Tightening The Food Chain

Biosecurity remains a hot-button issue, in light of new regulations and proactive measures.
This month marks the third anniversary of the attacks on the World Trade Center in New York City and the Pentagon in Washington, D.C., events which led to unprecedented scrutiny of the security of the nation. It wasn’t long after September 11, in fact, that the country’s food supply became a focus of anti-terrorism efforts and initiatives.
The potential for bioterrorism has loomed large on the agendas of both government officials who must prepare for such possibilities as well as food and beverage manufacturers who produce, export and import products that could be considered vulnerable to any kind of intentional tampering, from international or domestic culprits.
The scenarios may range from the improbable to the downright frightening, but one thing is certain: Processors are working diligently on measures to combat any potential attacks and to comply with government regulations, while still providing input on realities and practicalities.
“The government talks about terrorist attacks involving any type of industry out there, including the food industry. Although I think the odds are probably fairly low, you cannot be sure and the ramifications could be quite severe,” says Clay Detlefsen, vice president of regulatory affairs and counsel for the Washington, D.C.-based International Dairy Foods Association (IDFA). “If we’ve done one thing to stop something, then we’ve done a good thing.”
From a regulatory side, dairy industry organizations and manufacturers have been closely tracking the regulations stemming from the Bioterrorism Act of 2002, which was designed to enhance Food and Drug Adminis­tration’s (FDA) authority to protect the nation’s food supply against terrorist threats or similar food safety emergencies.
Just under a year ago, in October 2003, the FDA announced the release of interim final rules for the registration of food facilities and for the prior notice of imported food shipments. A third rule on administrative detention of suspect food products was released in June, while the fourth interim rule, pertaining to the establishment and maintenance of recordkeeping, is expected to be released by the end of 2004, after a series of delays.
For its part, IDFA has worked to provide industry insight, recommendations and, in some cases, objections on the proposed regulations. “They opened it up to comments before they even drafted anything. FDA was extremely diligent in trying to get industry’s perspective and all concerned parties have been involved in an enormous amount of discussions,” says Detlefsen, noting that IDFA has filed comments on at least six occasions in addition to regularly attending meetings.
The industry’s comments were effective in making some changes to proposed rules, says Detlefsen. “The major problem we saw early on was in their definition of food. At one point, it actually covered anything that touched food — a plate, a pipe, a truck. But FDA looked beyond it, figured it out and got it right.”
IDFA is also working with its members to update them about the bioterrorism regulations and their potential impact. The group held a dedicated workshop on the topic in late 2003 and has included biosecurity on the agenda of other workshops and conferences.
In addition, IDFA has organized a member committee on biosecurity, which has drawn at least 60 participants. “It is a pretty good indicator that there is a lot of interest in this,” says Detlefsen.
Other industry bodies have carefully monitored the regulations as well. “Here in Wisconsin, we formed a committee for the assurance of dairy product safety, and we included a section on biosecurity,” says Marianne Smukowski, safety quality applications coordinator for the Wisconsin Center for Dairy Research at the University of Wisconsin-Madison. “A lot of folks are still waiting to see the final rules on that (topic).”
Dairy Management Inc. (DMI), Rosemont, Ill., also has worked on biosecurity issues management, which may become an even greater focus of industry-funded efforts. “I think we’ll be looking at safety and biosecurity, to see if there is need for new research,” observes Bill Haines, DMI’s vice president of product innovation, adding that traceability will likely become an increasingly key issue tied to security.
In addition to keeping informed of current and pending regulations, dairy processors have taken proactive measures on the biosecurity front. Often, the responsibility for such firewalls falls on the same individuals responsible for food safety, although some manufacturers have hired or contracted with security experts.
Steps to combat potential bioterrorism vary. “We have focused most of our efforts on physical things such as sealing trucks, inbound and outbound,” says Carl Schroeder, vice president of manufacturing for Schroeder Dairy Co., Maplewood, Minn. “We have also installed security systems like badge readers, which limit access, and have trained employees to be alert and aware of who is in the facility.”
Stonyfield Farm, Londonderry, N.H., also has changed some of its operations and policies in light of a changing world. “Stonyfield Farm has implemented a dozen food security measure enhancements including improvement of physical barriers, new procedures, and management and employee training over the past year,” says Alton Bradshaw, director of corporate and regulatory compliance.  
Ben & Jerry’s, South Burlington, Vt., has taken a fresh look at security as well, and focuses on the company’s key gatekeepers, according to director of public relations Chrystie Heimert. “Employee awareness has to be the most significant change to the new environment,” she says. “Shipping and receiving personnel vigilance are critical to the process, and careful attention to our plant security systems is another line of defense.”
Some processors are working with third parties to identify gaps in their security situation. Homewood, Ill.-based Silliker Laboratories, for example, provides such evaluations as part of its overall food safety services. This year, the company added a separate scored section onto food security to one of its food safety audit tools.
“That was something we determined was needed, and our customers were asking for it as well,” says Rena Pierami, division vice president. “We are looking at various levels within security, from facilities to people to records. For the facilities, we ask things like, are the grounds protected? How did they determine if protection was needed? Internally, it’s the same thing: Is access restricted? Can a visitor get around the facility?
Although Silliker offers risk assessments, the company does not offer specific suggestions on measures, leaving such decisions up to its clients.
Pierami stresses thoughtful planning when it comes to matters of such importance. “It doesn’t matter who it is,” she says. “They have to have firewalls in place and have to think about what they are doing.”  df
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