Government food protection officials do a great deal of various types of work to ensure food marketed within their jurisdiction is safe. Most people are generally aware of the food establishment inspections, consumer complaint investigations, and food sampling and testing conducted on a daily basis by government food safety agencies, but they may be less aware of the critical work performed by these agencies during their most important functions. Three of these most important functions are investigations relating to foodborne illness, coordinating food recalls, and responding to disasters. During disaster response, government officials work to identify and mitigate food safety issues that were created by the disaster and assist industries into the recovery phase. Their response can occur directly, by visiting the site, or indirectly, through a press release or advisory placed with the media.
Public health officials at all levels of government recognize that food emergencies can occur at any time and have a huge impact on the citizens they work so hard to protect. These food emergencies are the result of both man-made and natural disasters. Man-made disasters include vehicle mishaps, explosions, chemical spills, and nuclear accidents, whereas natural disasters include hurricanes, floods, tornadoes, blizzards, and wildfires. They all can create havoc in the normal lives of citizens and have serious impacts on food safety and the economy.
Hurricanes are one of the most damaging natural disasters; they are perilous for not only the people living in their paths but for the national economy as well. A hurricane can lower U.S. production, increase unemployment, and depress financial markets.
For the sake of the discussion below, we offer the following definitions of hurricane categories:
Category 1: Very dangerous winds between 74 and 95 mph will cause some damage, and power outages for a few days are likely
Category 2: Extremely dangerous winds between 96 and 110 mph will cause extensive damage and a near-total power loss that could last up to a few weeks
Category 3: Devastating damage will occur from winds between 111 and 129 mph; electricity and water will be unavailable for up to several weeks, and trees will be snapped or uprooted, blocking roads
Category 4: Catastrophic damage will occur from winds between 130 and 156 mph; even well-built framed homes will lose most of the roof structure and/or some exterior walls; fallen trees and power poles will probably isolate residential areas, and power outages could last possibly months
Category 5: Catastrophic damage will occur from winds 157 mph or higher; a high percentage of homes will be destroyed; and most areas will be uninhabitable for weeks or months
The United States is very vulnerable to hurricane damage. The 2017 hurricane season was especially harsh, as two major hurricanes—Harvey and Irma—blasted the U.S. East Coast with winds exceeding 130 mph.
Hurricane Harvey began as a tropical wave off the west coast of Africa on August 13, 2017, and tracked across the Atlantic Ocean, where it became a tropical storm on August 17. After entering the Caribbean Sea, it became disorganized and then entered the Gulf of Mexico on August 22. It would intensify due to the warm Gulf waters and soon grew into a Category 1 hurricane on August 24 with 80-mph winds. It continued to gain strength as it churned toward Texas. The National Hurricane Center upgraded the storm to a Category 4 hurricane August 25, with sustained winds of up to 130 mph.
It first made landfall over San Jose Island and then near Rockport in south-central Texas late August 25 threatening millions of residents with 130-mph winds, heavy rains, and a massive storm surge that swamped coastal areas. As the hurricane moved inland, its forward motion slowed to near 5 mph and meandered just north of Victoria, Texas. Strong rain bands developed during the evening of August 26, causing tremendous rainfall rates and rapid development of flash flooding.
By August 27, winds died down to as low as 40 mph, but the storm dumped a year’s worth of rain in less than a week on Houston and much of southeastern Texas. By August 29, two flood-control reservoirs had breached, increasing water levels throughout the Houston area.
Hurricane Harvey made its third and final landfall August 30 near Port Arthur, Texas, bringing widespread catastrophic flooding. While authorities and first responders handled as many as 10,000 rescue missions around Houston, at least 30,000 people fled to temporary shelters.
As the hurricane was being downgraded, it continued to dump massive amounts of rain on parts of eastern Texas. Some parts of Houston received more than 50 inches of rainfall—so much that the National Weather Service had to update the colors it uses on its weather charts to properly account for it.
On September 1, Texas governor Greg Abbott appeared on Good Morning America and said, “This is going to be a massive, massive cleanup process. People need to understand this is not going to be a short-term project. This is going to be a multi-year project for Texas to be able to dig out of this catastrophe.”
Hurricane Irma was the most powerful Atlantic hurricane in recorded history. Its winds were 185 mph for 37 hours, longer than any storm ever recorded. Those winds extended 50 miles from the center of the hurricane. Its coastal storm surges were 20 feet above normal tide levels.
