Jamie Stamey, MS, RD, LDN, CFSP

(PDF Attachment: Food Security Checklist available at the bottom of this page)

Introduction

In a post-Sept 11 United States, “safety” has become a major focus of nearly every sector from government to industry to consumers (1,2,3,4). While most foodservice operators have started to address basic food safety plans to prevent unintentional contamination, such as time-temperature abuse or cross-contamination, many facilities may not be adequately prepared to deal with the renewed threat of deliberate contamination (1,2) or the malicious tampering of food products.

Food offers the perfect vehicle for large-scale terrorist attacks (5,6). In fact, small-scale cases of food bioterrorism have already occurred in the United States. In 1984, a religious cult in the Pacific Northwest sprayed cultured Salmonella bacteria on a salad bar, resulting in over 750 reported cases of illness (7). Malicious tampering has also occurred in other products, including arsenic-laced Chilean grapes and in non-food products like pain reliever capsules (1,5).

Centers for Disease Control and Prevention

The Centers for Disease Control and Prevention (CDC) have categorized many foodborne pathogens as potential weapons in a bioterrorism attack (5,8). Names of such “bio-weapons” may sound surprisingly familiar. Salmonella E. coli Botulinum Shigella. These organisms can cause foodborne illness in their natural state when food is not prepared properly or contaminated by improper handling. However, they can also be introduced deliberately into a food or water supply to cause harm (1,5,8). Chemicals can also be used for deliberate contamination. Pesticides and cleaning agents are just a few of the chemical agents readily available at most food-related facilities (2,3).

Resources for Healthcare Foodservice Operators

Healthcare foodservice operators need a positive, proactive, risk-based management approach to assess and prevent food exposure from both unintentional and malicious contamination. On Dec. 17, 2003 the Food and Drug Administration and US Department of Health and Human Services released Guidance for Industry Retail Food Stores and Food Service Establishments: Food Security Preventive Measures Guidance (2) and on March 21, 2003, Guidance for Industry: Food Producers, Processors, and Transporters: Food Security Preventive Measures Guide(3). Both documents provide important direction in evaluation and implementation of such preventive measures (2,3).

Every foodservice operation needs a food safety plan that includes standard operating procedures and incorporates Hazard Analysis Critical Control Points (HACCP) principles for hazard analysis, prevention, monitoring and verifying security in the following areas:

1. vendor assurance and recall strategy

2. facility security and restricted access

3. employee screening, supervision and training

4. foodservice operations throughout the flow of food (1,2,3) (See Figure 1.)

Vendor Assurance and Recall Strategy

As part of your foodservice-distributor relationship, establish a predetermined system to include your facility in a rapid communication and recall notification plan should food contamination occur. Identify primary and back-up contacts within your organization who can be reached 24 hours a day, seven days a week. Request that the distributor include a plan that provides for food security throughout transportation. Delivery trucks and loading docks should be secured and monitored during delivery. Foods should never be left unattended.

Facility Security and Restricted Access

Secure the building by securing doors, windows, ventilation systems, utility rooms and roof openings. All hazardous materials should be secured and routinely inventoried.

Restrict entry of unauthorized staff, vendors and visitors from food and chemical storage, food preparation and food holding areas. Employ strict policies on checking visitors in and out, distributing and collecting of visitor badges and the requiring proof of identity.

Employee Screening, Supervision and Training

Background screening should be used for all personnel: full time, part time, contract, seasonal, temporary and volunteer staff require equal scrutiny. Employees should be required to wear identification. This identification should be collected upon termination or resignation. Daily work assignments should be available to supervisors to determine who should be on the premises. Staff should be allowed access only to areas essential to perform their required tasks. Unscheduled employees, staff relatives and friends should be excluded from the workplace. Personal items including clothing, lunch containers, bags, backpacks, packages and medications should be kept away from food storage and production areas. Employees play a very important role in helping to prevent breaches that would allow for deliberate attacks. Incorporate food security awareness into initial and on-going training programs for ALL employees and volunteers.

Train staff on how to prevent, identify, report and respond to actual or suspicious actions or threats. Involve staff in food security planning and provide periodic reminders of its importance.

Train employees, supervisors and managers to watch for unusual or suspicious behavior in internal and external staff, visitors and clients.

Foodservice Operations Throughout the Flow of Food (See Figure 2.)

Food vulnerability can be assessed and preventive measure implemented by grouping foods into three main categories:

Pre-packaged foods that will be sold in their original package in a cafeteria or convenience store location should be:

• stored in a secure location to prevent tampering
• inspected prior to display or service for signs of adulteration
• and monitored during display to prevent manipulation

Foods prepared or packaged on site should be prepared using a HACCP-based plan, including:

• secure storage of ingredients and packaging materials to prevent contamination
• pre-operation cleaning and sanitizing of food contact surfaces
• batch-processing in small qualities with end-batch cleaning and sanitizing

and labeling of product batch and lot for identification in the event of recall and secured and monitored during storage, display and service to prevent post-production contamination

Secure self-service and bulk displayed items during storage during storage to prevent contamination. Monitor in a proactive fashion to prevent tampering or other malicious actions to this most vulnerable product during display.

Take the necessary steps to implement a well-planned and tightly controlled security plan at your facility. This plan should take into account a heightened awareness of product vulnerability at all stages (1,2,3,4). Once under your control, food should be protected in a secured facility with well-screened and trained staff that can provide effective, vigilant monitoring. By establishing and prioritizing food safety and security guidelines for food reception, storage, preparation, holding and service, you can prevent deliberate food supply contamination within your operation. A proactive plan is a safeguard.

Jamie Stamey is Senior Food Safety Consultant at The Steritech Group, Inc, Charlotte, N.C. Contact Jamie at jamie.stamey@steritech.com

References

1. World Health Organization. Food Safety Issues: Terrorist Threats to Food. Guidance for Establishing and Strengthening Prevention and Response Systems. Available at www.who.int/fsf. Accessed July 7, 2002.

1. U.S. Food and Drug Administration. Guidance for Industry, Retail Food Stores and Food Service Establishments: Food Security Preventive Measures Guidance. Available at http://www.cfsan.fda.gov/. Accessed Dec. 17, 2003.

1. U.S. Food and Drug Administration. Guide for Industry Food Producers, Processors, Transporters and Retailers: Food Security Preventive Measures Guidance. Available at http://www.cfsan.fda.gov/. Accessed March 21, 2003.

1. Cody, MC. Bioterrorism: What does it mean for dietetics professionals and the American public? ADA Member News Alert. http://www.eatright.org/ Accessed December 5, 2001.

1. Sobel, J. Threat of biological terrorist attack on the U.S. food supply: The CDC perspective, Lancet, 2002 59: 874-80.

1. Henderson, D. Bioterrorism as a Public Health Threat, Emerging Infectious Diseases, CDC July-Sept 1998.

1. Torok TJ, Tauxe RV, Wise RP, Livengood JR, Sokolow R, Mauvais S, Birkness KA, Skeels MR, Horan JM, Foster L R. A large community outbreak of salmonellosis caused by intentional contamination of restaurant salad bars. J Am Med Assoc..1997;278:389-395.

1. The Centers for Disease Control and Prevention, Emergency Preparedness and Response. http://www.bt.cdc.gov/. Accessed March 21, 2003