1
Developing Food Defense Plans
Presented by
Cathy Crawford
HACCP Consulting Group, LLC
For FSIS “How To Workshops”
Spring 2009
Objectives
 By the end of this workshop, you will be able
to
• Define food defense
• Understand why food defense is important
• Develop your own food defense plan
2
What Is Food Defense?
 Food defense is not food safety.
 Food safety addresses predictable and
unintentional risks. Food safety is best
addressed through HACCP.
 Food defense addresses intentional attacks
on the safety or quality of food. It is not well
suited to HACCP.
3
Why Be Concerned?
 Intentional contamination has happened and
can happen again.
• Oranges with mercury – Israel, 1978
• Salad bars with Salmonella – Oregon, 1984
• Cookies with needles, St. Louis, 1984
• Fast food with rat poison, China, 2002
• Ground beef with nicotine – Michigan, 2003
4
Why Be Concerned?
 1994: A tanker was accidentally contaminated
resulting in an estimated 224,000 illnesses.
 2009: What if it wasn’t accidental? What if it
was a tanker of oil for frying meat/poultry?
5
Who Would Do This?
 Terrorists or Activists
 Competitors
 Disgruntled employees
6
Why?
 Anger over national, business, or personal
differences
 Seeking changes in culture
 Seeking economic disruption
 Seeking public fear
 Seeking harm to others
7
Why Me?
Factors that increase risk:
 Making large batches of food
 Foods with short shelf lives
 Uniformly mixed products
 Products that reach key populations
 Ease of access
8
Imagine—What If?
 People are ill, injured, or even dying.
 Your company name and product are
involved.
 A recall is initiated.
 Production is halted—jobs lost.
 Financial losses occur locally and even
nationally.
You are asked, “What did you do
to prevent this?”
9
FSIS Survey Findings: Percentage
of Plants with Food Defense Plans
 August 2006: 27% of establishments have
plan
 November 2007: 31% of establishments have
plan
 August 2008: 41% of establishments have
plan
FSIS goal: 90% of establishments
have food defense plan
10
11
Why Write a Plan?
 Writing it down will improve it.
 Insurance companies and audits request a
plan.
Objectives Review
 Defining Food Defense
 Understanding why it matters
 Develop a Plan
12
How to Develop a Plan?
1. Conduct a self assessment. Know where you
are today.
2. Plan to stay as good or become better.
3. Compare to where you could/should be
tomorrow or next year. Find vulnerabilities.
4. Plan and prioritize a way to improve.
5. Implement and update the plan.
13
Discussion Question
 What obstacles have
you encountered
when creating or
improving your food
defense plan?
14
Conduct an Assessment
 Developing a Food Defense Plan for Meat and
Poultry Slaughter and Processing Plants (June
2008)
http://www.fsis.usda.gov/PDF/Food_Defense_Plan.
pdf
 FSIS check list (Dec. 2007)
http://www.fsis.usda.gov/PDF/Slaughter_Plant_Che
cklist.pdf
 FDA Food Defense Self Assessment Tool for Food
Producers, Processors, and Transporters
http://www.cfsan.fda.gov/~acrobat/secgui14.pdf
15
Conduct an Assessment (con’t)
 Choose one or more checklists.
 Consider any other areas of potential risks
and vulnerabilities.
 Record what is already being done or partially
done.
16
Areas to Consider: Food Defense
Management
 Do you have a food defense plan?
 Is someone responsible?
 Do you have related necessary plans, such as
product withdraw or recall and personnel
emergency or evacuation procedures?
17
Areas to Consider: Outside Defense
Measures
 Do you keep doors
closed?
 Do you have a fence?
 Is there adequate
lighting?
 Do you control access
by people and vehicles?
18
Areas to Consider: Inside Defense
Measures
 Do you use surveillance?
 Do you have alert systems?
 Do you control access?
 Do you take inventory?
19
Areas to Consider:
Slaughter/Processing Measures
 Are animals or batches or product exposed to
tampering?
 Are areas or equipment left unobserved?
 Will employees report
unusual situations?
