Today the National Counterintelligence and Security Center (NCSC) and the Department of Defense’s Center for Development of Security Excellence (CDSE) published a risk mitigation guide to help organizations in the food industry understand insider risks, establish insider risk programs, and develop mitigation strategies. The “Insider Risk Mitigation Programs: Food and Agriculture Sector Implementation Guide” was developed in collaboration with federal partners and stakeholders, including the FDA.
The Fall edition of the 2021 Food Safety Consortium Virtual Conference Series will feature an episode on Food Defense Strategies | Register Now“Organizations in the food and agriculture sector play a critical role in protecting public health and safety, as well as U.S. economic and national security,” said NCSC Acting Director Michael Orlando in an NCSC press release. “This guidance is designed to help these entities create effective programs to deter, detect, and mitigate potential insider threats before they can cause harm.”
The guide includes links to federal resources in food and agriculture, and case studies concerning food adulteration, IP theft and active shooter incidents that were carried about by insiders. Any organization can be exposed by an insider threat, which is a person who has authorized access and uses it to commit harm to the organization. “Those with authorized access to facilities, personnel, or information can include employees, vendors, partners, suppliers, or others,” according to NCSC. “Most insider threats exhibit risky behavior prior to committing negative workplace events. If identified early, many insider threats can be mitigated before harm to the organization occurs.”
Insider threats can target food organizations through food adulteration, food fraud, theft and workplace violence.
Current events and external threats to food and agriculture
Case studies and lessons learned in food defense
Insider threat mitigation
Resources for food and beverage manufacturers
Featured speakers include Jason Bashura, PepsiCo (session moderator); April Bishop, Treehouse Foods; Ben Miller, The Acheson Group; Frank Pisciotta, BPS, Inc.; Joel Martin, Cargill; James Nasella, Tate & Lyle; Scott Mahloch, Cassandra Carter, and Kevin Spradlin, FBI; Rob Odell – National Insider Threat Task Force; Sarah Miller – Carnegie Mellon/CERT; Rebecca Morgan, Center for the Development of Security Excellence
The event begins at 12 pm ET on Thursday, November 12. Haven’t registered? Follow this link to the 2020 Food Safety Consortium Virtual Conference Series, which provides access to 14 episodes of critical industry insights from leading subject matter experts! We look forward to your joining us virtually.
The USDA estimates that foodborne illnesses cost more than $15.6 billion each year. However, biological contamination isn’t the only risk to the safety and quality of food. Food safety can also be compromised by foreign objects at virtually any stage in the production process, from contaminants in raw materials to metal shavings from the wear of equipment on the line, and even from human error. While the risk of foreign object contamination may seem easy to avoid, in 2019 alone the USDA reported 34 food recalls, impacting 17 million pounds of food due to ‘extraneous material’ which can include metal, plastic and even glass.
When FSMA went into effect, the focus shifted to preventing food safety problems, necessitating that food processors implement preventive controls to shift the focus from recovery and quarantine to proactive risk mitigation. Food producers developed Hazard Analysis and Critical Control Point (HACCP) plans focused on identifying potential areas of risk and placement of appropriate inspection equipment at these key locations within the processing line.
Metal detection is the most common detection technology used to find ferrous, non-ferrous, and stainless steel foreign objects in food. In order to increase levels of food safety and better protect brand reputation, food processors need detection technologies that can find increasingly smaller metal foreign objects. Leading retailers are echoing that need and more often stipulate specific detection performance in their codes of practice, which processors must meet in order to sell them product.
As food processors face increased consumer demand and continued price-per-unit pressures, they must meet the challenges of greater throughput demands while concurrently driving out waste to ensure maximum operational efficiencies.
Challenges Inherent in Meat Metal Detection
While some food products are easier to inspect, such as dry, inert products like pasta or grains, metal foreign object detection in meat is particularly challenging. This is due to the high moisture and salt content common in ready-to-eat, frozen and processed, often spicy, meat products that have high “product effect.” Bloody whole muscle cuts can also create high product effect.
