What would you do if you were the QA manager in a large commercial bakery and found a handwritten note under dough in a refrigerated unit that said, “By the time you find this note some of the dough will be contaminated with deadly poison.”
Who would you call first? Would you call the police or state health inspector? Would you tell your employees? Would you tell your customers?
Noted security expert Rod Wheeler of the Global Food Defense Institute, says there are no easy answers to those questions. This scenario played out at a commercial bakery in the Midwest that employed more than 450 people and that was capable of storing more than 91,000 lbs. of dough at any given time.
Wheeler says plant management would first likely try and determine how long the note had been there because if it had been placed there two or three shifts ago contaminated product could have been shipped out the facility.
“If you call the police their knowledge on food safety is low and if you call the state public health inspector their protocol is likely to shut everything down for an indefinite period of time,” says Wheeler. “If you tell your employees or customers a reporter from the local television station or newspaper is likely to be in lobby asking questions.”
A mandate in the Food Safety Modernization Act calls for protection of food from intentional adulteration that could cause large-scale public harm. Food defense differs from food safety, which is to prevent unwanted micro issues and anything else from the process that could harm consumers, from getting into the products.
Under the rule facilities are required to review their production systems, complete their own vulnerability assessment and complete a written food defense plan. The plan would need to identify actionable procedures in a food process that will require focused mitigation strategies to reduce the risk of intentional adulteration.
“Everything in food defense and food security has changed since 9/11,” says Wheeler. “The industry has shifted focus since then because the threat is very real. However, convincing people of the severity of the threat is hard.”
Wheeler also points to an incident at Kansas City food plant that showed the vulnerability of working with outside contractors. Plant employees came across a man with a contractor badge in a restricted ingredients silo. They also noticed the door to the silo area was propped open with fire extinguishers.
The person should not have been in the restricted are and when asked what he was doing the man said, “I never been in food plant and I wanted to learn how products were made.”
After asking him to leave the area, plant management immediately went to the main contractor and a background check was made on the person. The check, with the assistance of the FBI, revealed the job application for the individual was actually made in the name of a person who died three years ago.
“This was the fourth complaint in several years about a person in a food plant with a similar story and in each instance the guy took off before FBI arrived,” says Wheeler. “This is the new reality. If you see something, say something.”
Wheeler says a facility’s pest management partner is often one of the best weapons in food defense since they know the facility and its people well, and are trained observers of not only pests but anything that could be out of the ordinary.