20
Areas to Consider: Storage
 Is access limited?
 Is inventory maintained?
 Can the impact of an attack
be minimized?
21
Areas to Consider: Shipping and
Receiving
 Are trailers sealed?
 Are drivers identified and deliveries
scheduled?
 Are all vendors selected thoughtfully?
 Are returned goods examined closely?
22
Areas to Consider: Water, Ice, and
Ingredients
 Are water lines secure?
 Is ice-making equipment protected?
 Are all bulk ingredients protected when not in
use?
23
Areas to Consider: Mail
 Is mail opened away
from other areas?
 Are procedures
understood for
handling suspect mail?
24
Areas to Consider: Personnel
 Are background checks completed?
 Are personnel supervised?
 Are employees trained?
 Are lockers inspected?
 Are cameras allowed?
25
Plan
 Now that you know where you are, plan to
remain at least as good as you are today.
 If you don’t follow up, the plan may not be
happening as you expect.
 Document what you have learned.
26
Compare
 Compare where you are to where you could
or should be. Review what you have not done.
 Any NO answer on the checklist may be a
vulnerability.
 Consider any other vulnerabilities not
addressed.
 Document what is not as good as it could be.
27
Plan Again
 With over 120 suggested measures and a list
of potential vulnerabilities—where do you
start?
 Decisions should be supportable.
 Actions must be based on a risk analysis.
 A method is needed to know—which
measures might matter most?
28
Discussion Question
 Of the areas discussed,
which one is most
important?
• Management
• Outside Security
• Inside Security
• Slaughter/Processing
• Storage
• Shipping/Receiving
• Water, Ice, Ingredients
• Mail
• Personnel
29
30
Factors of an Attractive Target
The CARVER + Shock method—an
assessment tool to identify areas of high
risk.
CARVER + SHOCK METHOD
 A series of questions addresses each area
and leads to calculated risk factors.
 This can lead to a functional food defense
plan by combining the checklist (a “to-do” list)
and the risk factors (a way to prioritize the
list).
 Simple—right?
31
CARVER + SHOCK METHOD (con’t)
C—Criticality
A—Accessibility
R—Recuperability
V—Vulnerability
E—Effect
R—Recognizability
+
SHOCK
32
C—Criticality
How serious are the public health and economic
impacts of an attack at this point?
 Number of lives lost
 Number of dollars lost or spent
33
A—Accessibility
How easily can an attacker learn about and
reach the target?
 Information availability
 Physical or human barriers
34
R—Recuperability
How long would it take to overcome the
damage?
 Physical and economic damage
 Psychological damage
35
V—Vulnerability
How easily could an attack achieve the desired
effect?
36
E—Effect
What percentage of your productivity would be
damaged?
 One line or one plant
 One product or all products
 One customer or a group of customers
37
R—Recognizability
How easily can a target be found and attacked?
38
SHOCK
How deeply would an attack impact people?
 Employees/community/nation
 Symbolism/history
39
Discussion Question
 What advantages
and disadvantages
do you see with the
CARVER method?
40
41
CARVER + SHOCK Guidance
The CARVER + Shock Primer
http://www.fsis.usda.gov/PDF/CARVER.pdf
Using the CARVER + SHOCK
Software
 Step 1: Download FREE software:
http://www.cfsan.fda.gov/~dms/carverdl.html
 Step 2: Insert your process flow chart.
 Step 3: Answer about 50 questions per step.
42
Too Many Questions!
 Answer 120 checklist questions?
 Answer 50 questions per step in your process
flow?
 Document and respond to all this?
 There’s an easier way …
43
Combine Methods and Prioritize
Risk
 Not all CARVER questions are applicable to
you.
 Use the questions best suited to your process.
 Prioritize with a simple, logical format.
 Write your plan.
 Ready?
44
Blank Sample Plan—
Individual Exercise
 Review and complete as much as possible of the
introduction and prevention sections of the Blank
Sample Plan. (pages 1–13)
 The left-hand columns in the tables indicate the status
of suggested food defense measures:
X indicates an item is not applicable to your facility.
 indicates a measure is implemented at your facility.
