“For the life of me, I cannot understand why the terrorists have not attacked our food supply because it is so easy to do.” —Tommy Thompson, former Secretary of the U.S. Department of Health and Human Services, at his farewell news conference
“U.S. residents say protecting the food supply chain and preventing release of chemical or biological agents in public areas is most important.” —National Center for Food Protection and Defense, University of Minnesota
In April 2007, the Department of Nutrition and Food Science, University of Maryland, College Park, MD, with the support of a grant from the U.S. Department of Agriculture’s Cooperative State Research, Education, and Extension Service (USDA CSREES), sponsored a meeting of food experts from industry, government and academia to examine what food defense means to industry. Twenty-three attendees participated in this workshop, which was held at the Maritime Institute of Technology and Graduate Studies (MITAGS).[1] Attendees, representing eight national/ international industrial organizations (companies and trade groups), seven federal and state government agencies, as well as eight representatives from three academic institutions, expressed a strong consensual view that food defense was but one essential and separate element of an inseparable trio of responsibilities (food quality, safety and defense) that comprise food protection. Park describes food protection as the connection of food safety and food defense elements into a common risk-based food protection platform.[2] The MITAGS workshop defines food protection as the integration of food quality, food safety and food defense concerns into a single unified strategic and operational action plan (Figure 1).
This view marks a maturation of the thinking about food defense, which in the aftermath of 9/11, was viewed as separate and distinct from food safety. Food defense is indeed separate but it cannot pragmatically or strategically be considered as distinct from food safety. Just as measures implemented for food safety, such as the Hazard Analysis and Critical Control Point (HACCP) program, have secondarily impacted food product quality, it can be equally surmised that measures designed to address food defense will have some positive effect on both food quality and safety. For example, enclosing certain unit operations to prevent contamination as a defense measure might prevent unintentional as well as intentional contamination. Likewise, adoption of safety programs and protocols undoubtedly provide an enhanced degree of product defense. The constant monitoring of product and process parameters to ensure that product specifications remain under control enables the manufacturer to maintain a watchful eye over both the safety and defense of the product. The introduction of physical barriers to prevent the accidental injury of production workers has the added benefit of minimizing the capability of potential threats to gain access to the product.
What is Food Defense?
A review of the literature reveals a pervasive and growing usage of the term “food defense” without a widely agreed upon definition. Definitions range from guarding against the intentional contamination of food (ubiquitous) to the following agency definitions:
1. The U.S. Food and Drug Admin-istration (FDA)’s Office of Regulatory Affairs in its Food Defense Terms and Acronym List defines food defense as “the collective term used by the FDA, USDA, DHS, etc. to encompass activities associated with protecting the nation’s food supply from terrorist activities.”[3]
2. Marc L. Ostfield, U.S. Department of Homeland Security, states that “food defense encompasses the steps taken to minimize or mitigate the threat of deliberate contamination of the food supply, and includes identifying points of vulnerability and working to strengthen infrastructure, thereby, making the food supply a less attractive and, more importantly, less vulnerable target.”[4]
3. In its guidance document “Developing a Food Defense Plan for Meat and Poultry Slaughter and Processing Plants,” USDA’s Food Safety and Inspection Service responds to the question of what is food defense with: “Food defense is not the same as food safety. Food defense focuses on protecting the food supply from intentional contamination, with a variety of chemicals, biological agents or other harmful substances by people who want to do us harm. These agents could include materials that are not naturally-occurring or not routinely tested for. An attacker’s goal might be to kill people or disrupt our economy. Intentional acts are generally not reasonable and are hard to predict.”[5]
The notion of “food defense” was begun in the aftermath of 9/11 and was initiated by U.S. government agencies. The initial term adopted for this purpose was “food security.” This was confusing to many because the term was already in wide usage with an alternative meaning. Food security is defined by the Food and Agriculture Organization of the United Nations (FAO) as: “Physical and economic access, at all times, to sufficient, safe and nutritious food to meet dietary needs and food preferences for an active and healthy life.”[6] Government agencies have begun to use the term food defense and they have treated it as a separate program, reflecting the manner in which government agencies organize to consider new ideas. Industry, on the other hand, is less inclined to see food defense as a stand-alone program or function. The food industry readily expands the notion of food safety to food protection, which includes food defense. Most recently, federal agencies are adopting the term “food protection” as an umbrella term to encompass food safety and food defense.
Developing a Definition
When important words are not clearly understood, misinterpretation may result, sometimes with severe consequences. In fact, substantive disagreements can arise because people use the same words to mean different things or because they use different words to mean the same thing. As noted above, early attempts to use the term “food security” in relation to the defense of our food supply were met with concerns expressed by nutritionists and others who interpret the term in its classic context of nutrient consumption. As another example, despite many years of discussions within the international community about HACCP, there remain differences as to how it is understood and practiced. There is sometimes a lack of clarity surrounding the words validation and verification, with people using the words interchangeably and in an incorrect context. For the sake of clarity and understanding, it is critical that we think, speak and act in ways that are more inclusive than exclusive as food becomes increasingly global.
