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From: Food Quality & Safety magazine, October/November 2007

Lock Out Food Supply Threats

Whether by intention or sheer negligence, compromises on food product safety can cost dearly. Well-planned and executed systems, aided by appropriate technology and contingency planning, can help companies prepare for the worst

by Alan Naditz

For several weeks in September and October 1984, residents in the town of The Dalles, Ore., went about their business: they went to work, attended school, cleaned up their backyards, and followed the upcoming county elections. When it was time for dinner, many of them went to one of nearly a dozen local restaurants or purchased food from an in-town supermarket.

Shortly after eating, however, hundreds of these residents began to suffer from abdominal cramps, diarrhea, and vomiting. The cause—Salmonella typhimurium, a bacterium that had been sprinkled onto fruits and vegetables, mixed into bleu cheese dressing and potato salad, and dropped into coffee creamer and glasses of water. The culprit: a religious cult trying to gain control of the county by making people too sick to go to the polls.

If this sounds like the plot of the latest thriller at the multiplex, guess again. This malicious case of food tampering really happened; 751 people sickened by the bacterium and a town that became economically crippled can attest to that. And, as bizarre as it sounds, the non-lethal incident goes on record as America’s first and, thus far, only food-related bioterrorism attack.

Food Supply Vulnerability: Then and Now

Fast forward to the fall of 2006. An E. coli outbreak among more than 200 people leads to a nationwide recall of thousands of bags of fresh spinach. The incident, traced to a grower for Earthbound Farm, based in San Juan Bautista, Calif., costs the Monterey County Farm industry more than $100 million, according to the Western Growers Association.

Unlike the incident in Oregon 21 years earlier, there’s no evidence linking the spinach contamination to a terrorist act, so it cannot be considered bioterrorism, according to Marion Nestle, PhD, MPH, professor of nutrition at New York University in New York, N.Y., and author of Safe Food: Bacteria, Biotechnology, and Bioterrorism (University of California Press, 2004). But this recent incident and others do underscore the need for the food industry to take precautions against potential attacks in America.

“It comes down to safety,” Nestle says. “If our food supply is better prepared against food safety problems, then it will be better prepared against bioterrorism.”

But if it’s been more than two decades since the country’s only confirmed case of bioterrorism, should American companies even worry about it? Absolutely, says Michael Doyle, PhD, director of the University of Georgia’s Center for Food Safety in Griffin, Ga.

As the United States imports more food products from other countries each year, there’s a growing chance that some kind of biological contamination—terrorist-related or not—will hit American soil, according to Doyle. Non-intentional product contamination recalls have recently hit the nation’s seafood, produce, meat, and pet food industries, and intentional contamination efforts could happen almost as easily, he says.

“If somebody [overseas] really wanted to do something serious and damage our food supply, it wouldn’t be too hard,” Doyle says. “It could take many days to weeks before we figure out what was introduced. Depending on how widespread it was, it could take some time to figure out what the source is. There could be a lot of damage in between.”

The Economics of Food Safety

Product recalls and possible lawsuits stemming from injuries or deaths will cost affected companies a fortune, according to attorney Bill Marler of Marler Clark LLP. His Seattle law firm has filed—and won or settled—hundreds of food safety lawsuits in the past 15 years, to the tune of hundreds of millions of dollars.

There is also the long-term damage to corporate reputations to consider. “One of the desired effects of terrorism is loss of economic stability,” says Eddie Sorrells, chief operating officer and general counsel for DSI Security Services in Dothan, Ala. When the public hears that a major fast food chain’s burgers are tainted, they are simply going to stay away. “I’m not going to that chain for a while, and I’m not going to let my family go either,” Sorrells says.

The scenario he describes has played out several times over the years, even without the element of terrorism. Jack in the Box lost $138 million in two years after the 1993 E. coli outbreak that killed four people and sickened more than 600. Wendy’s lost $2.5 million in sales in the San Francisco Bay Area after the infamous “finger in the chili” hoax in 2005. In the fourth quarter of 2006, sales dropped 5% at Taco Bell after an E. coli outbreak made 71 customers ill.

Castleberry’s Food Company, in Augusta, Ga., is still dusting itself off after recalling more than 90 brands of canned chili, beef stew, and other meat products because of a botulism outbreak last July. Although the state’s Department of Food Safety attributed the outbreak to a random equipment malfunction, the damage, in the public’s eye, is already done. “It will be months, if not years, before Castleberry’s can regain whatever confidence it had among the consumers,” Sorrells says. “In these cases, it’s not always what actually happened—it’s what consumers believe can happen.”

Safety Starts at Home

The key to bioterrorism defense starts with a vulnerability assessment and a rock-solid food defense plan, according to Skip Seward, PhD, vice president of regulatory affairs at the American Meat Institute (AMI) in Washington, D.C. “Companies in our industry need to do what’s necessary to ensure that if there is an issue, they’re as well-prepared as they can be. They then need to really execute that plan on a day-to-day basis to minimize their risk.”