I indicates either incomplete or not implemented.
These items will be further considered in a risk
analysis worksheet.
45
Food Defense Risk Worksheet—
Group Exercise
 Select one or two defense areas per group
 Discuss those defense measures and rate the
potential impact on improving prevention
 On the worksheet, list the items you marked
with an ‘I’ in your Blank Sample Plan
 Determine the score for each item based on
impact and status
46
Food Defense Risk Worksheet—
Group Exercise
 Determine the score for each item based on
impact and status
 Is the potential impact minor (1), significant
(5), or major (10)? Enter: 1, 5,or 10
 Is this complete (1), partially complete (5), or
not started (10)? Enter: 1 , 5, or 10
 Score: Multiply the 2 scores and enter the
result.
47
Food Defense Plan Prevention
Group Discussion
Each group will summarize their findings.
What were the most common items not yet
implemented?
Of these, which were determined to be most
important?
48
Agency Response—FSIS Directive
Series 5420.1–5420.8
 During elevated threat levels (yellow, orange, red),
defense verification procedures must be followed.
 Results are documented:
• A—acceptable, or
• S—indicating a concern but no evidence of
adulteration, or
• T—there is evidence of adulteration and issue an
NR
 Plant should respond to the memorandum of interview
(MOI).
49
Agency Response—FSIS Directive
5500.2–5500.4
 Defines how communication is ensured for
non-routine incident
 Defines how to secure intentionally
adulterated product and how to oversee
disposal/decontamination activities
 Establishes how Incident Investigation Teams
can be formed and used
50
Agency Response—FSIS Directive
8080.1
 Provides instruction for recalling meat and
poultry products
51
Company Response
 Communication is the key to all crisis
management programs. Update contact lists
and keep them with you.
 Ensure safety of personnel and consumers.
 Stop all activity that might increase damage.
 Prepare for external communication to dispel
fear and increase confidence for recovery.
52
Blank Sample Plan—
Individual Exercise
 Review and complete as much as possible of the
incident response sections of the Blank Sample Plan.
(pages 14–17)
 The left-hand columns in the tables indicate the status
of suggested food defense measures:
X indicates an item is not applicable to your facility.
 indicates a measure is implemented at your facility.
I indicates either incomplete or not implemented.
These items will be further considered in a risk
analysis worksheet.
53
The Food Defense Risk Worksheet—
Group Exercise
 Select one or two incident response areas per
group
 Discuss those defense measures and rate the
potential impact on improving prevention
 On the worksheet, list the items you marked
with an ‘I’ in your Blank Sample Plan
 Determine the score for each item based on
impact and status
54
55
Food Defense Plan Prevention
Group Discussion
Each group will summarize their findings.
What were the most common items not yet
implemented?
Of these, which were determined to be most
important?
56
Recommendations
Finish the Plan
Implement the Plan
Reassess Annually
57
Tampering Laws
FEDERAL ANTI-TAMPERING ACT
U.S.C. TITLE 18 - CRIMES AND CRIMINAL
PROCEDURE
PART I - CRIMES
CHAPTER 65 - MALICIOUS MISCHIEF
58
Resources
 FSIS checklist (December 2007):
http://www.fsis.usda.gov/PDF/Slaughter_Plant_Checklist.pdf
 FSIS primer:
http://www.fsis.usda.gov/PDF/CARVER.pdf
 Federal anti-tampering law:
http://www.fda.gov/opacom/laws/fedatact.htm
 USDA Guidance:
http://www.fsis.usda.gov/Food_Defense_&_Emergency_Response/
Guidance_Materials/index.asp#Industry
Resources (con’t)
 Podcasts:
http://www.fsis.usda.gov/News_&_Events/Food_Safety_Insp
ection_Podcasts/index.asp
 Food Defense Plan worksheet:
http://www.fsis.usda.gov/PDF/Slaughter_Plant_Plan.pdf
 Free online course hosted by FDA:
http://www.fda.gov/ora/training/orau/FoodSecurity/default.htm
http://www.fsis.usda.gov/Science/Resources_&_Information/i
ndex.asp
59

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Food-Defense Presentation by Mr Javad.ppt

