Preventing the willful contamination of food means more than just keeping ingredients pure. Intentional adulteration can strike at any point, from raw products to finished goods. Your food defense plan must make provisions for food production and storage, access to those operations, and even your plant utilities.
The areas where food is processed and held for delivery are the most susceptible to adulteration. Food is often moving unprotected through a facility, and even the watchful eye of supervisors cannot cover the entire line. These areas are targets for intentional adulteration, and protecting them should serve as the backbone of your food defense plan.
Employees can be the first line of deterrence for your production and storage areas because they are your eyes on the production floor. Employees can see signs of adulteration, report suspicious behavior, and prevent harm. Making sure that they are familiar with the FDA’s See Something, Say Something plan, and empowered to act on it, can help prevent adulteration.
That's doubly important because these same employees can be your single largest source of adulteration, either by intentionally sabotaging food or just by showing up to work sick. In the second half of 2015, the Chipotle fast-food chain had norovirus outbreaks in five different states that were likely caused by a sick store employees processing food. The company moved processing of some ingredients back to central kitchens and implemented a new, corporate-wide food safety program. But that didn't stop all norovirus outbreaks: In July 2017, an ill store employee in Washington, D.C. caused 130 customers to get sick and the subsequent five-day slide in Chipotle's stock price cut $1 billion off its market cap. Supervisors need to take responsibility for preventing this kind of harm.
Once food is processed, it is also extremely sensitive to adulteration because it is often placed in a warehouse or freezer, and left unmonitored until shipping.
You may already inspect food in storage, but to prevent adulteration, your food defense plan should mandate more. Conduct regular audits and inspections in food storage areas to look for signs of adulteration. Reject any stored product that has been tampered with or stored improperly.
Covers for food at each stage of production should also factor into the plan. Food left uncovered is susceptible to environmental contamination, intentional adulteration, as well as bacteria from sick employees. In 2012, the U.D. Food & Drug Administration (FDA) linked 29 cases of Salmonella to Sunland's peanut butter production facility in New Mexico. The FDA found that improper storage and a lack of food covering led to many different types of Salmonella. Sunland, which was the leading maker of organic peanut butter at the time, had to recall 76 different types of nut butters. The company never recovered from the recall and filed for Chapter 7 bankruptcy liquidation in 2013. Remember that, under the Food Safety Modernization Act (FSMA), your business and its executives can be held personally responsible for food adulteration.
Locks, Monitors, and Cameras
Not everyone should have access to every system in your facility, and especially not outside actors. The importance of locks, monitors, and cameras in preventing and logging cases of intentional adulteration cannot be overstated.
Locks prevent unauthorized staff and outside agents from accessing sensitive food storage and production areas. This prevention becomes particularly important when managing food defense plans, because your plan should specify which areas are open to which employees. Labs and food testing areas in particular should require multiple forms of authorization, including keys, codes, and badging.
Monitors and cameras serve as active and passive defense against intentional adulteration. Human monitors watch over sensitive areas for any changes or signs of adulteration, and their presence is likely to dissuade any activity. Cameras also serve as a deterrent, and log any activity for later audit or legal action.
Think about less common badging situations as well when building the plan. Visitor access points can be an avenue for adulteration if not monitored, while secure lids and seals on even the smallest openings can prevent harm. The FDA expects your plan to cover visitors, as well as delivery crews, third parties, and anyone else entering production and storage without proper credentials or training.
Utilities and Infrastructure
The security of utilities and infrastructure is addressed in general emergency plans, but not often in food defense plans. It should be: By harming these core systems, an actor can commit intentional adulteration without even touching your food supplies.
Shutting off electricity can lead to tons of food spoiling, or cause small differences in storage temperatures that promote bacteria growth. Water can be contaminated or disabled, potentially reaching the production line and spoiling product. Alteration to core infrastructure like supply containers or conveyor belts can lead to closed production lines at the least, and a contaminated food supply at worst.
Ensure that your food defense plan includes considerations for protecting your infrastructure and utilities. These areas should be subject to the same protections as your food storage and processing areas, and should undergo regular audit and review. Utilities often need to be redundant, so that in the event of an emergency, power and clean water can be maintained.
Building the Plan
These common access considerations should form the core of your food defense plan. According to the FDA, everything from doors and windows to storage facilities, lines, and even lids and seals should be considered in your plan. The FSMA regulations expect you to apply the same standards to the entire facility.
Finding every place susceptible to adulteration can be a tremendous challenge. Resources like the Food Defense Mitigation Strategies Database can help you identify gaps and build an extremely comprehensive plan.