Food defense standards already exist at many meat, produce, and dairy product companies nationwide. While not specifically directed at preventing bioterrorist attacks, these standards are designed to ensure safe handling of food products in general, including safeguarding against intentional and accidental contamination, Nestle says.
“Everyone who is involved in preparing food should use a hazard plan—whether it’s called that or not—and bring in someone who understands how contamination can occur,” Nestle says. “Then you at least have things in place that are looking for the obvious areas where problems can occur, and you’re taking steps to prevent them. That seems minimal to me.”

Larger meat and poultry companies create and use food defense plans as a matter of course, according to Seward. But smaller facilities, which are typically family-owned, may not see the urgency. “In many cases, they know all their employees,” Seward says. “The idea of someone coming into the establishment as a terrorist and having access to the production facility is a lot less likely and would be easier to detect than in a larger establishment.”

When conducting a vulnerability assessment, facilities should perform a CARVER plus shock analysis, Seward says. The USDA’s Web site, at www.fsis.usda.gov, includes step-by-step guidelines for implementing the strategy at any facility. Key components are criticality, accessibility, recuperability, vulnerability, effect, recognizability, and shock (see Table 1, p. 22). The CARVER plus shock method will help to identify a series of critical nodes at your production facility—areas most vulnerable to some sort of disruption—according to Seward. From there, a company can develop mitigation strategies to deal with the critical nodes, and “that’s where the real challenges come in.”

Safer, but More Disruptions

One catch is that countermeasures that make a facility safer can also disrupt its production process, Seward says. A typical critical node in a meat plant might be a large, open hopper where meat products are blended. Someone with access could easily throw a lethal agent into the blender, sending it into the food product. “One of the obvious countermeasures would be to put a lid on the blender, so that someone cannot simply toss something into it,” Seward says. “But at the same time, the challenge is that there’s a reason no lid is on that blender to begin with: so you can observe what’s going on, so you can easily put proper materials in there, so people have access to it for cleaning and sanitation.”

Sorrells says that one of a company’s biggest critical nodes is often its most obvious: the front door. “One of the worst security scenarios I’ve seen is a facility where there was absolutely no access control. You pulled up to the parking lot of a public facility, literally walked through the door and were in the production area within 30 seconds. That’s got some obvious vulnerabilities.”

Les Glowka, vice president of quality assurance at Quantum Foods in Chicago, doesn’t disagree, but city ordinance doesn’t allow his company to install perimeter fencing, so the frozen meat product business mounted surveillance cameras on the sides of the building, near doorways, and on the roof. To control access, Quantum also installed fingerprint scanners and magnetic card readers throughout the facility. “Now, it’s pretty much like a locked-down building with an invisible 20-foot wall around the building,” Glowka says.

Sometimes companies believe they’re doing what they must to address a critical node but end up causing other safety problems. During her research for Safe Food, Nestle visited one meat packing plant that was trying very hard to make its safety procedures work, including upgrading its ovens so that operators could raise the temperature of a particular meat product to 165ºF—enough to kill “pretty much everything.” But the company then removed the meat and left it out in the open air for several hours to cool.

“I asked the man who was giving me a tour of the plant if he was worried about the product becoming re-contaminated, and his response was, ‘We’ve tested it, and we don’t have any problem,’” Nestle says. “Three weeks later, the company had a problems with Listeria.”

The founders of Homemade Baby, an organic/kosher baby food manufacturer in Culver City, Calif., didn’t leave anything to chance when they put their business together in 2005. “Knowing that no one had ever made and commercially sold fresh baby food before, we wanted to make sure we did everything right,” says Theresa Kiene, Homemade Baby’s chief executive officer. “We found Melissa Calicchia, one of the world’s most renowned microbiologists, who was interested in what we were trying to do and helped put some of our safety systems in place. Her name turned out to be like an American Express Gold card: Soon, my husband and I were able to surround ourselves with people who were a lot smarter than we were about the short- and long-term precautions and preparations we needed to make.”

AMI hosts periodic Strategic Partnership Program on Agroterrorism meetings at member facilities, which include group CARVER plus shock vulnerability assessment exercises and discussion, Seward says. Entities such as the Department of Homeland Security, the Federal Bureau of Investigation, the Food and Drug Administration, and state and local law enforcement can also interact with AMI about potential safety issues. “This gives people who are not in our industry a better idea of what goes on in our industry,” Seward says. “That way, these groups are better equipped to make judgments about what’s likely to happen.”

Testing, Testing …

Microbial testing is the backbone of any food safety effort—just ask officials at Earthbound Farm. Supplying packaged produce to 75% of all U.S. supermarkets, Earthbound launched its new four-level “test-and-hold” system in October 2006, a few weeks after an E. coli outbreak traced to its bagged spinach product killed three people and sickened more than 200 others.

The company had a product testing system in place prior to the outbreak, but it wasn’t effective enough, according to Mike Daniels, Earthbound Farm’s vice president of food safety and organic integrity. “When this happened to us, it wasn’t, ‘Gee, it’s a numbers game, and now we’re going to be okay for the next 22 years of processing.’ It was, ‘This is not good. We’ve produced an unhealthy product, and that’s not what we want to be associated with. Let’s figure out how to make this product safer.’”