  • 1. 1 Developing Food Defense Plans Presented by Cathy Crawford HACCP Consulting Group, LLC For FSIS “How To Workshops” Spring 2009
  • 2. Objectives  By the end of this workshop, you will be able to • Define food defense • Understand why food defense is important • Develop your own food defense plan 2
  • 3. What Is Food Defense?  Food defense is not food safety.  Food safety addresses predictable and unintentional risks. Food safety is best addressed through HACCP.  Food defense addresses intentional attacks on the safety or quality of food. It is not well suited to HACCP. 3
  • 4. Why Be Concerned?  Intentional contamination has happened and can happen again. • Oranges with mercury – Israel, 1978 • Salad bars with Salmonella – Oregon, 1984 • Cookies with needles, St. Louis, 1984 • Fast food with rat poison, China, 2002 • Ground beef with nicotine – Michigan, 2003 4
  • 5. Why Be Concerned?  1994: A tanker was accidentally contaminated resulting in an estimated 224,000 illnesses.  2009: What if it wasn’t accidental? What if it was a tanker of oil for frying meat/poultry? 5
  • 6. Who Would Do This?  Terrorists or Activists  Competitors  Disgruntled employees 6
  • 7. Why?  Anger over national, business, or personal differences  Seeking changes in culture  Seeking economic disruption  Seeking public fear  Seeking harm to others 7
  • 8. Why Me? Factors that increase risk:  Making large batches of food  Foods with short shelf lives  Uniformly mixed products  Products that reach key populations  Ease of access 8
  • 9. Imagine—What If?  People are ill, injured, or even dying.  Your company name and product are involved.  A recall is initiated.  Production is halted—jobs lost.  Financial losses occur locally and even nationally. You are asked, “What did you do to prevent this?” 9
  • 10. FSIS Survey Findings: Percentage of Plants with Food Defense Plans  August 2006: 27% of establishments have plan  November 2007: 31% of establishments have plan  August 2008: 41% of establishments have plan FSIS goal: 90% of establishments have food defense plan 10
  • 11. 11 Why Write a Plan?  Writing it down will improve it.  Insurance companies and audits request a plan.
  • 12. Objectives Review  Defining Food Defense  Understanding why it matters  Develop a Plan 12
  • 13. How to Develop a Plan? 1. Conduct a self assessment. Know where you are today. 2. Plan to stay as good or become better. 3. Compare to where you could/should be tomorrow or next year. Find vulnerabilities. 4. Plan and prioritize a way to improve. 5. Implement and update the plan. 13
  • 14. Discussion Question  What obstacles have you encountered when creating or improving your food defense plan? 14
  • 15. Conduct an Assessment  Developing a Food Defense Plan for Meat and Poultry Slaughter and Processing Plants (June 2008) http://www.fsis.usda.gov/PDF/Food_Defense_Plan. pdf  FSIS check list (Dec. 2007) http://www.fsis.usda.gov/PDF/Slaughter_Plant_Che cklist.pdf  FDA Food Defense Self Assessment Tool for Food Producers, Processors, and Transporters http://www.cfsan.fda.gov/~acrobat/secgui14.pdf 15
  • 16. Conduct an Assessment (con’t)  Choose one or more checklists.  Consider any other areas of potential risks and vulnerabilities.  Record what is already being done or partially done. 16
  • 17. Areas to Consider: Food Defense Management  Do you have a food defense plan?  Is someone responsible?  Do you have related necessary plans, such as product withdraw or recall and personnel emergency or evacuation procedures? 17
  • 18. Areas to Consider: Outside Defense Measures  Do you keep doors closed?  Do you have a fence?  Is there adequate lighting?  Do you control access by people and vehicles? 18
  • 19. Areas to Consider: Inside Defense Measures  Do you use surveillance?  Do you have alert systems?  Do you control access?  Do you take inventory? 19
  • 20. Areas to Consider: Slaughter/Processing Measures  Are animals or batches or product exposed to tampering?  Are areas or equipment left unobserved?  Will employees report unusual situations? 20
  • 21. Areas to Consider: Storage  Is access limited?  Is inventory maintained?  Can the impact of an attack be minimized? 21
