Food Defence

In 2002, World Health Organization (WHO) said that ‘the malicious contamination of food for terrorist purposes is a real and current threat, and deliberate contamination of food at one location could have global public health implications’ ⁽⁶⁾. The same year, the World Health Assembly also expressed concerns about threats to the general population by the intentional use of agents in food ⁽⁸⁾.  In the Elliott Review ⁽⁹⁾ into the integrity and assurance of food supply networks, Professor Elliot states that ‘food crime is an emerging issue for all of Europe’, although it is not possible to know whether this is due to individuals, groups or organised criminal gangs.  In 2004, former American Secretary of Health and Human Services, Tommy Thompson, said ‘for the life of me, I cannot understand why terrorists have not attacked our food supply, because it is so easy to do’.

Of all industrial or infrastructure-related activities, the food supply is the most complicated system in the world. It is a fairly easy target and with a potentially high number of people that would be impacted, with those foods that have a uniform distribution, short shelf life (rapid distribution and consumption by consumers), reach key populations or are made in large batches, being particularly vulnerable to intentional contamination.  Modern bioterrorism attacks on the food chain could be conducted for personal or business extortion, financial gain through counterfeiting, political influence, corporate sabotage or destruction of a brand or company image, and/or destruction of an economic sector. Materials reportedly discovered in Al Qaeda training camps in Afghanistan showed that the group had knowledge and potential to be able to contaminate the food supply ⁽¹⁰⁾ and a cell of Jamaah Ansharut Daulah, in Indonesia, plotted a suicide attack utilising abrin⁽¹¹⁾ (a natural poison extracted from the seeds of the rosary pea) - which could also be used to contaminate food. However, there have been few terrorist attacks on food reported to date ⁽¹²⁾ and given the history of incidents it is more likely that a threat to an organisation will come from an ‘insider’.

Deliberate contamination of food products can have public health consequences (on the population and resources available to deliver healthcare), widespread public fear, economic impacts for food manufactures and countries (foodborne illness is very costly), disruption of trade, a loss of confidence in the safety of food by consumers and a loss of confidence in the government.  Intentional adulteration of food can be difficult to anticipate and prevent, plus is designed to evade detection. Contaminants may often be unconventional.

With the global nature and length of the supply chain, food manufactured in one country can have a large effect on others.  There are a wide variety of hazards that can be considered in food defence, which can be broken down into biological, chemical, physical and radio-nuclear hazards.

In food defence there may be no direct precedent from which to learn, statistics may be immaterial and it unlikely that there will be any environmental or ecological principles which can be used. The size of the threat depends upon:

• motivation, innovation and capability of the would-be attacker
• vulnerability of the site or process targeted
• prospective impact of a successful attack.

1. Biological

Delivery through food to cause disease by biological agents in liquid, solid or aerosol form.  Can be achieved by utilising an animal or plant variety to destroy crops and livestock for political or economic means.  Biological agents could be used to cause foodbourne illness. Potential agents include Salmonella and Listeria which could cause mass human casualties, and Vibrio cholera which can also cause severe economic loss.

2. Physical

Diabetic needles, sewing needles and glass have been used to deliberately adulterate food products. In 2005, bread was found in to be contaminated with glass and needles, in UK. Tampering incidents are often not widely published by regulatory bodies for fear of copycats. Physical hazards can also include damage to infrastructure or equipment.

3. Chemical

A wide range of chemical agents that are likely to cause foodborne illness, and could be used to intentionally adulterate food, includes agri-chemicals such as insecticides, poisons (cyanide or strychnine), melamine and naturally occurring toxins (e.g. from poisonous mushrooms) could be used to adulterate food.  In 1980, in Pittsburgh (USA), a town’s water supply was intentionally contaminated with pesticide.  The water supply had to be shut down for two weeks and water was brought in for residents ⁽¹⁴⁾. Many of the chemicals are odourless, colourless and tasteless so adulteration would not be detected until foodborne illness in consumers occurred.

4. Radio-nuclear

Intentional contamination of radio-nuclear agents through food and drink would be likely to cause widespread panic, prevent the provision of food or water suppliers, or force multiple widescale recalls.  An attack of this nature could include long-term contamination of water treatment plants and supply systems, markets, supermarkets and food manufacturing facilities.  Given the very large amounts of radioactive material needed, to cause rapid causalities and fatalities, it is likely that an incident of this type would only affect a small number of people ⁽¹⁴⁾.  In 2006, Alexander Litvinenko was poisoned by Polonium-210 and tests by the Health Protection Agency showed that the poison was in his teacup.

v. Financial

These types of hazards can include the threat, or claim of an attack, commercial espionage and extortion.

While a food defence plan is in some respects similar to a HACCP plan, it generally should not be managed by a site’s Quality Assurance or Technical Manager, as there can be conflicts between the two plans.  The food defence plan should be treated as highly confidential by the site, to avoid giving away the site’s weaknesses and response plans.  A food defence plan assesses the current security conditions, and risk mitigation measures already in place, to prevent intentional food contamination and sets out control measures, that have been developed by a team at a specific facility, to prevent intentional adulteration of raw materials and food products.  The plan must be developed (assessing where issues may arise and reduce any identified risks), written, implemented, tested, verified and maintained, if it is to be functional and ‘live’ document.  Internal and external threats are constantly evolving, so a plan needs to be reviewed frequently. Control measures should be developed by an establishment to prevent intentional adulteration of a product, bearing in mind that zero risk is unachievable. Procedures and policies are people-focused, as malicious intent or act require an individual or group of people. An attacker is likely to want to see a short-term impact (such as with foodborne illness), so long-term effects such as chronic disease are not a major concern.  Developing a food defence plan does not require the creation of another HACCP-type document, although does require a vulnerability assessment. A sites current HACCP plan, including Sanitation Standard Operating Procedures (SSOP), GMPs, training, crisis management procedures etc. can be used to help develop a food defence plan.