Hurricane Irma developed off Africa’s west coast just west of the Cape Verde Islands on August 30, 2017. The storm moved westward along the Atlantic basin as a major hurricane. It was listed as a Category 5 hurricane with peak sustained winds of 185 mph. As it continued to move west and northwest, it impacted the Bahamas and Cuba with strong winds, storm surge, and tropical rains. On the evening of September 9, Hurricane Irma turned northward toward the U.S. mainland. It made landfall over the Southern Florida mainland around 1 p.m. local time Sunday, September 10, as a Category 3 storm, packing winds of more than 110 mph. It later intensified to a Category 4 hurricane with 130-mph winds. Life-threatening and highly damaging storm surge greatly impacted both coastlines of Florida with severe flooding. More than 6.7 million Floridians lost power. By September 11, Hurricane Irma weakened to a tropical storm as it moved north toward Georgia and Alabama. It continued to weaken, and by September 13 it had dissipated over western Tennessee.
The storm was responsible for 34 deaths in Florida, and damage estimates were in excess of $100 billion.
Role of Food Protection Officials Following a Natural Disaster
The disruptions following a natural disaster can create potential health concerns. Government food protection officials are responsible to ensure these potential health concerns have been mitigated. Food establishments are generally required to cease operations in an emergency, and those affected by a natural disaster should not reopen until authorization has been granted by the local or state regulatory authority.
The personal safety of responding officials is always a primary concern. These individuals should never enter a hurricane- or flood-damaged building where there is potential for hazardous materials or gas leaks until the building has been cleared by appropriate authorities.
The basic role of food protection officials is to provide oversight and guidance for establishments impacted by the disaster. Oftentimes, this is an enormous burden placed upon an agency that is difficult to address. Their general responsibilities involve the following areas:
Oversight of regulated establishments
Officials will assess the level of damage imposed on food facilities under their jurisdiction. They may conduct a final reopening inspection of a food establishment after the disaster has abated. In some cases, they may issue a temporary operating permit with certain restrictions to facilitate recovery. They also investigate related complaints and may also provide information or needed training to establishment staff.
Food product evaluation
Officials assist the operator or provide training to the operator to evaluate food involved in a disaster to determine whether it can be salvaged, used for nonfood purposes, or must be destroyed.
Officials note the need for first responders and identify the stage of recovery of utilities, other infrastructure, and food establishments preparing to reopen. They provide real-time information to Incident Command Centers that are generally assembled in response to a disaster.
Food- or waterborne investigations
Officials conduct foodborne or waterborne investigations when statistical evaluations indicate food or water is implicated. They interview employees to identify contributing factors to illness and collect food or water samples when necessary.
Officials document daily work, inspections, problems and solutions, investigations and complaints, and other requested information to assist in the preparation of an “After Action Report.” These reports are also necessary for receiving federal funding when an emergency is declared.
Mass feeding sites
Officials support and inspect mass feeding sites and other temporary food establishments that are set up to serve residents and responders during the response and recovery following a disaster.
However, there is little normalcy following a disaster and, as a result, there are two ground rules for government officials involved in response efforts. The first is to understand that they may be called upon to provide a service that is not within their general area of expertise. This is very common with response efforts involving a large or catastrophic event. The second ground rule is that agencies operating independently of other agencies working in a response effort can be very damaging to the overall effectiveness of the response. Collaboration and coordination are absolutely essential among all responding government agencies. This is a primary reason for the application of Incident Command Centers that are set up for response and recovery activities associated with disasters. The food protection response can overlap with other functions going on, including waste disposal, food source, mass feeding, and public health.
During response and recovery activities, food protection officials will utilize the following approach when conducting food safety assessments:
Assess the overall effect on the establishment
Officials review the extent of damage that has occurred to the building and the ability to maintain sanitary facilities such as water supply and sewage.
Evaluate product abuse
Officials review the impact that the incident has had on the food within the establishment. Temperature abuse, smoke damage, filth contamination, container damage, and floodwater damage can all affect food safety.
Identify corrective actions to take
There may be mitigating steps that can be taken to prevent products from further abuse. For example, during power outages, establishments can use blankets to cover perishable foods or use dry ice to provide temporary cold storage. Other examples of mitigating procedures include the use of bottled water as a source of potable water.
Provide educational assistance
Frequently, food protection agencies will have guidelines and educational materials available that they can provide to operators to help them follow appropriate procedures in responding to specific events.
Take enforcement action where necessary
Where establishment operators fail to take appropriate steps to ensure unsafe foods are not being sold, the regulatory agency will take appropriate enforcement action.