  • 22. Areas to Consider: Shipping and Receiving  Are trailers sealed?  Are drivers identified and deliveries scheduled?  Are all vendors selected thoughtfully?  Are returned goods examined closely? 22
  • 23. Areas to Consider: Water, Ice, and Ingredients  Are water lines secure?  Is ice-making equipment protected?  Are all bulk ingredients protected when not in use? 23
  • 24. Areas to Consider: Mail  Is mail opened away from other areas?  Are procedures understood for handling suspect mail? 24
  • 25. Areas to Consider: Personnel  Are background checks completed?  Are personnel supervised?  Are employees trained?  Are lockers inspected?  Are cameras allowed? 25
  • 26. Plan  Now that you know where you are, plan to remain at least as good as you are today.  If you don’t follow up, the plan may not be happening as you expect.  Document what you have learned. 26
  • 27. Compare  Compare where you are to where you could or should be. Review what you have not done.  Any NO answer on the checklist may be a vulnerability.  Consider any other vulnerabilities not addressed.  Document what is not as good as it could be. 27
  • 28. Plan Again  With over 120 suggested measures and a list of potential vulnerabilities—where do you start?  Decisions should be supportable.  Actions must be based on a risk analysis.  A method is needed to know—which measures might matter most? 28
  • 29. Discussion Question  Of the areas discussed, which one is most important? • Management • Outside Security • Inside Security • Slaughter/Processing • Storage • Shipping/Receiving • Water, Ice, Ingredients • Mail • Personnel 29
  • 30. 30 Factors of an Attractive Target The CARVER + Shock method—an assessment tool to identify areas of high risk.
  • 31. CARVER + SHOCK METHOD  A series of questions addresses each area and leads to calculated risk factors.  This can lead to a functional food defense plan by combining the checklist (a “to-do” list) and the risk factors (a way to prioritize the list).  Simple—right? 31
  • 32. CARVER + SHOCK METHOD (con’t) C—Criticality A—Accessibility R—Recuperability V—Vulnerability E—Effect R—Recognizability + SHOCK 32
  • 33. C—Criticality How serious are the public health and economic impacts of an attack at this point?  Number of lives lost  Number of dollars lost or spent 33
  • 34. A—Accessibility How easily can an attacker learn about and reach the target?  Information availability  Physical or human barriers 34
  • 35. R—Recuperability How long would it take to overcome the damage?  Physical and economic damage  Psychological damage 35
  • 36. V—Vulnerability How easily could an attack achieve the desired effect? 36
  • 37. E—Effect What percentage of your productivity would be damaged?  One line or one plant  One product or all products  One customer or a group of customers 37
  • 38. R—Recognizability How easily can a target be found and attacked? 38
  • 39. SHOCK How deeply would an attack impact people?  Employees/community/nation  Symbolism/history 39
  • 40. Discussion Question  What advantages and disadvantages do you see with the CARVER method? 40
  • 41. 41 CARVER + SHOCK Guidance The CARVER + Shock Primer http://www.fsis.usda.gov/PDF/CARVER.pdf
  • 42. Using the CARVER + SHOCK Software  Step 1: Download FREE software: http://www.cfsan.fda.gov/~dms/carverdl.html  Step 2: Insert your process flow chart.  Step 3: Answer about 50 questions per step. 42
  • 43. Too Many Questions!  Answer 120 checklist questions?  Answer 50 questions per step in your process flow?  Document and respond to all this?  There’s an easier way … 43
  • 44. Combine Methods and Prioritize Risk  Not all CARVER questions are applicable to you.  Use the questions best suited to your process.  Prioritize with a simple, logical format.  Write your plan.  Ready? 44
  • 45. Blank Sample Plan— Individual Exercise  Review and complete as much as possible of the introduction and prevention sections of the Blank Sample Plan. (pages 1–13)  The left-hand columns in the tables indicate the status of suggested food defense measures: X indicates an item is not applicable to your facility.  indicates a measure is implemented at your facility. I indicates either incomplete or not implemented. These items will be further considered in a risk analysis worksheet. 45
