Don Kraemer, senior advisor, FDA Center for Food Safety and Applied Nutrition, told DairyReporter.com intentional contamination of bulk liquids and food could cause wide-spread public harm.
Regulation needs to find a balance between the ‘unlikely’ event of intentional adulteration, the cost of preventative measures, and the potential ‘catastrophic’ results of an attack, he said.
“We’re not aware of a circumstance of widespread attack on the food supply, and yet we’ve done a lot of modelling and vulnerability assessments and have a good idea of what it would look like,” said Kraemer. “It could be devastating.”
A public meeting was held at Sheraton Park Hotel, Anaheim, California on March 13 to get feedback on the FDA’s proposed rule on food defense.
This would tell large food businesses to address vulnerable points in their processes, and is the first time preventative measures are being put into regulations.
Dairy processors are vulnerable because they deal with fresh food – which is distributed and consumed quickly. Bulk liquids could be another target, Kraemer said.
“There are certain aspects of products that contribute to risk. Shelf life is important,” he said.
“If someone was to contaminate food, it’s a race between that food getting out and the public eating it, and us, as public health officials, detecting the problem and reacting to it.”
Fluid products are better at distributing contaminants, and large batch sizes distribute large quantities of food at once.
“There was some concern raised [after 9/11] and so this industry recognized their somewhat unique vulnerability and did take some steps,” Kraemer said.
“The most worrisome threat is the sophisticated insider, someone who gains access through normal means – posing as pest control or an employee. So we’ve figured out the common characteristics of sites where an attack could occur.
“For example, the storage of liquids in a bulk storage milk tank: what can you do to provide added security to that location, even if the insider had access?”
Producers will have to create strategies to reduce the risk of intentional adulteration. It would affect producers who manufacture, process, pack or hold food.
Kraemer suggests measures could include video surveillance, locks and limited access, or buddy systems where two people have to be present.
The average annualized cost of the rule per firm would be around $37k, with initial costs of $70k. The expected benefit of preventing a terrorist attack on the US food supply is around $130bn, the FDA said.
In 2003, the FDA issued its first guidance of what manufacturers could do to avoid risk, which has been built on since. It is voluntary and the FDA is gathering reactions to the idea of the mandatory rule.
This meeting in California was the third of three public events with producers and stakeholders. Events were held in Chicago and Maryland in February. The closing date for comments is March 31.
The FDA is responsible for protecting public health in food and has a role in the nation’s counterterrorism capability by ensuring the security of the food supply.