Thwarting Bioterrorism

June 2005

Thwarting Bioterrorism

By Steven LuffContributing Editor

It is no exaggeration to say that on the morning of Sept. 12, 2001 every sector of American society woke up determined to meet and exceed the new challenges posed to our nation. The food industry was no exception to this new reality. After Sept. 11, 2001, America was the largest food producer and exporter in the world, and it had no intention of letting that fine distinction slip.

The food industry's efforts at protecting our food supply have always been a priority. What changed after 9/11 was the nature of that protection. Before 9/11, food safety chiefly meant protection and prevention against unintentional hazards, such as foodborne pathogens. After 9/11, food safety, while still about preventing the unintentional, became one protection against intentional dangers -- that is, the deliberate adulteration of our food supply by forces hostile to our country.

In an immediate effort to address these new challenges, the food industry created, in Sept. 2001, the Alliance for Food Security. The Alliance is a coalition of some 130 food-industry interests, including manufacturers, transporters and distributors, gathered together to act as a clearinghouse for food-safety information. While this information was intended for the betterment of the food industry, it was also intended for the federal government. The Alliance wanted to know what protection measures were already in place for the food industry and how to encourage those that weren't; the federal government, in its duty to protect the country, wanted to know from a legislative perspective how it could help.

Three things came out of this process of communication and cooperation: a better understanding of how the food industry's safety measures work from an internal perspective; the federal mandates tucked within the Public Health Security and Bioterrorism Preparedness and Response Act of 2002, also known as Bioterrorism Act of 2002, which specifically address food manufacturers; and the beginning of an ongoing discussion about the nature of these new threats existing within the fabric of a free society. This resulted in the dawn of a new era of food safety and security.

Improved internal protections When the U.S. food industry took stock of its safety measures after 9/11, it found that much was already in place to thwart potential terrorist attacks. After all, the food industry has never considered it good business to welcome any form of adulteration, whether intentional, unintentional, domestic or foreign.

"Industry has always done a lot related to food security, and sometimes not even in the name of food security," says Tim Willard, vice president of communications, National Food Processors Association, Washington, D.C. "For example, at retail you have very strong security activities that are not focused on 'food security.' They are things like loss prevention, theft protection. You leave cartons of food out on a shipping dock unattended and they have a tendency to disappear."

The recognition of preexisting security measures was an important part of the Alliance's initial anti-bioterrorism analysis. It helped illustrate what should now be seen as essential measures for any company engaged in the food business. These measures are known as the "Three Ps" -- personnel, products and property.

"Companies absolutely have increased both employee screening and supervision to ensure that there are not issues related to personnel," says Willard. "Companies have established more controls on ingredients and products throughout the food chain. For our members, actual food companies, that means controls on ingredients products during receiving, during productions and at distribution so that you ensure the highest level of food safety. There also has been an expanded focus on property. Companies have reviewed and ensured that they have strong barriers in place to guard against possible attacks against them."

Federal government's role The "Three Ps" takes a voluntary, self-governing approach to national security. Using elements from these main heads, Congress has legislated the Bioterrorism Act of 2002. The last of these new rules was finalized in Dec. 2004. Four of the rules represent the essence of food security, detailing the government's right to detain food shipments, require the registration of food-manufacturing plants, enforce traceability standards and demand prior notification of intent to import foods.

One rule empowers customs agents, per Section 303 of the Bioterrorism Act, to detain -- in warehouses or docks, for instance -- any suspect food shipments without a court order. This ensures that potential violators cannot move food items during the time it takes authorities to process paperwork.

Another, in Section 305, outlines the need for all food facilities, whether involved in the manufacturing, processing, packing or storing of food items, to register with FDA. "We were estimating that there would be about 420,000 facilities that would register, and we haven't had that many register yet," says Sebastian Cianci, trade press liaison for FDA's Center for Food Safety and Applied Nutrition. "As of March 24, 2005, approximately 241,000 facilities have registered. Of those, 134,000 were foreign facilities and 107,000 domestic. So either we overestimated or there are many companies that haven't gotten the word."

Section 306 addresses mandatory measures food companies must take that will aid U.S. officials in managing an attack after it occurs. All food manufacturers and ingredient suppliers must maintain records of the source of their food items and where they went within the distribution chain. This helps authorities in pinpointing exactly where adulterated material might have entered the food supply.

