As President Barack Obama signed the Food Safety Modernization Act (FSMA) into law Jan. 4, 2011, it represented the first major overhaul of federal food laws since 1938, when Congress empowered the Food and Drug Administration (FDA) to oversee the safety of most foods, along with drugs and cosmetics. With FSMA’s advent, security — already a vital component in protecting America’s food chain — will likely play an even larger role.
The food industry needs to prepare for this brave new world, suggests Mark Powers, the regional security and emergency manager for MillerCoors. Powers is also a member of the U.S. Department of Homeland Security’s Food and Agriculture Sector Coordinating Council, so he has a foot planted in both the private and government sectors. “With the January signing of the FSMA, almost overnight the FDA was transformed,” Powers explained at a recent ADT Media Summit in Chicago. “(The FDA) couldn’t recall tainted products. If (they) wanted to subpoena your records, they had to go to the Department of Justice and convince some U.S. attorney. Now, the FDA can do it by themselves.”
The FDA’s enhanced powers under FSMA will mean more frequent inspections at FDA-registered food processing sites, the right to inspect foreign plants that process food products imported to the United States, more stringent documentation requirements for food companies and stronger product-recall authority.
That last category should especially catch the attention of food industry decision-makers, Powers said. He estimates that the average product recall cost to a corporation will exceed a million dollars. The negative publicity accompanying a recall can do serious damage to a brand and set up the company for large losses in claims against it.
The Atlanta-based Centers for Disease Control and Prevention reports that 48 million Americans — about one in six — get sick from food-borne diseases each year. Nearly 128,000 are hospitalized, and roughly 3,000 die. The new law gives the FDA new enforcement powers to protect public health against food contamination that is, for the most part, considered preventable.
A Vast Challenge
Since the Sept. 11 attacks, government officials and business security specialists have also had to consider another potential contamination source: terrorists who clandestinely insert themselves into the food chain with intent to do harm. However, according to Don Hsieh, ADT Security Services director of food defense, it is far more likely that someone legitimately on the premises will contaminate the food supply, intentionally or unintentionally.
At the ADT Media Summit, Hsieh pointed out that there are two million farms in the United States — 150,000 domestic processing facilities registered with the FDA and another 270,000 in foreign countries. Most food products are moved by trucks, about nine million of which are used for transport in the industry. Trains move truckloads of food products on rail cars, and ocean vessels bring in imported food from all over the world. Restaurants, grocery stores and institutional food-service companies represent more than a million points of sale. Clearly, the supply chain’s vastness presents a formidable challenge for those trying to protect it.
In industry terminology, “food defense” refers to protecting against the intentional adulteration of food. “Food safety” encompasses the unintentional adulteration of food, usually via microbiological pathogens that might be seeping into it. The term “food protection” covers both of those. “Food security,” which sometimes comes up in industry discussions, refers to providing enough food for the world’s population.
Three Trends Driving Food Defense
Hsieh sees three key trends that are driving food defense. The first is the beefed-up regulatory oversight represented by FSMA, which was itself spawned by the increasing threat of food contamination from within and outside the supply chain, plus the growth of the global supply chain.
Next are the technology drivers. Products such as location sensors, equipment sensors, temperature sensors and vibration sensors can protect the supply chain in the physical plant and all the way through the logistics, down to the point of sale. ADT, for example, offers software with physical security information management capabilities that allow an integrated approach.
“That really enables us to take all that input — whether it’s a video or asset control throughout the enterprise — and then provide real-time intelligent monitoring for that supply chain,” Hsieh said. “There’s situational awareness across the enterprise of what’s going on so they can protect their food-supply chain.”
The third trend driver Hsieh sees is the consumer, who has high expectations of being able to have safe food whenever he/she wants it. Today’s omnipresent media output heightens the risk for food manufacturers that might have a problem.
In today’s 24/7 media environment, Hsieh observed, “there is a sensitivity now that if anything happens, it has got to be reported, and because of social networking, the consumer has just as much impact on the company brand as the CEO of that company. So there is a heightened sensitivity of the corporations to really be proactive and prevent adulteration as much as they can because they know the impact on their brand can be severe, and it can come from anywhere.”
To protect their brand from threats along the supply chain, companies must have the capability to gather actionable intelligence, Hsieh said. A successful defense plan will comprise what ADT refers to as the Four A’s:
1. Assess risk at critical control points;
2. Access, which only allows authorized staff to visit critical control points;
3. Alert of intentional and unintentional instances of food adulteration delivered by continuous monitoring of critical control points; and
4. Audit, which provides invaluable documentation for compliance with FSMA requirements.
“You need to be able to ensure that you have a complete chain of custody from the time the product left your facility to the time it is sold at the store,” Hsieh said. “There are some significant issues there for these companies. The consequences, of course, are certainly loss of product that could be contaminated and not really knowing whether the product is actually even stolen until it didn’t get delivered, which may be well after that code chain has been broken. But if you can know at the time it happens, you can act quicker and address those issues.”
Bob Giles is a regular contributor to Security Technology Executive.