The conductive properties of meat can mimic a foreign object and cause metal detectors to incorrectly signal the presence of a physical contaminant even when it is nonexistent. Food metal detectors must be intelligent enough to ignore these signals and recognize them as product effect to avoid false rejection. Otherwise, they can signal metal when it is not present, thus rejecting good product and thereby increasing costs through scrap or re-work.
Equipping for Success
When evaluating metal detection technologies, food processors should request a product test, which allows the processor to see how various options perform for their application. The gold standard is for the food processor to send in samples of their product and provide information about the processing environment so that the companies under consideration can as closely as possible simulate the manufacturing environment. These tests are typically provided at no charge, but care should be taken upfront to fully understand the comprehensiveness of the testing methodologies and reporting.
Among the options to explore are new technologies such as multiscan metal detection, which enables meat processors to achieve a new level of food safety and quality. This technology utilizes five user-adjustable frequencies at once, essentially doing the work of five metal detectors back-to-back in the production line and yielding the highest probability of detecting metal foreign objects in food. When running, multiscan technology allows inspectors to view all the selected frequencies in real time and pull up a report of the last 20 rejects to see what caused them, allowing them to quickly make appropriate adjustments to the production line.
Such innovations are designed for ease of use and to meet even the most rigorous retailer codes of practice. Brands, their retail and wholesale customers, and consumers all benefit from carefully considered, application-specific, food safety inspection.
The food processing industry is necessarily highly regulated. Implementing the right food safety program needs to be a top priority to ensure consumer safety and brand protection. Innovative new approaches address these safety concerns for regulatory requirements and at the same time are designed to support increased productivity and operational efficiency.
The COVID-19 pandemic has caused significant disruption to the food industry, especially in meat and poultry processing facilities. On Wednesday, May 27, Food Safety Tech is hosting a complimentary webinar, “Is Your Plant COVID-19 Safe?”, to provide realistic advice and tips on how to mitigate workplace exposure risks related to COVID-19. Our subject matter expert speaker, Trish Wester, founder of The Association for Food Safety Auditing Professionals, will also insights into updated cleaning and sanitation practices, and how companies can make sure that their facilities are more prepared for the entire period of the pandemic. The event is sponsored by Sterilex.
The increasing complexity of the global food chain has also increased the complexity of traceability of ingredients. However, FSMA has made this task a critical part of the seed to fork process. More vigilance and awareness of the supply chain is an essential part of protecting consumers and the company brand, and plays in an important role in the event of a recall. In a Q&A with Food Safety Tech Dean Wiltse, CEO of FoodLogiQ, explains the issues the food industry is experience in this area and why transparency in the supply chain will become the new normal.
Food Safety Tech: What are the biggest supply chain challenges you see industry facing today?
Dean Wiltse: The biggest challenge we see in the food supply chain is getting beyond the “one-up and one-back” approach to supply chain management to achieve real transparency in the supply chain. Now I think more than ever consumers want to know more information about their food and 2017 is going to be the year of transparency. A year of getting beyond one-up and one-back, and beyond the four walls of the food manufacturing facility to really dig down and understand what is going on two, three, four, or five levels down the supply chain, from a safety and risk mitigation standpoint.
I also think food companies will continue to be challenged by the ripple effect of increased recalls: Sunflower seeds, flour, powdered milk. Many food companies were rocked with these recalls in 2016. We expect these recalls to continue in scale and frequency going into 2017.
Another challenge is in the area of quality incidents—and the monitoring of those quality incidents. Oftentimes these quality issues go unchecked and it’s damaging to the quality of your food—and of course your brand—as well as damaging to the bottom line.
FST: How should companies monitor and ensure that they are getting high quality product from suppliers?
Wiltse: It sounds simple, but it all starts with being aware of exactly where you are experiencing quality issues across your supply chain. At FoodLogiQ, we pull all of the quality and incident data together in our dashboard to enable food companies to know exactly which suppliers you are having quality issues with and which ones you aren’t.
FoodLogiQ dashboards enable users to monitor quality issues in the supply chain and document incidents. (Click above images to enlarge the dashboards)
Tracking and documenting these incidents—followed by the corrective actions—is critical. It is also important that all of the requirements and expectations are communicated openly; it makes the food supply chain safer by opening up transparency.