The final major rule, Section 307, requires that anyone who is importing food into the United States must inform the U.S. government before importation occurs, including specific details about the food. Cinani says that if the U.S. government has intelligence that suggests that someone is trying to contaminate a certain type of product, or a product from a certain country or region, this rule will allow it to make targeted inspection efforts.

Ongoing debate While no one wishes to disregard the value of prevention, all sides recognize that with the amount of free-market activities that exist in this country, only so much prevention can be done. Some level of risk of a terrorist attack must be accepted.

"What we have tried to do is to reduce the risk of threat and attack to as low as possible," says Willard. "It would be wonderful to say that risk were eliminated, but you cannot eliminate risk -- 100% security doesn't exist. So what we're talking about is risk management, not elimination."

This risk management includes the assessment of where our security dollars are going and what the highest rate of return is for that investment.

Mark Wheelis, senior lecturer in microbiology   at the University of California, Davis, suggests that while we might spend a couple of billion dollars to lower the risk, the next billion we spend will only have a moderate effect, and the subsequent $50 billion will just get us a few percent more protection.

An example of this debate can be seen with Congress' approval to fund the increase of FDA inspectors inspecting imported food. While this was a noble effort, it only increased our inspection of all imported foods from 1% to 2%.

"On the one hand, by going from inspecting 1% of imported foods to inspecting 2% of imported foods we have increased our inspection by 100%," says Wheelis. "On the other hand, there's still 98% of the food that's not being inspected. So even though it's a dramatic improvement with reference to the former level, it's virtually trivial in terms of making any actual increment of improved security."

Cianci sees this from a different perspective. "We get information on everything that comes in," he says. "Physically inspecting and pulling things open may only be between 1% and 2% of imported foods, but it's very targeted. We believe that we're hitting the areas from which we have seen the most trouble or where we think there is the most concern."

Trouble spots Part of the hyper-attention given to the threat of bioterrorism has resulted from the Sept. 11th attacks. But now, almost a full four years later, that day has receded some in our memory allowing us to make more-rational decisions about bioterrorism.

The area that has given experts and regulatory officials the most cause for concern, even in this more-sober environment, is on the farm. In March 2005, the Government Accountability Office published a report entitled, "Homeland Security: Much Is Being Done to Protect Agriculture from a Terrorist Attack, but Important Challenges Remain," addressing the fears of agroterrorism.

"The United States still faces complex challenges that limit the nation's ability to respond effectively to an attack against livestock," the report reads. "For example, USDA would not be able to deploy animal vaccines within 24 hours of an outbreak as called for in a presidential directive, in part because the only vaccines currently stored in the United States are for strains of foot-and-mouth disease, and these vaccines need to be sent to the United Kingdom to be activated for use. There are also management problems that inhibit the effectiveness of agencies' efforts to protect against agroterrorism."

Despite these dire words, this danger requires some perspective, says Wheelis. It is highly unlikely that the use of foot and mouth, mad cow or classical swine fever to attack American agriculture would cause any significant amount of ill health in humans, he says. But it could potentially cause many billions, tens of billions, of dollars in economic damage.

"The animal agricultural sector is probably considerably more at risk because animal disease makes a much-bigger splash," says Wheelis. "Karnal bunt has invaded this country a couple times, but you never see a headline in The New York Times or The Washington Post about it. One of those two papers might have a small article buried deep inside the paper once, but if you have a foot-and-mouth outbreak in this country comparable to the one in the U.K., there would be front-page articles virtually every day for months. The visibility is much higher. The economic damage is probably higher if you chose the right agent. And, of course, the political consequence will be much higher."

Outlook and resources "I think there will be a continued assessment of how we're doing," says Willard of the food industry's response to terrorism. "I think very much the food industry wants to be in the lead and proactive. They're not just waiting to respond. The food companies themselves very much want to say, 'OK, what are the next things we can do?' There's been guidance on food security in addition to the Bioterrorism Act regulations. There's been guidance on food security by both FDA and USDA. And I think that food companies have used that and they look for, and will continue to look for, next steps that they can do."

Steven Luff is a Los Angeles-based writer specializing in health, the environment, government regulation and social concerns. He has worked for a number of years as a bread baker and appreciates the complexities of the food industry from company management to end product.

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