Regulatory Program Standards and Rapid Response Teams
Twenty-two states currently have Rapid Response Teams (RRTs), 19 funded through the U.S. Food and Drug Administration (FDA) and 3 without federal support. The teams are organized to respond to all human and animal food emergencies from foodborne illness to intentional contamination to natural disasters. The RRT program allows for enhanced training related to these activities and also training and implementation of the Incident Command System (ICS). This enhanced capability typically includes dedicated response leaders and has proven to be a successful model as the FDA has expanded the funded program from 6 to 19 RRTs since its inception and additional states will probably be added in 2018.
RRTs have developed and shared best practices across teams. Furthermore, through mentorships, recent RRT additions have been able to more quickly establish their response team. One common theme across teams is the need to have staff dedicated to emergency response. Most teams have a dedicated staff member leading the response team. This person ensures that emergency response procedures are up to date and serves as a key resource during emergency situations, often leading the response. RRTs also focus on bringing together the human and animal food response agencies into a unified approach to maximize efficiency during these emergencies.
While foodborne illness investigations are the most common type of response, natural disasters also represent a common deployment of RRTs. Hurricanes, floods, landslides, fires, and water contamination events are among the many types of natural disasters RRTs have responded to since inception. Following is an example of how two RRTs—Texas and Florida—approached 2017’s Hurricanes Harvey and Irma.
The Texas RRT (TRRT) provides preparedness, prevention, and timely response to food- and/or feed-related disasters affecting the citizens of Texas. It is a multi-agency team, comprising FDA, the Texas Department of State Health Services (DSHS), and the Office of the Texas State Chemist (OTSC). In August 2017, the TRRT was faced with the enormous task of responding to manufactured product safety concerns caused by Hurricane Harvey. Harvey struck the Texas Gulf Coast on August 25, 2017, causing substantial amounts of devastation. Thousands of processors and manufacturers of food, animal feed, drugs, and medical devices were in the path of the storm. Structural damage, power outages, and floodwaters potentially contaminated products produced by these businesses. The TRRT sought to prevent compromised products, produced in regulated firms, from reaching the public.
TRRT activated on August 30 for the Hurricane Harvey response. The mission tasks were to assess food, medical devices, drug, and animal feed businesses affected by Harvey, conduct on-site inspections as necessary based on assessments, and communicate appropriate information to various agencies. FDA, DSHS, and OTSC formed a joint incident command to lead response efforts. Each agency designated an incident commander. The team of incident commanders directed response efforts concurrently, allowing for effective communication and preventing duplication of efforts.
Before damage assessments could take place, firms that were potentially affected by the storm had to be determined. Texas counties affected by Hurricane Harvey were identified, then lists of manufacturing companies in those counties were compiled. Lists had to be vetted and compared between agencies to meet the goal of conducting response efforts without duplication of effort. These lists were then divided and assigned to field teams tasked with performing surveys.
While the geographic information was being gathered, methods of assessment were being developed. Firms would be surveyed to determine levels of damage sustained. Disaster survey questionnaires were created. The surveys contained questions that asked whether firms had been affected by Hurricane Harvey, were currently in operation, had power, had been flooded, sustained physical damage, and had products affected by any storm conditions.
Field teams were assembled to collect survey data. Surveys were conducted by phone. If sustained storm damage was indicated, an on-site assessment was performed to make certain that contaminated products were destroyed and that sustained structural damage would not lead to further product contamination. Fortunately, it was discovered that most compromised products had already been destroyed voluntarily by firms.
This was the first TRRT activation that went beyond the scope of food and animal feed. The TRRT primarily responds to foodborne illness outbreaks, but the enormous impact of Hurricane Harvey required the inclusion of groups that had never before participated in a TRRT response. DSHS mobilized resources from Milk and Dairy, and Drugs and Medical Device programs. FDA mobilized Human and Animal Foods, the Office of Pharmaceutical Quality Operations, the Office of Biological Product Operations, the Office of Medical Devices and Radiological Health, and the Office of Biological Research and Monitoring Operations. The OTSC Laboratory was utilized under a TRRT ICS structure for the first time during this response. The lab provided analytical results to the Texas rice industry to be used for market certainty and crop insurance purposes. The analytical testing included microbiological (e.g., Salmonella, Escherichia coli, and Clostridium perfringens), heavy metals (e.g., mercury, lead, and cadmium), mycotoxins (e.g., aflatoxin, fumonisin, and zearalenone), and a poison screen.
