and Drug Administration (FDA) 17. Jesusa Joyce N. Cirunay- FDA 18. Minda G. Villa, M.D./Josefina P. Giliberte - Bureau of Quarantine (BOQ) 19. Richard B. Laroya - BOQ 20. Shirley F. Rillo/Jelene N. Jose – BOQ
Secretariat
Chairperson Karen Kristine A. Roscom Chief Science Research Specialist Standards Development Division BAFPS- DA Member Charlie T. Palilio Research Assistant I Standards Development Division BAFPS-DA
your partner in product quality and safety
BUREAU OF PRODUCT STANDARDS
3F Trade and Industry Building 361 Sen. Gil J. Puyat Avenue, Makati City 1200, Metro Manila, Philippines
T/ (632) 751.3125 / 751.3123 / 751.4735 F/ (632) 751.4706 / 751.4731
E-mail : [email protected] www.dti.gov.ph