Customers can also use our technology to aggregate the quality and safety data into a star rating for their suppliers. Defining what is important to you from a quality and safety standpoint and aggregate that data in the software, and then assign a star rating for your suppliers. You can then use this star rating to formulate your preferred and approved supplier list.
FST: Where are the biggest disconnects in the supply chain? And how can companies rectify this?
Wiltse: Back to what the consumer is demanding: More information about their food, where it came from and what exactly is in it. Leading food brands want to provide this level of transparency to their consumers, but many are struggling with delivering this information in an authentic, real-time fashion.
Today there’s technology that can deliver it to them. In order to get more granular and provide more detailed information through the supply chain, there’s a cost associated with that, even down to the labeling at the grower for traceability. Many in the industry view this as an additional cost, but the leaders see this as a strategic investment and realize there is significant ROI in supply chain transparency.
FST: What are the most serious concerns surrounding FSMA and the supply chain?
Wiltse: Clearly the majority of the industry has been preparing for FSMA for several years now, getting their processes in place, if they weren’t already. Where we see a significant opportunity for companies to be proactive is in centralizing their required records, safety plans, and other essential processes into one platform for their entire supply chain.
We see many food companies who may have the required documentation and corrective actions in place, but they are scattered or siloed throughout the organization, and not centralized and easily accessible when the FDA calls on you to provide that information.
Another challenge is certainly top of mind is foreign supplier verification. The wave of required verification for foreign suppliers will be significant for many companies so they must be vigilant and start that process now or risk a significant disruption to their business.
While illnesses linked to Chipotle restaurants are grabbing headlines, the federal government recently took steps to improve how manufacturers and packagers process and handle food. Last year FDA released several final FSMA rules, giving food companies a roadmap for ensuring food safety. The proactive approach of the regulations can help companies avoid the hazards that lead to disease and allergen contaminations, and even legal troubles. Indeed, unsafe food handling can carry costly consequences from both a financial standpoint as well as in lives lost or harmed.
In 2011, the good intentions of a family-owned cantaloupe company produced tragic results. The company, seeking more natural melons, followed a consultant’s advice and discontinued the chlorine rinse used to wash off contaminants. A Listeria outbreak followed, killing 33 people and hospitalizing 147 more. Although prosecution is rare in foodborne disease outbreaks, the company owners were sentenced to probation, home detention, community service, and $150,000 each in restitution.
A more egregious case occurred in September 2015, when the former CEO of the Peanut Corporation of America was convicted of knowingly shipping Salmonella-tainted peanut butter, which had caused an outbreak that killed nine people and sickened hundreds more. Stewart Parnell was sentenced to 28 years in federal prison.
The new regulations require companies to undertake hazard analyses of their production, along with remedial steps. This scrutiny leads to the creation of a written plan that details the controls to prevent contamination and establish a schedule for periodic testing. This analysis and control system is called the Hazard Analysis Critical Control Point, or HACCP.
Adherence to regulations doesn’t necessarily protect a company from liability, but not adhering can sound a company’s death knell when there’s a problem. The following are five ways in which companies can protect themselves:
Put food safety first. The company culture must revolve around it. The message that the HACCP plan is to be followed must be relayed to all levels of the organization. Otherwise, companies can face severe consequences, based on the question, “Did the company behave badly enough to face strong punitive damages?”
Concentrate on internal communications. In many cases, food recalls happen because of a breakdown in the communication process.
Hire accredited consultants. Make sure that your consultants are qualified and have been accredited by an appropriate body such as the International HACCP Alliance or The Seafood HACCP Alliance.
Don’t overlook supplied products. Suppliers should adhere to strict contamination-prevention protocols, but don’t assume they follow guidelines completely or have flawless processes. Your contracts with them should require that they periodically audit their facilities and share the audit results with you.
Label clearly. Packaging language might state that a product is manufactured in facilities that also process allergens such as peanuts and tree nuts. These types of warnings allow consumers to make up their own minds. It is also a reminder that HACCP plans must address prevention of cross-contamination (i.e., putting cleaning protocols in place if products with and without allergens are processed on the same equipment).
