No Food Safety without Food Defense
It is common knowledge that food industry sees a high rate of employee turnover – both in the food service sector which sees up to 100% annual turnover1, or manufacturing where labor shortages abound2. This may give some employers pause when asked “do you really know the employees in your facility?” While in general, close scrutiny and quality assurance measures are present to ensure employees are well-trained and adhering to good manufacturing practices, this is not necessarily enough.
Protection from unintentional contamination has been, for years, the foremost concern in food safety, and the industry is doing an increasingly thorough job across all steps of the process. However, where the scope of protection from inadvertent evil ends, there exists another, even more daunting, set of challenges. Shielding the process from intentional harm is a commonly overlooked arena, for many reasons. The risk of an incident is much lower than that of more mundane, traditional “food safety” topics, which are generally seen as the more imminent threat and so often get tackled first. Also, measures to prevent unintentional contamination are much more within our control, and it is comfortable to believe that once a HACCP plan is sound, everything is safe. A third reason is that food defense is partially outside of the range of duty and expertise for the everyday QA/food safety team, and so a comprehensive team must be built to include security experts as well. All too often, this is not the case, particularly in smaller operations and at the plant level even among large companies. Furthermore, even when a security system is functioning well to prevent outsiders from entering, the threat of harm from existing employees with nefarious intent is present. As touched on earlier, turnover and a large labor force in the food industry are a major challenge, and even if each and every person entering the building is vetted thoroughly, this still does not guarantee an absence of disgruntled workers being created over time, or of workers coming in with ill-intent but no prior record of criminal acts.
In the US, the Food Safety Modernization Act (FSMA)’s Final Rule on Mitigation Strategies to Protect Food Against Intentional Adulteration now requires a Food Defense plan (and a tool for developing a comprehensive plan is available for free via the FDA website3). For large operations, compliance deadline was last July, but smaller operations have upcoming deadlines, in July 2020 and 2021. A main focus of the rule is to prevent adulteration from terrorism, but it covers other eventualities as well, from disgruntled employees to food fraud.
How can you, even as part of a company with an existing, well-tested food defense plan, or as a small stand-alone plant, effectively improve your facility for the safety of yourself and others? There are many ways; the following are merely a few suggestions I have gleaned from experience and training as an FDQI, to get you thinking.
- Train your workforce on behaviors to watch out for in their coworkers, and provide incentives for reporting suspicious activity. Make sure they know how they can report (and to whom) in real-time; do not encourage them to directly confront a suspicious person or to wait until they get time to find a manager. This is good practice for general food safety issues as well.
- Designate employees to high-risk areas (ingredient storage, ready-to-eat (RTE) processing, warehouse) by trust level. Yes, this is difficult to measure, but you may want to classify employees by risk assessment (work with your human resources or legal team to develop a non-discriminatory but robust system – it may include multiple factors including length of employment, performance, completion of training programs, even recommendations from managers or fellow employees).
- Test your food defense plan regularly. Even if not required by law or audit scheme, this is essential and should include a physical drill, and repeatable under different circumstances (e.g. vary the shift, weekend vs. weekday, full staff vs. skeleton or backup crew if that is a possibility in your operation).
- If your drill fails to properly bar a security breach, treat this as an emergency need for corrective action, and repeat similar drills until the security threat is mitigated to a reasonable level. There will be cases where absent capital is needed to eliminate a certain risk, but there are always cost-effective solutions that can reduce a risk until the necessary capital is available. That said, do not treat security as a bottom of the list item – imminent risk may be low, but severity if that breach occurs could be catastrophic.
- Limit access and knowledge of your Food Defense Plan. Ensure that those who have access and contribute to the plan are well-trusted, have a buy-in to the process, and are themselves aware that they should not disclose confidential parts of the plan to others.
- Use technology to your advantage. I believe that this will be the future of food defense. Just as breaches in online security are able to be monitored with artificial intelligence, there are ways – both current and upcoming – to employ technology to your advantage in food defense. This can include real-time monitoring of key areas of your process that maps to an automated anomaly detection system, smart surveillance and alarm systems, electronic badges to let you know who is in different parts of the facility, and in the future, methods may come more readily available for advancements that already exist, such as rapid detection for anthrax and other agents of biological warfare4.
- Do not assume that your role in food defense begins and ends at your warehouse docks. Your food defense plan should include diligent provisions for incoming and outgoing product inspections, seal check procedures, transportation provider and supplier approval/monitoring (to the greatest extent possible), and swift action plans, should potential tampering be detected.
About the Author:
A foodie with 6 years of experience in Quality Assurance and a B.S. in Food Science from Penn State, Stephanie is an avid food safety advocate with a passion for reading, writing, and encouraging people to think about their role in assuring safe food for everyone. She is currently working on a Master’s Degree in Applied Data Science and feels that there is a need for more tech-centric solutions in the food industry.