Under guidance from food safety microbiologist Mansour Samadpour, PhD, the man who helped the beef industry develop an E. coli detection program after the Jack in the Box outbreak in 1993, Earthbound developed what is now considered the produce industry’s most aggressive testing and safety program:

  • At stage 1, “Seed to Harvest,” seed, irrigation water, soil amendments, and plant tissues are tested for pathogens; all field harvesters are trained in Good Agricultural Practices, and harvest equipment is regularly inspected and sanitized.
  • Stage 2, the “Raw Material Firewall,” features the raw material test-and-hold program. Because microbial contamination most commonly occurs at the farm level, samples of incoming salad greens are tested and held until results return negative for pathogens. This can take 8 to 12 hours.
  • Stage 3, the “Processing Facility” stage, features triple product washing (Earthbound added a third wash after the outbreak) and elimination of foreign objects using state-of-the-art laser optical sorting.
  • At the final stage, the “Finished Product Firewall,” produce is again tested and held for 8 to 12 hours until results return negative for pathogens. Only after clearing this stage is the product released for shipping.

Nestle is a fan of Earthbound’s new program. “It seems extraordinary,” she says. “A microbiologist will tell you it’s not going to stop everything. But it’s certainly going to deal with, on a statistical basis, the probability of something ever happening again.”

Industry reaction to the program has been positive, although there have been a few smaller growers who doubt they’ll ever have a produce safety problem, according to Daniels. “The chances of it happening to a small grower are still there; bacteria don’t differentiate between large and small growers,” Daniels says. “So we’re encouraging every grower and processor out there to conduct a hazard analysis and determine areas where they can best control problems in their own environment.”

Where Is It From?

Early this summer, the University of Georgia’s Doyle passed through Gilroy, Calif., the self-proclaimed “Garlic Capital of the World.” While there, he bought three packages of—surprise, surprise—garlic. At the top of each was a label that read, “Fresh Pacific garlic.” It wasn’t until he got home that he saw the label on the package’s other side: “Product of China.” The lesson here, Doyle says, is that you never really know where things come from or under what conditions they are produced. That’s what makes traceability a huge safety issue.

According to Barbara Rasco, PhD, co-author of Bioterrorism and Food Safety (CRC Press, 2005) and a professor at Washington State University’s Department of Food Science and Human Nutrition in Pullman, Wash., the best food safety and security programs can tell you the origins and status of your product at any given time, from seed to store.

“If someone claims they’ve contaminated your shipment, you can say, ‘There’s no way he could have gone to that point in our facility and done what he says he did, because we have system checks here that are so good we can prove the guy is lying,’” Rasco says. “But only guys who really have their act together with traceability and plant security are the ones who can make this claim.”

From the beginning, Homemade Baby has used a Meal Integrity System that makes traceability rather simple. According to Kiene, each cup of baby food includes a production code identifying the kettle batch the product came from, and a batch card tells plant operators exactly which ingredients were used. “The records on the specific ingredients give us our suppliers’ lot numbers for those ingredients, and the lot numbers identify the specific field and farm where those ingredients were grown,” Kiene says. “This system gives us field to fingers traceability.”

Earlier this year, the company tested the procedure by staging a mock product recall. “We had to identify a specific ingredient in a cup,” Kiene says, and they were able to do so in an eight-hour shift. “We knew exactly where the product came from.”

A key to Homemade Baby’s success is its insistence that vendors have complete records showing the production history of their products. “If you can’t provide that documentation, then don’t call us,” Kiene says.

What You See vs. What You Get

Every season, officials at Homemade Baby pay a visit to their Washington State-based apple and pear supplier. What they see on the trees is what they know they’re going to get, because the grower has set aside a plot of land specifically for Homemade Baby, Kiene says. “We’re not only getting wonderful quality products, but we also understand what’s been going on at that plot of land. We’ve seen it, we know where it is, and we know the farmers. And they have documentation about that piece of land from the time it was planted with a seedling to when it was harvested. We know about anything that’s happened to that fruit, that raw material, before it gets to us.”

If only it were that simple for everyone in the food processing industry. According to Doyle, America continues to import increasing numbers of overseas products: 15% of all food consumed in the United States annually comes from outside the country, a figure expected to double within the next 10 years. Meanwhile, FDA inspections are at an all-time low, totaling less than 1% of all incoming foods.

“You don’t really need to look at every single box of foodstuff that comes in, but you do need to be looking at enough of them so that the people who are sending in food believe that there’s a pretty good probability they’ll be caught if they do something wrong,” Nestle says. “Right now, if you’re trying to pass something through, the odds are 99 in 100 that you can get away with anything you want.”

Glowka says food safety needs to start with a company’s suppliers. “By the time it’s at your door, it’s way too late. You have to start analyzing and backpedaling to find out where it, and all its components, came from, whether it was properly handled and was healthy and safe… . You need to think a little bit ahead and over the horizon to see where the real food safety and security starts.”

Naditz is a freelance writer based on the West Coast; reach him at (916) 681-2057 or anaditz@yahoo.com.

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