The members of the TRRT returned to their normal duties on October 20, 2017. In total, 2,850 businesses were surveyed by DSHS, 279 by OTSC, and over 1,700 by FDA. Forty-six on-site visits were completed by DSHS, 68 were completed by OTSC, and 7 were completed by FDA.
There were many challenges during the Hurricane Harvey response. The TRRT was already activated due to a national cyclosporiasis outbreak when the storm struck the Texas coast. This was the first time that the TRRT was activated for two separate events simultaneously. Although Hurricane Harvey essentially halted all boots-on-the-ground activity in the Houston area, Cyclospora-related activities continued. Several command and general staff were working on both activations at the same time, eventually being mobilized for 3 months.
The workload for the command and general staff could have been reduced if the TRRT had more people trained and available for mobilization. This would have prevented those resources from having to work on more than one activation at a time. As a result, TRRT has requested Incident Command, Plans Chief, and Operations Chief ICS courses. Those courses are to take place in the spring and summer of 2018.
TRRT resources, namely boots-on-the-ground inspectors, had been assigned to assist with other Hurricane Harvey response efforts outside of the RRT. This led to unavailability of sanitarians in Houston and several surrounding areas to assist with collecting survey data and performing on-site visits. These resources would not become available until several weeks into the activation.
Hurricane Harvey required more participants than any previous TRRT activation. This was exacerbated by the unavailability of Houston-area sanitarians. The TRRT anticipated needing 50 people to perform response duties; however, well over twice that amount were mobilized. This was the first TRRT activation for many team members, and some were unfamiliar with TRRT and ICS procedures. The TRRT is currently revising Standard Operating Procedures to provide practical training to additional staff in the event of another dual mobilization. Overall, Hurricane Harvey showed that the team must be prepared and have adequate resources to address concurrent activations.
Despite the many challenges and lessons learned (see “Hurricane Harvey: At a Glance,” p. 42), Hurricane Harvey activation efforts were a success. This can be attributed to strong communication and preexisting relationships between FDA, DSHS, and OTSC. The agencies had prior experience responding in May 2015 when heavy rains and flooding threatened the safety of the food/feed supply in Texas. The TRRT was able to use the lessons learned in that activation to anticipate Hurricane Harvey objectives and assignments. Effective communication can be attributed to FDA, DSHS, and OTSC constantly working together on TRRT activities. The TRRT continues to pursue relationships with other state and federal agencies to facilitate future activations whenever the safety of the food/feed system is threatened.
The Florida Department of Agriculture and Consumer Services (FDACS) is the lead coordinating food agency for the Florida Integrated Rapid Response Team (FLIRRT). FLIRRT consists of four food regulatory agencies: FDACS has jurisdiction over retail and manufactured food establishments; the Florida Department of Health has jurisdiction over schools, institutions, and bars; the Florida Department of Business and Professional Regulations has jurisdiction over public foodservice establishments; and FDA regulates 80 percent of the nation’s food supply.
As Hurricane Irma began its move toward Florida with what appeared to be a direct hit to the entire state, FLIRRT members began making a coordinated plan and efforts for recovery after the storm had passed. The storm made its first U.S. mainland landfall in the Florida Keys as a category four hurricane on the afternoon of September 10, 2017. A second landfall hit Marco Island, Florida, 6 hours later, and then the storm exited the state the following day through North Florida. Hurricane Irma was over 400 miles in diameter, impacting 63 of Florida’s 67 counties.
FDACS’s Food Emergency Response Coordinator staffed a seat at Emergency Support Function 11 for Food and Water (ESF-11) at the Florida Emergency Operations Center (EOC), where she began to gather and disseminate real-time information regarding infrastructure damage, power outages, and flooding reports to FLIRRT agencies to help determine priority areas for food assessment. Since the state food safety regulatory program in Florida is distributed across multiple agencies, hurricane assessments were conducted independently by each of them. Information was shared with ESF-11 to assist all agencies as they conducted their work planning.
Leading up to Hurricane Irma’s landfall, FDACS validated all the regulated food establishments under its jurisdiction and ensured they were uploaded into the geographic information mapping system (GIS). Hurricane assessment kits were pre-staged throughout the state in June, including equipment and supplies needed in the event of activation. Predetermined strike teams were also notified to retrieve their assessment kits and prepare a personal travel bag with clothing, toiletries, and medications should they be deployed to another area of the state for work.