  • 46. Food Defense Risk Worksheet— Group Exercise  Select one or two defense areas per group  Discuss those defense measures and rate the potential impact on improving prevention  On the worksheet, list the items you marked with an ‘I’ in your Blank Sample Plan  Determine the score for each item based on impact and status 46
  • 47. Food Defense Risk Worksheet— Group Exercise  Determine the score for each item based on impact and status  Is the potential impact minor (1), significant (5), or major (10)? Enter: 1, 5,or 10  Is this complete (1), partially complete (5), or not started (10)? Enter: 1 , 5, or 10  Score: Multiply the 2 scores and enter the result. 47
  • 48. Food Defense Plan Prevention Group Discussion Each group will summarize their findings. What were the most common items not yet implemented? Of these, which were determined to be most important? 48
  • 49. Agency Response—FSIS Directive Series 5420.1–5420.8  During elevated threat levels (yellow, orange, red), defense verification procedures must be followed.  Results are documented: • A—acceptable, or • S—indicating a concern but no evidence of adulteration, or • T—there is evidence of adulteration and issue an NR  Plant should respond to the memorandum of interview (MOI). 49
  • 50. Agency Response—FSIS Directive 5500.2–5500.4  Defines how communication is ensured for non-routine incident  Defines how to secure intentionally adulterated product and how to oversee disposal/decontamination activities  Establishes how Incident Investigation Teams can be formed and used 50
  • 51. Agency Response—FSIS Directive 8080.1  Provides instruction for recalling meat and poultry products 51
  • 52. Company Response  Communication is the key to all crisis management programs. Update contact lists and keep them with you.  Ensure safety of personnel and consumers.  Stop all activity that might increase damage.  Prepare for external communication to dispel fear and increase confidence for recovery. 52
  • 53. Blank Sample Plan— Individual Exercise  Review and complete as much as possible of the incident response sections of the Blank Sample Plan. (pages 14–17)  The left-hand columns in the tables indicate the status of suggested food defense measures: X indicates an item is not applicable to your facility.  indicates a measure is implemented at your facility. I indicates either incomplete or not implemented. These items will be further considered in a risk analysis worksheet. 53
  • 54. The Food Defense Risk Worksheet— Group Exercise  Select one or two incident response areas per group  Discuss those defense measures and rate the potential impact on improving prevention  On the worksheet, list the items you marked with an ‘I’ in your Blank Sample Plan  Determine the score for each item based on impact and status 54
  • 55. 55 Food Defense Plan Prevention Group Discussion Each group will summarize their findings. What were the most common items not yet implemented? Of these, which were determined to be most important?
  • 56. 56 Recommendations Finish the Plan Implement the Plan Reassess Annually
  • 57. 57 Tampering Laws FEDERAL ANTI-TAMPERING ACT U.S.C. TITLE 18 - CRIMES AND CRIMINAL PROCEDURE PART I - CRIMES CHAPTER 65 - MALICIOUS MISCHIEF
  • 58. 58 Resources  FSIS checklist (December 2007): http://www.fsis.usda.gov/PDF/Slaughter_Plant_Checklist.pdf  FSIS primer: http://www.fsis.usda.gov/PDF/CARVER.pdf  Federal anti-tampering law: http://www.fda.gov/opacom/laws/fedatact.htm  USDA Guidance: http://www.fsis.usda.gov/Food_Defense_&_Emergency_Response/ Guidance_Materials/index.asp#Industry
  • 59. Resources (con’t)  Podcasts: http://www.fsis.usda.gov/News_&_Events/Food_Safety_Insp ection_Podcasts/index.asp  Food Defense Plan worksheet: http://www.fsis.usda.gov/PDF/Slaughter_Plant_Plan.pdf  Free online course hosted by FDA: http://www.fda.gov/ora/training/orau/FoodSecurity/default.htm http://www.fsis.usda.gov/Science/Resources_&_Information/i ndex.asp 59