The National Center for Food Protection and Defense conference in April 2007 recommended the following as part of its breakout workshop conclusions: “Develop/promote common definitions and metadata terms to achieve consistency, interoperability and clarity in educational programs to help students, industry, etc.”[7] To this end, the MITAGS participants sought to offer the growing food protection community some clarity on the words we might use to discuss these important issues. Therefore, one of the most important objectives of the MITAGS workshop was to develop a definition of food defense that met the needs of the participants. In the process used, each attendee was asked to provide a definition for food defense. Working from these personal definitions, small group definitions were developed and then these were winnowed down in a simple consensual voting process to finalize their definition of food defense.
In reviewing the personal definitions of food defense presented by the twenty-three participating individuals, there were varieties of perspectives on just what is being defended. The general consensus was that the food supply is to be protected. But the practical definition varied depending on whether one takes the viewpoint of an individual company, an industry or a nation as a whole.
Industry representatives tended to focus on the company’s supply chain, production and marketing functions. Their approach encompassed the entire product cycle including producers, processors, transportation, storage and point of sale. Infrastructure and brand were specifically included as assets to be protected in addition to the food itself. Government and academia attendees tended to take a more holistic view of the food supply. Food defense was seen as more of a responsibility to be shared by all parties in the product lifecycle or the farm to the table “food chain.” In a food safety context, “food chain” is sometimes used loosely to include all food related activities from production of the food to its consumption. A few participants held the opinion that food defense was, at least to some degree, the defense of consumers/customers. Most expressed the view of protecting the food itself and the equipment used to produce, process and provide it.
There was widespread linking of food defense to reducing various risks associated with intentional tampering of food supplies. Some definitions indicated a clear assumption that food defense would be conducted within a risk analysis framework. Some focused on the risk of an attack of some sort, some on the risk of a successful attack and others focused on risks to consumers.
It is clear that intentionality is an important distinguishing characteristic of food defense. The prevailing food protection focus clearly linked the intentional contamination of food defense to the unintentional contamination of food safety. Intentional threat, adulteration, contamination, sabotage or other malicious acts are included in the definition.
The likely hazards to the food or food facilities include biological, chemical, radiologic, physical or financial hazards. The physical hazards include damage and destruction to infrastructure and equipment as well as the entire range of physical materials that can be added to food. A few participants noted that the mere threat or claim of an attack could be sufficient to inflict economic damage on a producer.
Many definitions included some notion of risk management. Several participants specifically suggested that food defense needed to be proactive while others pointed to the need to include “reacting” to an attack as an element of their definition of food defense. Perhaps “response” to an attack is a more faithful interpretation of their intent, based on discussions that attended the development of the definition. Management measures were sometimes described in terms of controlling the various procedural operations in the food chain. Taking action to prevent attacks was also an element within several definitions. Relatively few people included any explicit mention of “vulnerabilities” but one offered a definition centered on this concept. It included understanding, anticipating and evaluating vulnerabilities, as well as taking subsequent steps to mitigate these vulnerabilities. Numerous definitions mentioned taking measures to reduce risks, without explicitly addressing the need to assess the hazards that cause the risks.
Terrorists, bioterrorists, individuals and inside saboteurs were mentioned as the likely types of people to perpetrate an attack. Several participants offered a definition that specified that food defense should be a strategic initiative, as opposed to a tactical measure. When participants included actions to be taken in their definitions they tended to use such verbs as training, screening, assessing, managing, communicating, planning, analyzing, implementing, preventing, recalling, recovering and responding.
After lengthy discussions and debates, the participants of the MITAGS Workshop proposed the following definition of food defense: “Food defense means having a system in place to prevent, protect, respond to and recover from the intentional introduction of contaminants into our nation’s food supply designed specifically to cause negative public health, psychological, and/or economic consequences.”
What is a Food Defense Plan?
The USDA’s Food Safety And Inspection Service (2006b) defines a food defense plan as follows: “A food defense plan is a document that sets out control measures developed by an establishment to prevent intentional adulteration of product. A food defense plan should be developed, written, implemented, tested, assessed, and maintained if it is to be functional. All establishments are encouraged to operate with a food defense plan.”[8] The elements of such a food defense plan include the following:[5]
• Assessment. As part of the assessment the establishment: looks for vulnerable points at the establishment, determines what the risk factor is for each point, develops defense measures at each point that it has identified as high risk, and creates a written plan to implement defense measures.
• Implement. The food defense plan is implemented when the defense measures identified in the plan are in place and used as intended.