Red alert: vigilance the key to ensuring security of food supply

In the wake of the Sept. 11, 2001, attacks, subsequent anthrax letter scares and the constantly changing color-coded terror alert levels, many operators are wondering how vulnerable they are to a malicious biological attack.

Salmonella, E. coli, botulinum and shigella can cause food-borne illness when food is not prepared properly or when it is contaminated by improper handling. They also can be introduced deliberately as bio-weapons into a food or water supply to cause harm. In addition, other hazardous materials, such as pesticides and cleaning agents commonly found in many food-related facilities, also can be used for deliberate contamination.

As part of federal emergency funding after the Sept. 11 attacks, the U.S. government funneled additional resources for the U.S. Department of Agriculture to strengthen bio-security. While that funding helps to ensure that food from processors is safe, it is unlikely that regulatory action can prevent an isolated attack at a retail location. The only way to prevent that is for individual operators to take charge and responsibility for increasing food safety and security in their establishments.

It's fortunate that the U.S. Department of Agriculture and the U.S. Food and Drug Administration have issued guidelines for operators. When coupled with an HACCP-based, common-sense approach and strong monitoring and surveillance on the part of an operator's management and employees, those guidelines minimize operators' risks. Even the smallest operator can apply standard operating procedures, or SOPs, for food safety, employee and management training, strong vendor relationships, a crisis management plan, and physical facility readiness toward ensuring that food under their control will not be subject to tampering or other malicious, criminal or terrorist actions.

Management: The buck starts here. Ideally, operators already should have a food safety and security program in place. If that's not so, now is the time to conduct an assessment of food security procedures and operations to identify areas or activities where threats might occur and to increase security in those areas.

A key step in any food safety and security plan is to assign primary food security responsibility to one individual and to make certain that the individual is fully educated in the requirements of the assignment. The individual should be in charge of daily checks of key areas as well as maintaining an internal organizational checklist. Be sure to assign a backup for the individual for round-the-clock coverage.

Management also needs to maintain an environment of total control for the workforce. Know who is on duty and who should be in the building at any given time. Daily activities--including those conducted by contract workers, support staff and volunteers--should be supervised.

Management also should be encouraged to have a crisis and product recall plan in place and to ensure that suppliers also have recall programs in place. Have a step-by-step plan for responding to evidence of tampering or other criminal or terrorist actions; the plan should include identifying, isolating and securing affected products.

Also, develop an internal communications system to inform and update staff as well as an external communications system for communicating with the public. Regularly conduct emergency drills and post evacuation procedures prominently.

Employees: Use prehire screening programs to check the immigration status and criminal background of all applicants, without regard to the applicant's race, religion or ethnic background. Pay special attention to contract, seasonal and temporary employees. Require employees to wear uniforms and other identification. Collect IDs as well as keys and access cards upon termination or resignation. Restrict employees' personal items to specified areas, away from food storage and production areas.

Incorporate food security awareness into initial and ongoing training for all employees and volunteers. Employees should be encouraged to be alert and to investigate or notify management of anything that seems suspicious or out of the ordinary. Be sure that employees know how and where to report potential threats.

Suppliers and vendors: Require suppliers and vendors to provide documentation on their food safety and security practices, including provisions for rapid notification of product recalls. Restrict all deliveries to scheduled times. Inspect inbound and outbound vehicles. When inbound vehicles arrive, immediately reconcile deliveries with what was ordered. Investigate missing items as well as any "additional" items that were not ordered. Inspect all incoming products for signs of tampering, contamination or damage and reject any suspicious food. That is good practice in general, not just in terms of food security.

Physical facility: Vulnerable areas, such as where food is handled and stored and employee lockers, should have restricted entry. Establish clear zones: for the public, for employees and for supplier representatives, such as truck drivers and delivery people. Protect the perimeter with secure doors and a program that accounts for all keys.

Keep an accurate inventory of all equipment, food, ingredients, utensils, chemicals and supplies. It is particularly important to develop a system to log and track hazardous materials, such as cleaning chemicals, and investigate promptly if anything is missing. Closely monitor food holding and serving areas, especially open display areas, such as salad bars. Never leave food unsecured or unattended at any stage of delivery, storage, preparation or service.

In conclusion, by taking the necessary steps to implement a tightly controlled security plan at your facility, you can guard against deliberate contamination of the food supply within your operation.

For more information and guidance, visit the USDA's Web site at www.usda.gov or the FDA Center for Food Safety and Applied Nutrition at www. cfsan.fda.gov.

Robert Strong, Ph.D., is vice president of quality management for The Steritech Group Inc., one of the premier providers o f food safety and environmental hygiene services in North America. For more information visit www.steritech.com.

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