Transcript Document

Combined Effect:
Enhancing Food Defense
Strategies through
Integration of Food
Safety Practices at the
State and Local Level
Food Defense at the Retail
Regulatory State and Local
Level
Gary W. Elliott, MA, REHS
April 30, 2014
Overview
FIRST
Primary Retail Regulatory Focus - Food Safety or Defense
SECOND
FSMA and Proposed Rules
THIRD
AFDO, State and Local Perspectives
FOURTH
Exploring the integration of food
safety practices with food defense
principles
1
PRIMARY FOCUS
FOOD SAFETY
OR
FOOD DEFENSE
Primary Focus
Food Safety = Preventing Foodborne Illness Related Risks
Regulations or Rules Based On
Prevention of Risk from:
• Unintentional
and
• Intentional
Contamination
Sub-Primary Focus
Food Defense = Prevention Focus on
Intentional Contamination Threats
• Terrorism
• (International and Domestic Groups)
• Disgruntled Employee,
Customers, Competitors
• Economic Sabotage
• Criminals
DEFINING
FOOD
SAFETY
ENSE
Food defense has been defined as “a
collective term to encompass activities
associated with protecting the nation's
food supply from deliberate or
intentional acts of contamination or
tampering. This term encompasses other
similar verbiage (i.e., bioterrorism,
counter-terrorism, etc.) (FDA, 2008).”
Food Defense Concerns Are Real
Threats Are Real
Documents Found in Afghanistan Caves during Operation Anaconda in 2002
(From: Williams, 2005).
A History Of Threats
A Global Chronology of Incidents of Chemical, Biological,
Radioactive and Nuclear Attacks: 1950-2005
Hamid Mohtadi and Antu Murshid*
July 7 2006
http://www.ncfpd.umn.edu/Ncfpd/assets/File/pdf/GlobalChron.pdf
http://cns.miis.edu/cbw/foodchron.htm
The impact of a major agricultural/food-related
disaster in the U.S. would be enormous and could
easily extend beyond the immediate agricultural
community to affect other segments of society. It is
possible to envision at least three major effects that
might result—mass economic destabilization, loss
of political support and confidence in government,
and social instability. (Chalk, 2001)
“An enemy bent on victory at
any cost could and will make
the food supply of a populace
a main target”
(ShoahEducation.com, 2003).
Psychological Fears
• Probability of intentional contamination of the food supply
is thought by some to be low
• Fact remains that the food/agricultural infrastructure and
food supply remain targets of interest for terrorist
organizations
• Survey by Stinson, Kinsey, Degeneffe, and Ghosh, (2007)
published in the Homeland Security Journal
• High percentage among U.S. respondents polled (4,260
persons) were concerned about the possibility of deliberate
contamination of the food supply
Psychological Fears
Psychological Fears
• Preliminary survey results about perceptions that Americans
have toward homeland security conducted by Stanford
University and NPS/CHDS professor Jim Breckenridge
(Breckenridge, personal communication, 2008)
• 400 polled individuals
• 23.2 percent of the respondents polled saw contaminated
food problems as a matter of great concern.
• The concern about protection of the food supply ranked
third on a list of homeland security concerns related to
fears of attack by terrorists.
2
FSMA
and the
FDA
PROPOSED RULES
Food Safety Modernization Act
Focus On Specific Sections
Section 205(c)2 of the Food Safety Modernization Act
(FSMA) requires a review of state and local capacities in
order to enhance the development primarily of strategies
required under 205(c)1, but also sections 108, 110, 209 and
210.
Sec. 108. National agriculture and food defense strategy.
Sec. 110. Building domestic capacity.
Food Safety Modernization Act
Focus On Specific Sections
Sec. 209. Improving the training of State, local, territorial, and
tribal food safety officials.
Sec. 210. Enhancing food safety.