Many problems involve internal slip-ups or problems with supplied ingredients that allow contaminated food to reach consumers. If the contamination becomes known—and it often is not, when victims don’t equate their illnesses with tainted food—the businesses involved often face strict liability, meaning they carry some blame even if they didn’t act in a negligent manner and cause the problem directly.
Keep in mind that liability isn’t the only consequence of non-compliance. A recall or outbreak can damage the reputation of the company and the product. The cantaloupe tragedy sent sales of the melons plummeting, even in states not linked to the outbreak.
To minimize the hit on sales, a recall team should be in place, with a plan modeled on crisis management principles. Team members should come from all divisions of the company, including transportation and distribution to track down products, and communications to manage messaging. Legal counsel should be on board to advise on the ramifications.
When it comes to foodborne outbreaks, it’s a matter of taking classic prevention and preparation steps. Do everything you can to keep it from happening, but be ready just in case it does.
Unfortunately, quite often we are reminded of the vulnerabilities throughout the food supply chain. The latest E. coli outbreak linked to Chipotle restaurants in Oregon and Washington once again has consumers and the food safety industry on edge about traceability and a company’s ability to quickly identify the source of a serious outbreak. According to the CDC’s most recent update, laboratory testing is ongoing to find the DNA fingerprint of the bacteria. Concerning as this may be, no deaths have been reported thus far, but 42 people have been reported ill and 14 have been hospitalized in Washington and Oregon. In the most recent statement released on Chipotle’s website, the company said it is “aggressively” taking steps to address the problem, including by conducting deep cleaning and sanitization of its restaurants as well as environmental testing in its restaurants, and replacing all food items in the establishments that it closed “out of an abundance of caution”.
What if this were a situation of intentional contamination? Would Chipotle or any other company in this type of scenario really be prepared? These questions were posed by Rod Wheeler, CEO of The Global Food Defense Institute during a recent conversation with Food Safety Tech about food defense, and food tampering and intentional adulteration. Wheeler and Bruce Lesniak, president of Lesniak & Associates, shared their views on the threats that the food industry is facing and why companies need to have a strong plan in place to prepare for an attack on the food supply.
During next week’s Food Safety Consortium conference, Rod Wheeler will moderate the Ask the Experts session, “Engaging Food Tampering Discussion Surrounding Food Defense” on Wednesday, November 18. LEARN MOREFood Safety Tech:What challenges do you see companies facing in the area of food tampering and adulteration?
Rod Wheeler: Our food supply is wide open. It accounts for 13% of the overall U.S. GDP. One thing we know about terrorists is that they want to affect our financial markets. What’s the best way to do that? You attack the 13% GDP – and what infrastructure is that? It’s our wireless systems, airline systems, transportation systems, medical supply, or our food and agricultural supply. Those are the top areas in which we need to focus, and we have to make sure the food & agriculture supply remains safe and secure in the United States.
On 9/11 the world changed, and the challenge for us becomes, within all of our 18 infrastructures, but how have we changed? Do we continue to do business the same way we always have, even prior to 9/11? Over the past few years, we’ve seen a significant increase in terroristic activity around the world—from France to Syria to Yemen to Pakistan. Here in the United States, we have to be mindful of what is happening.
We’ve always had food safety programs: HACCP, HARPC, GFSI, SQF, etc.—those are good for unintentional contamination. But what happens if someone wants to intentionally place a deadly contaminant into a product?
In this country, on a daily basis we see contaminations occurring. We were recently notified of a massive outbreak of E. coli that has occurred throughout the Chipotle system: 47 Chipotle stores have been closed. What does that mean? Is that just a food safety issue? What if that E. coli could have been intentionally grown in a test tube and placed into the food supply? Going forward, we have a duty and an obligation to look at these things, not just at face value but think about whether they are intentional events.
FST: Where are the biggest holes within food defense plans?
Wheeler: With more than 15 years of visiting food processing facilities, agricultural farms, dairy farms, and dairy processing facilities, the biggest concern that resonates with me is the fact that the culture of security is not there. The culture of security is simply security awareness—not planning. People in food plants are being taught to be mindful not vigilant. The largest of food companies have well thought out and active safety and defense plans, and their employees are educated, trained and empowered. We find that this falls off sharply with the mid-sized and small manufacturers and suppliers. All food providers must have a comprehensive and strategic security plan that is active and measureable.