Step 1 - Food defence assessment

Choose a team to be responsible for the security of your perimeter, facility and processes. To understand which parts of the facility may be more vulnerable to threats, conduct a vulnerability assessment (numerous checklists are widely available on the internet). Potential internal and external threats should be considered. 

Step 2 - Develop a food defence plan

Once the areas of vulnerability have been identified (exterior or interior of the site, procedures used on daily operations etc.) identify preventative actions that are cost effective, realistic and based on risk assessment to minimise the vulnerabilities.  Receiving, processing, storage and shipping security and water/ice security is the minimum that should be considered.

Step 3 - Implement the food defence plan

The key elements of effective plan implementation are assigning responsibilities (who implements, manages and updates the plan), training staff (in all provisions of the plan, so that employees know their responsibilities), developing contact lists (including police, government and environmental health officials, suppliers, customers), and checking the facility’s recall plan (up to date and tested at a minimum within the last year).

Step 4 - Test the plan

Plans can be tested in a variety of ways, including mock recalls (at the same time as the HACCP plan and food defence), mock incidents/simulations, drills and tabletop exercises. A post-event evaluation, with lessons learned, should be conducted with corrective actions agreed and implemented. Ways to test the plan include: reviewing signage, procedures, inventory, employee access cards and visitor logs.

Step 5 - Manage the plan

Consider how the plan will be managed in the long term.  This can include annual reviews and periodic tests, to see if the plan still effectively reduces the risks of intentional contamination, or needs to be updated.  Changes to operations, construction work, addition of new technology, a new supplier or raw material, a contamination incident at a competitor, are examples of what should also trigger a review.

A robust food defence plan will typically contain:

1. Security management, which should include:

1. physical controls that prevent access, such as fences, security guards, turnstiles etc.
2. technical controls, including swipe cards, cameras, specialised hardware/software, including firewalls
3. administrative controls (policies, procedures).

2. Personnel measures including:

1. Screening - pre-hiring, hiring, post-hiring
2. Daily work assignments - where should operatives be?  How do you identify employees with access to certain areas?
3. Identification and restricted areas - access identification and security checks, daily work assignments, e.g. what areas should operatives be in and how to identify them?
4. Personal items - what are you allowed to bring on site (hunting guns, ammunition, personal medications etc.). Can employees bring portable recording equipment on site?
5. Training in food security procedures - everyone should be trained in expectations and empowered to ask people for identification
6. Leaving procedures - are access codes changed and entry passes recovered?

3. How visitors to the site are identified and accompanied:

1. Visitors, including customers, reporters, tour groups, supplier representatives etc.
2. Regulatory - health and safety, food safety, labour
3. Contractors/service providers e.g. laundry, maintenance contractors, delivery drivers, couriers, pest control representatives

4. Facility

1. Physical security
2. Laboratory safety
3. Storage and use of poisonous and toxic chemicals e.g. cleaning and sanitising agents, pesticides
4. Storage and items that may be used as physical contaminants: nails, injection needles, blades etc.
5. Operations
6. Incoming materials and contract operations
7. Production processes e.g. weighing, mixing
8. Storage
9. Security of water and utilities
10. Mail packages
6. Access to computer systems and prevention of cyber attacks

The PAS 96:2017 guide to protecting and defending food and drink from deliberate attack provides some approaches to the potential problems of intentional attack, on the food and drink industry, to help businesses deter potential attackers. It is not a certification,  however major UK companies may expect a supplier to comply with the standards set out in the guidance document ⁽²⁶⁾_.

FDA’s ‘CARVER plus Shock’ ⁽²⁷⁾ is a method of vulnerability assessment which offensively targets priorities, by breaking down a food system or process into small pieces. The tool helps to identify the vulnerabilities within a system, or infrastructure, to a malicious attack. It gives the food defence team the opportunity to think like an attacker and identify the most attractive targets for contamination. The focus can then be on resources to protect facilities most vulnerable points. 

CARVER is an acronym for six attributes are used to evaluate the attractiveness of a target for attack: criticality, accessibility, recuperability, vulnerability, effect and recognisability. A seventh attribute is evaluated in the modified CARVER tool for combined health, economic, and psychological impacts of an attack, or the Shock attributes of a target (CARVER plus Shock).

A ranking scale is used for the attractiveness of facilities, or processes, which may be vulnerable to deliberate contamination, and can be used to help identify where an attack is most likely to occur within a facility.

Threat Assessment and Critical Control Points (TACCP) is a systematic management process aimed at preventing malicious contamination in foods. It is similar to HACCP, in that it is based on risk assessment, however it often needs a wider range of employees to be involved in the process than HACCP, as it includes Information technology and security.

A risk assessment matrix can help to visualise risks by evaluating and prioritising operational risks and assist management decision making. There are several versions including the severity/probablity matrix and 5x5 matrix.

Risk assessment matrix for use in evaluating hazards and threats⁽²⁸⁾

			Probability of food contamination
			Frequent	Likely	Occasional	Seldom	Unlikely
			A	B	C	D	E
Severity	Catastrophic	I
	Critical	II
	Moderate	II
	Negligible	IV
			Risk levels

Red = Extremely High, Amber = High, Yellow = Medium, Green = Low