Is Your Facility On ALERT For Intentional Food Contamination?
By Laurel Maloy, contributing writer, Food Online
All states have laws regarding the accidental or unintentional adulteration or contamination of food products. However, active prevention of intentional adulteration does not seem to be a priority
The FDA developed the voluntary ALERT program in response to increased reports of intentional food contamination. The full name is the ALERT Food Defense Awareness program. The basis for the program is the fact that our food supply is vulnerable to such attacks. From the farm to the fork, our foods are touched by many hands, go through a myriad of processing facilities, and are transported thousands of miles. To any person hell bent on touching the lives of the American people in a negative manner, the food supply is definitely one of the least-secure and most-susceptible means to an end.
Sometimes referred to as agro-terrorism, one of the earliest instances dates back to the First Sacred War (595-588 BC). Documented by the medical writer Thessalos, the Delphi warriors discovered —quite by accident — a water pipe leading into the city of Kirrha while they were laying siege. The pipe was inadvertently discovered and broken by a horse’s hoof. Upon the discovery, a priest came up with the idea to intentionally poison the water with white hellebore, the rationale being that the inhabitants would become too sick to repel the attack. It worked — the city’s defenders became so weak and dehydrated from the effects of the poison, they succumbed to the attack and all its inhabitants were slaughtered.
There is a history of agro-terrorism, though that particular term is quite new. The term most associated with instances of intentional food contamination or adulteration is biological warfare. In ancient times, water sources were purposely contaminated with animal carcasses and filth. Soldiers were known to allow unimpeded access by enemy forces into areas recognized as infected with such debilitating diseases as malaria. Smallpox was introduced to the Native American population in 1763 by the Fort Pitt commander. The smallpox outbreak at Ft. Pitt provided an opportunity for the commander to decimate a population. He simply gave a few Native Americans two blankets and a handkerchief from the hospital housing the small pox patients, “hoping it would have the desired effect.” It did.
FSMA Fridays: The Food Defense Rule
If there is one thing that is sometimes glaringly apparent in our high-tech world, it is the fact that getting back-to-basics is sometimes the most-effective solution to a problem. Agro-terrorism is a real and conceivable threat. The FDA’s ALERT program addresses this threat by focusing on protecting the nation’s food infrastructure just as other agencies concentrate on protecting physical and data-based infrastructures. ALERT, in my opinion, is one of the best, governmental acronyms in terms of describing a program that warrants our undivided attention:
Assure
This pertains to knowing and properly vetting suppliers. A facility should be assured, or confident, that the ingredients, packaging, chemicals, and services provided are from safe and secure sources. Beware the price that sounds too good to be true from a new supplier.
Look
This pertains to looking after, as in scrutinizing the security of the products once they are within your capacity to control. Tracking the materials as they go from loading dock to storage to processing is critical — if an intentional contamination is suspected, the source can be more-quickly identified. The FDA also suggests implementing a comprehensive system for product handling and tracking the finished product. Storing product labels in a secure location and destroying any old labels will further prevent product tampering that could lead to serious illness or death.
Employees
A company’s workers are a critical component of the ALERT system. A lower-level employee is the person most likely to be successful at intentional food contamination. Background checks should be conducted on future employees, while current employees should have photo identification tags and have access only to those areas pertinent to their position. Visitors should be limited and controlled as well.
Reports
Documentation is also critical. The establishment and maintenance of records pertaining to all aspects of your ALERT program will help immensely in the face of an incidence of agro-terrorism. Document how you’ve vetted your suppliers, as well as each supplier’s contact information. Document how you track and monitor product security and maintain employee background checks and employment information — including disciplinary incidents — all in one place. Meticulous reporting provides an analyst with the information necessary to identify the potential source.
Threat
Finally, in the face of a threat, key personnel should know exactly who to contact and how best to contact the proper authorities. Establish and practice a protocol to respond to a suspected contamination. Include contact information, the order in which to communicate, and a form to document all of the communication. Also implement a procedure for holding any product still in the plant and for recalling any product that has entered commerce.
Guest Column: It’s More Than Food Defense
FSMA further addresses these concerns in its proposed rule for Focused Mitigation Strategies to Protect Food Against Intentional Adulteration. Currently in effect since early this year, one year is allowed for compliance by all but those not deemed to be small or very small companies by the FDA. Very small businesses — those having less than $1 million in total annual food sales — have three years to comply. Small businesses — employing fewer than 500 people — have two years. The timeline for compliance is from 60 days after the rule’s publication in the Federal Register, which was last Christmas Eve.
Though the ALERT program is purely voluntary, FSMA is not. Implementing ALERT within your facility can help your company to satisfy some of FSMA’s requirements.