For example, let’s say a contractor is walking though a food plant. You have worked in that plant for five years but have never seen this person before. Would you question that person about their credentials? Are people thinking about the things they can personally do to reduce or mitigate the risk… are they empowered?
So, the question is “what do you do when/if”: This is one of the topics we will be discussing at the [Food Safety Consortium] conference. It’s interesting that when we present this scenario to the management of a food company, many answer back with a blank stare. We ask, do you shut down your facility? Do you notify your customers? Do you notify the national media? This question goes to the root of the company’s security culture and the strength of its strategic planning. Until we develop the necessary plans, processes and protocols to respond proactively, we will continue to remain vulnerable.
FST: Do you think many food companies assume something catastrophic won’t happen to them?
Wheeler: I always ask why it is that we don’t anticipate these things in advance. People are complacent. “It’s not going to have happen here,” they say. “What terrorist would come to our small town and do this? We’re just a small mom and pop [business].”
Recently, I received a call from a 17-employee company in Tennessee. This particular company processes honey for 100 large box retail stores. I received a call from the CEO who said, “My client wants us to have one of those vulnerability things.” He was referencing the vulnerability assessment. He said, “I don’t know why they’d want us to have one of those. We’re a small company down here in Tennessee, why does my client think some terrorist would come here?” The fact is, attackers will find the weakest link to attack: The small honey company is not the target; they are the vessel by which the attackers get to the primary target, and in this case, the big box retailer. The big box retailer/supplier is the target and the simplest, most effective way to get to them is through the hundreds of small, low to no protection suppliers.
These are the issues we need to enlighten and educate companies about; we need to get them thinking differently, because this way of thinking is completely different. If you ask someone who’s been in this industry for years, they’ll say, we never had to worry about locking our doors, or use biometrics to gain access to certain areas. We never had to think about these things in the Food & Ag supply before.
During our front line training course, we place a significant amount of focus on the food plant blending areas and why it is the number one threat area for intentional/unintentional contamination of our food supply in the United States. The blending area is exposed to a number of vulnerabilities and once attacked, the tainted ingredients are spread among numerous products that once distributed, are not necessarily quickly traced once they are blended into the final product.
Bruce Lesniak: The consequences of such an emergency are multifaceted; they affect the consumer and their product confidence, the manufacturer through recall and the retailer through recall, brand damage and loss of consumer loyalty. Often, this ripple effect begins with the small supplier and works its way upstream to affect the entire process.
We are seeing this scenario unfold in real time with Chipotle—this is huge in the food industry. FDA has not been able to determine exactly where that genetic fingerprint has originated resulting in location closures, shaken consumer confidence and brand damage. –Rod Wheeler
FST: What will it take the industry to wake up to what could become a serious reality?
Wheeler: Unfortunately it’s probably going to take a major incident for people to wake up and smell the coffee. With that said, we firmly believe that it is critical to awaken the sleeping giants before something happens. We must increase the awareness and provide education to heighten the reality of what can potentially happen and promote proactive engagement of risk mitigation.
FST: In the context of FSMA, are companies prepared for the compliance stage?
Wheeler: Over the years, I’ve seen a number of companies begin to ramp up security at their facilities. But a number of them are doing it because they realize they need to comply with the food defense elements of FSMA; the larger companies are driving compliance and are requiring that their suppliers comply. But I think convincing companies about “Why” this is important, is the challenge. Often times companies will say, “we’re doing this training”, or “we’re doing this vulnerability assessment because it’s a requirement of FSMA.”
We feel that if being compliant is your “Why “reason, then you are spending time and money for the entirely wrong reason. You don’t do vulnerability assessment or training in food defense because you want to comply with the law. You do it because you want to protect your company and the consumer from the reality of what can happen and proactively work to avoid a threat.
Lesniak: We see the adoption trend take hold as it has traditionally, in three phases. First are the early adopters—they understand the importance of compliance for the right reasons and the need for food defense, Second are those who feel the urgency to comply due to a compelling issues (an incident or have been instructed to do so by larger suppliers in order to retain contracts), and third are those who will come kicking and screaming.
