By Michael
Cramer, Vice President Food Safety and Quality Assurance, Specialty Brands,
Inc.
Like many other Americans, on September 11,
2001, I sat in stunned horror watching television news reports of the
deliberate and cowardly attacks on New York and Washington and in the skies
over Pennsylvania. I was travelling at
the time and was fearful of when and how I would get home or if the flight home
would be safe. That’s one of the
objectives of terrorism, to strike fear and diminish confidence. Terrorists seek to do harm, to kill and
maim, but they also seek to disrupt our businesses, our economy and our
security. They are like the foodborne
pathogens we fight so diligently, ubiquitous, hiding in dark recesses and
striking, sometimes without warning, causing harm to those with whom they come
in contact.
It’s now been exactly four weeks since the terrorist
attack on America and I am again traveling, less fearful and more confident due
to added security at the airports. I
find, however, that I remain at a heightened level of awareness of the
potential for further action against our country by those who wish us harmed.
Though terror might not come again from the skies, it may well come from a
source closet to all of us, through contamination of our food supply and our
products. It is with this in mind that I write about the need for food
companies to be at a high level of awarenessand take actions to minimize the
risk of being a terrorist victim. Ask
yourself if you are the potential target of a terrorist attack and then put
plans together to assess your vulnerability and take the appropriate actions to
prevent product tampering or other interference with your business operations.
Maintain accurate and updated employee rosters,
including rosters specific to each shift.
Know who is and who should be in the plant. Where possible, have photo ID cards for associates and restrict
access to the plant to employees and regulatory personnel with official
identification. Limit cooked
ready-to-eat area access to essential personnel and prohibit all personal
items, including lunch containers, cases, purses, etc. from processing areas.
Have a clear visitor policy that requires sign
in and sign out at a security desk or reception. Limit access to the plant to all visitors unless accompanied by a
company employee. Require visiting
regulatory personnel to present ID and sign in and out of the plant. Inspect all incoming vehicles. Keep plant doors closed at night and on the
weekends, even if the only ongoing activity is sanitation or maintenance.
Maintain an
up to date inventory of all hazardous lab chemicals and solvents and keep
hazardous materials securely locked.
Microbiological labs should keep positive control of pathogen cultures
under lock as well. Assure that mercury
thermometers are accounted for on a daily basis. Restrict lab access to lab personnel and essential management and
keep the lab locked when not occupied.
Do not allow lab materials, with the exception of sample collection
materials, to be brought out to the manufacturing floor.
It is also recommended that plants conduct an assessment of all potentially hazardous chemicals such as maintenance solvents and paints, sanitation chemicals and wastewater treatment compounds. These too should be kept in a secured storage area with limited access.
Know your
suppliers; be certain to have a general and continuing letter of guaranty on
file and have a program for inspection of incoming ingredients. Have a specific policy to identify new suppliers
to assure a safe supply. Develop
accountability for all restricted ingredients (nitrites) and food allergens
(dairy, wheat, soy, peanuts, tree nuts, eggs, fish and crustacea). Keep sensitive ingredients locked and have
specific personnel identified and trained to handle them properly. Have the ability to trace specific
ingredient lots to finished product lots. These precautions apply to direct
product contact packaging as well as to ingredients. Does your facility have a well for processing and clean-up
water? Evaluate the security of the
well systems. Consider testing for
water potability more frequently, depending on the water source, e.g. weekly
rather than monthly, or monthly rather than annually
Personnel
who move freely through the plant, typically QA and production associates,
should be alert to and aware of any abnormal findings in the plant. Look for signs of sabotage to equipment,
missing, broken or unprotected glass or indication of tampering with
ingredients and packaging. Make sure
that protective equipment (e.g. screens, sifters, magnets or metal detectors)
is in place and functioning properly.
Report any unusual activity to a manager, supervisor or appropriate
authorities. Account for all keys to
the facility or restricted areas held by supervisory employees.
It is not enough to simply have a recall policy and
procedure; food companies must also have a Crisis Management Policy and
Procedure. In the event of a threat or
real product tampering there must be a plan to address both the immediate
issues as well as near term and long term issues. Terrorist actions can result in potential harm to plant
employees, lost productivity, loss of customer confidence or lost
business. There are very good consultant
companies that can help you prepare an effective plan, however listed below are
some examples of steps that you can take to help you pull through a crisis
period .
· Have emergency telephone numbers
(e.g. fire, police, ambulance, hospital, FBI and regulatory agencies) available
to key management and plant personnel
· Have an emergency evacuation plan to
get personnel out of the plant quickly and safely. (This is an OSHA
requirement.)
· Provide a plant plan to the local
fire department or have one in a locked, sealed container outside the plant in
the event the plant cannot be accessed
· Prepare a strategy for continued
production using an alternate company plant or co-packer to avoid prolonged
disruption of product flow to customers
· Have an effective recall policy and
plan. Test the effectiveness at least
annually.
· Develop a relationship with a
qualified forensic lab to help with microbiological and chemical analysis or
physical evaluation of unknown materials.
· Have prepared statements for the
press and for customers identifying the action that you have taken depending on
the situation. Develop a relationship
with local print media, radio or television personnel so that they know about
the company and the measures that you take to produce safe, quality products.
· Designate a spokesperson to deal with
media calls, but be sure that they are well trained in handling the media.
· Prepare information about the
company, especially detailing positive information about food safety, quality,
customer recognition and community relations.
As a nation we will recover from the tragedy of September 11, our ideals of freedom and democracy will withstand evil terrorism. Our political and military leaders will develop their plans to battle terrorism on an international front to prevent further catastrophe. The American people have shown tremendous resilience in the face of adversity and a willingness to restore our damaged cities, our wounded economy and our fragile confidence. As food processors, we must do our part to assure that confidence in our products is never an issue. We must be prepared to prevent terrorists from striking our businesses; we must protect our common assets, valued customers and consumers.