Food Safety Modernization Act
Focus On Specific Rules
Proposed Rule: Focused Mitigation Strategies to Protect Food
Against Intentional Adulteration
Docket Number: FDA-2013-N-1425
December 2013
Food Defense Plan
•
Each facility covered by this rule would be required to
prepare and implement a written food defense plan,
which would include:
Focus On Specific Section Of Rule
• Actionable process steps
• Focused mitigation strategies
• Monitoring
Focus On Specific Section Of Rule
• Corrective actions
• Verification
• Training
• Recordkeeping
AFDO
3
AND
LOCAL
REGULATORY
Perspectives
• How does the new rule on intentional adulteration apply
to the retail regulator and retail industry
• Importance of integrating food defense within the
broader IFSS concept
• State food regulatory programs are important partners
for FDA and industry
• Importance of an effective implementation strategy with
clear roles and responsibilities for agencies, industry,
academic institutions, and other entities
Perspectives
•
Lots of loose ends aren’t addressed in the rule – FDA
needs to work closely with stakeholders to fill in these
gaps in practical ways
• Importance of education and outreach – for the
larger firms falling directly under the rule and for
others that may be indirectly impacted by market
forces
• Alliances have been successfully used to meet the
educational, training, and technical assistance needs
in the past
Perspectives
• Importance of education and outreach –
for the retail food industry that may
indirectly impacted by market forces
• How can the FDA work with state and
local agencies on a variety of FSMA
issues including food defense from a
realistic grass roots retail perspective
Perspectives
The Retail industry, unlike the manufactured
food industry, while supportive of the
concept of food defense generated after
September 11, may still have:
• Difficulty embracing a separation between food
safety and food defense especially with multiple
agencies
• Industry stakeholders may believe that without
information suggesting an increased level of
intentional threat that current safety precautions
are sufficient to protect the food products that they
produce
4
EXPLORE
OF FOOD SAFETY
AND FOOD DEFENSE
Explore Innovative Strategies
With reduced resources and limited budgets,
which receives a higher focus?
• Food Safety or Food Defense?? Priorities!!
Is there a proactive way to still have both at
the same time?
•
Create Value Propositions and Value
Innovations
•
Between Food Defense Principles and Food
Safety Smart Practices at the Retail Level
Integrate Innovative Strategies
•
Look for common threads between food safety
and food defense
•
Use common sense value innovations and avoid
complication
•
Be Proactive about Active Managerial Control
linked to Situational Awareness
•
Educational and training inspections from a
Food Defense and not a Food Safety viewpoint
Innovation Sense-Making Tools
Final Added Overall Thoughts
Needs and Beliefs:
• A focused and combined regulatory approach to food
safety/defense efforts can be established for the sector,
retail and manufactured
• Continue to establish a more focused mechanism for
research of food and agricultural pathogens, including
emerging pathogens
• Better education at all levels of the farm-to-table
continuum on food safety/defense involving all
stakeholders
Final Added Overall Thoughts
Needs and Beliefs:
• The fusion of intelligence information pertinent to the
food and agricultural sector, would provide a clearer
perspective of existing and emergent problems and
provide a path to strengthen outcome solutions.
• Explore a workable solution or policy for information
sharing between the regulatory system, DHS, the
intelligence community, and ultimately, the state and
local regulatory systems to analyze probabilities of
attack and prevent terrorist threats against the sector.
Chris Bellavita (2005) wrote in Homeland Security:
The Issue-Attention Cycle, “In the absence of an
active national consensus that terrorists are a clear
and present threat to the lives of average Americans,
the dynamics of the Issue-Attention Cycle are as
inevitable as the seasons.”
Anthony Downs argued that certain issues
follow a predictable five stage process: preproblem, alarmed discovery, awareness of the
cost of making significant progress, gradual
decline of intense public interest, and the post
problem stage.
In The Cycle of Preparedness: Establishing a Framework to
Prepare forTerrorist Threats, (2005), Willam Pelfrey used the
word “cycle… as a proxy for a dynamic, flexible, and
continuous process of interaction and integration, and
functioning as a self-organizing mechanism that improves
preparedness for anticipated events and for the unimagined
events.”
He goes on to say that a “…‘cycle’ implies a repetitiveness, in
sum as well as in parts, that is consistent with
‘preparedness.’
Preparedness cannot be proclaimed or finished; it is an
ongoing process with constituent parts or phases working in,
or being available to work in concert.”
Pelfrey also acknowledges the great importance of
“prevention” in preparedness, along with awareness,
response and recovery as part of the four phases of the cycle.
Questions/Comments/Thoughts/Ideas
NAVAL
POSTGRADUATE
SCHOOL
MONTEREY, CALIFORNIA
WHO’S ON FIRST: UNRAVELING THE COMPLEXITY
OF THE UNITED STATES’ FOOD AND AGRICULTURAL
REGULATORY SYSTEM IN THE REALM OF
HOMELAND SECURITY
http://handle.dtic.mil/100.2/ADA514142
Gary W. Elliott, MA, REHS
AFDO Food Protection and Food Defense Committee
Co-Chairman
[email protected]
(803)804-0564
South Carolina
Department of Health and
Environmental Control (DHEC)
[email protected]
(803) 896-0733