Wheeler: A lot of the requirements of FSMA were generated as a result of the PCA event in 2009. The prosecution and subsequent conviction of the Parnell brothers isn’t the last prosecution we’re going to see for someone violating a food safety protocol. This is the first, and it’s a wake up call.
It’s that time of year again: A time when Americans, both young and old, enjoy decorating pumpkins, dressing up in outrageous costumes, visiting houses haunted with ghosts and goblins, and consuming way too much sugar. And then there’s the classic favorite, the caramel apple. I’ve never been a huge fan of the sticky treat, but many Americans just can’t get enough it.
This year’s Food Safety Consortium conference features “Preventing Listeria Workshop: A Practical Workshop on Food Safety Controls” on Tuesday, November 17. REGISTER HERE. Last year caramel apples received a huge amount of negative press as a result of a deadly Listeria outbreak that was traced back to prepackaged caramel apples from Bidart Bros (Bakersfield, CA). In February of this year, the CDC closed its investigation, and provided the final stats: 7 dead and 34 hospitalizations throughout 12 states.
Now here we are, at the height of the season for apples and sweet treats, and concerns over Listeria in caramel apples are back in the media. The good news is that industry is proceeding with caution. The Wall Street Journal reports that Kroger Co. is taking unrefrigerated caramel apples off its store shelves following a recent study that cited a higher likelihood of Listeria growth on the products when at room temperature versus under refrigeration. Published by the American Society of Microbiology, the study, “Growth of Listeria monocytogenes within a Caramel-Coated Apple Microenvironment”, found that “insertion of a stick into the apple accelerates the transfer of juice from the interior of the apple to its surface, creating a microenvironment at the apple-caramel interface where L. monocytogenes can rapidly grow to levels sufficient to cause disease when stored at room temperature”. The researchers also advise that consumers purchase refrigerated apples or eat them fresh.
Although representatives from Kroger said they think the risk of Listeria contamination is minimal, they decided to take a cautionary approach. It’s reassuring to see companies step up and take proactive tactics to mitigating risks, especially when it involves protecting consumers against another potentially deadly outbreak.
FSMA’s proposed rule on intentional adulteration isn’t the only reason companies should be paying attention to food defense.
Establishing metrics in food defense, similar to the growing awareness around the importance of measuring behaviors in a food safety culture, was a topic recently brought up at FDA’s FSMA public meeting in the spring. The agency acknowledged that it will need to both clearly define what exactly is intentional adulteration and how it can be measured.
While food safety involves assessing and mitigating hazards, food defense is all about the threat and protection against intentional contamination. “The threat of fraud is a growing problem as supply chains get more complex, resources grow scarcer and the cost of food increases. All this provides more opportunity and potential reward for food adulterers,” stated a recent PwC report on food trust.
Prevention is the key word and on the most fundamental level of a food defense plan, businesses need to have management commitment before building, or even revisiting, a food defense plan—do they understand the resources, time and cost involved?
Conducting a vulnerability assessment is the first step in finding the gaps and examining whether a facility is secure. Beyond the standard questions that companies may ask when embarking on this assessment, businesses should identify potential attackers, asking how an attacker could have access to a product or process and what would be the outcome of an attack. Then look at the protective measures that are already in place—would these act as a deterrent? And if deterred, would the attacker proceed to the next target or would he or she stop? What measures are in place to find the attacker before there is an effect on the product?
When developing a food defense plan, there are several areas of potential vulnerability:
Shipping and receiving and packaging
Laboratories and testing sites
Recall and traceability programs and processes
Water used in processing/manufacturing—what is its origin?
Employees—what are the health risks? Is there a process for employee health reporting? Is there a process for reporting disgruntled employees?
With food fraud on the rise, it’s important for companies to continue to revisit and update their food defense plans, considering changes to facility designs or strategies, packaging changes, security improvements, etc. Companies should also be proactive in monitoring their employees both from a satisfaction (reducing the incidence of a disgruntled employee) and awareness perspective. FDA has initiatives to help companies build a food defense culture and employee awareness, including the ALERT training course for owners and operators of food facilities and Employees FIRST, and the National Center for Food Protection and Defense has programs aimed at workforce training as well as undergraduate and graduate curriculum on food defense.
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