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From: Food Quality & Safety magazine, October/November 2006

Think Like A Terrorist

Avert Bioterrorism by Assessing where you are Vulnerable, what a Terrorist could do to exploit it and what Countermeasures can be Effective

by Ryan Cliché

The FDA cites incidents in other countries to highlight the importance of its watchdog role in food security. In 2002, a restaurant owner in China added chemicals to a competitor’s food, killing dozens of people and sending hundreds to the hospital. In another incident in 2002, three people were arrested in Jerusalem for allegedly planning a mass poisoning of patrons at a cafe. In January 2003, several people were arrested in London for plotting to add deadly ricin to the food supply on a British military base.

How many incidences on foreign soil will it take to make U.S. food producers recognize the deadly threat of bioterrorism? Will it take an incident on U.S. soil before all U.S. food producers are registered with the FDA and take the necessary steps to protect the food supply?

The U.S. government is attempting to integrate its departments and work with industry to anticipate, preempt and deter threats to the homeland. They are doing this by thinking like a terrorist – anticipating what a terrorist organization might do and then using the insight they gain to stop terrorist before they strike.

Vulnerability Assessment

Homeland Security Presidential Directive 9 (HSPD-9), Defense of United States Agriculture and Food, requires the Food Safety and Inspection Service (FSIS) to prepare U.S. foods for an intentional attack on meat, poultry and egg products.

“Shortly after 9/11, both FDA and the Environmental Protection Agency (EPA) did an assessment to determine the most vulnerable products and agents,” says Dr. Carol A. Maczka, assistant administrator of the Office of Food Defense and Emergency Response, FSIS. “Then the White House asked the FSIS to use the same methodology: CARVER + Shock.”

The CARVER + Shock Method is an offensive targeting tool that the U.S. Department of Defense developed to figure out what are the high-risk targets. But FSIS adapted this for food.

“For example, let’s say you’re worried about meat production or liquid egg products,” Maczka explains. “You take your production system, and you break it down into subsystems, complexes, components and nodes – the smallest piece of your physical infrastructure.” In a processing plant, a silo could be a node. Then, you apply the acronym CARVER to the node, and you assess each node:

  • The “C” in CARVER stands for “critical.” This part of the assessment addresses the following questions: With respect to this node, how critical is this node? Would it knock out the entire system if this node was attacked? How many people would the attack kill? How many would it injure? What would be the economical impact?
  • “A” stands for “accessibility.” Determine how accessible the target node is to a terrorist. Can the terrorist get in, do his damage, and get out?
  • “R” stands for “recuperate.” If a terrorist attacks this node, can the system recuperate? What would be the effect on production? “For example, if a terrorist knocked out your ground beef production system, you should determine how long you think it would take for your production system to recuperate,” says Maczka.
  • “V” stands for “vulnerability.” How vulnerable is the node to attack? Is it easy to get to the node? A cover, cap or seal could help protect the node. Could a terrorist easily drop an agent into the node? If a terrorist has to back up a truck full of an agent to a node to get to the node, there is a much better chance that the terrorist will be discovered.
  • “E” stands for “effect.” What would be the overall effect on the system?
  • “R” stands for “recognizable.” How recognizable is the particular node? For example, if you were a terrorist, you may not be able to recognize a node if the node does not stand out as a target.

The “Shock” is the political and psychological effect of an attack on the node. Is a subset of the population going to be affected (i.e. children)? Maczka says, terrorists may attack a McDonald’s restaurant, which is recognized as a U.S. symbol, and children could be in danger. Just as symbolic nature also needs to be considered in vulnerability assessments.

Countermeasures

After you rank your particular node and all of the nodes in your system, you should come to a consensus on your score. (Government agencies are available to help you with this.) Then you should decide from the scores which nodes in the system are most important, and you can begin working on countermeasures to put in place.

Countermeasures can range from merely a government agency providing guidance to industry to enhanced testing or working with industry to apply a seal to protect a node from a dangerous agent.

“It’s the responsibility of FSIS to perform vulnerability assessments and develop countermeasures as dictated by HSPD-9,” Maczka cites.

What does it cost industry to allow the FSIS to perform these vulnerability assessments and develop countermeasures? Nothing, besides the time it takes to navigate through the assessment and become educated. FSIS is required to perform vulnerability assessments for at-risk food producers twice per year, but the agency encourages industry to use the tools it learns from the FSIS to perform vulnerability assessments more often. Read the Strategic Partnership Program on Agroterrorism (SPPA) First Year Status Report (www.usda.gov/homelandsecurity/8-1006%201%20yr%20report%20SPPA%20agroter5.pdf) to see how your vulnerability assessments and countermeasures stack up against others in the industry.

Shipping and Customs

So now you’ve examined your internal production systems down to every last node. Don’t forget to ensure the security of your product after it leaves your facilities.

Customs Trade Partnership Against Terrorism (C-TPAT) is a voluntary government-business initiative that has been put in place to build cooperative relationships that strengthen and improve overall international supply chain and U.S. border security. C-TPAT recognizes that U.S. Customs and Border Protection (CBP) can provide the highest level of cargo security only through close cooperation with the ultimate owners of the international supply chain such as importers, carriers, consolidators, licensed customs brokers and manufacturers. Through this initiative, CBP is asking businesses to ensure the integrity of their security practices and communicate and verify the security guidelines of their business partners within the supply chain.

Private firms, like Chicago-based Riggle & Craven International Trade & Customs Law, help industry certify their imports under C-TPAT, which helps food shipments, get through customs with fewer requirements. “If or as soon as we have a terrorist attack on these shipments, those in industry who are not members of C-TPAT may see impediments to their shipments,” says David A. Riggle, managing partner

In performing a C-TPAT certification, all of the different possibilities where a shipment could have a problem are analyzed. Terrorists may find an opening to attack your shipment after your food shipment is loaded and sealed.

“You often think of security for your manufacturing plant and for once your shipment reaches the U.S., if you are shipping from outside the U.S., but during the transportation is when there is also potential for attack,” according to Riggle. Many foreign ports are already online with the C-TPAT guidelines.

Riggle says that unsealed, fresh food is most vulnerable at this stage, since it is most easily contaminated. To make sure that your fresh food is not contaminated, you should choose a foreign exporter with a tight chain of security through all of their transportation networks.

“Price is always a concern for companies, but sometimes you don’t want to go with the cheapest partnership option. You want a foreign exporter with the best security procedures,” he continues. “It’s a fact of our modern world that food producers need security for their shipments.”

Get Registered

The U.S. government requires all food producers in the U.S. and food producers that aim to distribute in the U.S. to register with the FDA (see /www.cfsan.fda.gov/~furls/ovffreg. html). If you are not sure your company is registered, check immediately. This is the best way for you to take the first step toward protecting your production system and products and allow the government to help you protect them. You also need to have a 24-hour telephone number to register with the FDA, so that the agency can get in touch with you regarding products you’ve put into the food supply. If you ship goods either to or from the U.S., register with C-TPAT. www.cbp.gov/xp/cgov/import/commercial_enforcement/ctpat/.

Government and industry need to work together and think like a terrorist to take appropriate measures. “As you are aware, this is a new age,” says Maczka. “Industry is very good at protecting the food supply against food safety concerns, but we’re in a whole new dimension now where we really have to think like a terrorist to figure out where the vulnerabilities are and what countermeasures we need to put in place.”

Ryan Cliche is a contributing editor based in Washington, D.C.

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