Using the ICS, FDACS assembled an Incident Management Team near the EOC in Tallahassee after the storm passed on September 13, 2017. Eleven strike teams consisting of 10 strike team members each were activated to conduct on-site and phone assessments. A FLIRRT-designed assessment form was utilized for the assessments, and the findings were used to determine issues and further actions needed. A just-in-time web training event was used to ensure consistent and accurate reporting on the assessment form. This form was developed to be completed by a strike team member in no more than 20 minutes, capturing the condition of an establishment, including building condition, electricity, water, waste disposal, and condition of food products. This assessment form has been used by multiple states during hurricane assessments, and other states can get it by emailing FLIRRT@FreshFromFlorida.com.
The Operations Section held morning briefings via conference call with strike team members, which allowed the dissemination of information regarding safety, tactics, and logistics. Work planning utilized the GIS mapping system, which allowed the strike team leaders to have visual guidance of areas where establishments remained to be assessed and also allowed for assimilating lists by county, city, street name, or ZIP code. Once assessed, the locations were marked to show when they were back in operation by the Incident Management Team’s planning section. This map was shared with the State Emergency Response Team at the EOC and made available at FloridaDisaster.Org. This information assisted in determining where Florida Mass Care feeding sites were no longer needed based on the location of operating retail grocery stores and markets.
FDACS personnel experienced numerous internal challenges throughout this event that impacted the response efforts (see “Hurricane Irma: At a Glance”). Over one-third of Florida’s population was ordered to evacuate due to Hurricane Irma’s track, which directly affected the availability of staff for activation. Employees also had personal property damage, which needed to be immediately addressed. A major struggle after landfall was communication due to cellphone tower and power outages directly affecting phone calls, texting, and email. Over 6.7 million customers were without power throughout the state of Florida at the height of outages on September 11. Due to the extensive outages, even the Incident Command Post where the Incident Management Team was staged encountered difficulties with communication and power. Employees in lesser-impacted areas traveled to harder-hit areas throughout the state to assist with the assessments. Hotel accommodations were also difficult to find due to evacuees’ using these locations as lodging and because there were such large geographic areas without power. Due to the largest evacuation in state history, fuel availability became a significant challenge. Florida Department of Transportation (FDOT) worked with agencies activated under the Governor’s Hurricane Declaration to provide fuel to responders at fuel sites stationed around the state. Due to the mission of FLIRRT, activated food agencies were provided fuel availability at these FDOT sites as well. Activated personnel worked, on average, more than 10 hours per day.
The Florida Keys were the most difficult area to access due to road closures and bridge damage since there is one main road leading into the Keys. First responders, FDACS Office of Agricultural Law Enforcement, and the Florida Fish and Wildlife Conservation Commission were part of the search-and-rescue team and assisted FLIRRT agencies with general information and updates from the Keys, including using drones when access was prohibited. The U.S. Department of Agriculture also had a local strike team in the Keys and assisted FLIRRT agencies with information when the agency was unable to access heavily impacted areas.
Florida has an ESF-18 for Industry Partners that is designed for communication with Florida’s businesses. Food businesses were able to report status updates using an online portal when they could resume operation, which assisted in determining areas for assessment. Efforts are being made to enhance this self-reporting system, which will be a benefit to the Florida food agencies during disaster recovery and will allow consumers to know which businesses are open and operating.
After Hurricane Irma, the FLIRRT food agencies assessed within a 2-week period over 26,000 facilities by either on-site visits or phone assessments, and reported over 630,000 pounds of adulterated product destroyed post-Irma.
The Texas and Florida RRTs provide an example of how the RRT system has improved response to human and animal food emergencies. These teams along with the 20 others across the nation have become an integral component in the nation’s integrated food safety system. The rapid response teams prove the effectiveness of multi-agency and -jurisdictional responses incorporating federal, state, and local officials.
Joseph Corby is the executive director of the Association of Food & Drug Officials.
Steven Mandernach is the bureau chief for food and consumer safety at the Iowa Department of Inspections and Appeals.
Brenda Morris is the assistant director, Division of Food Safety, at the Florida Department of Agriculture and Consumer Services.
Summer Williams is the emergency response coordinator, Division of Food Safety, at the Florida Department of Agriculture and Consumer Services.
Tishara Coleman, MPA, REHS/RS, is a TRRT project specialist.
NASA. 2017. “Hot Water Ahead for Hurricane Irma.”
FDA. “Food Safety in the Event of Disasters.” University of Tennessee Center for Agriculture and Food Security and Preparedness.