Food Defense for the Small Retail Operation

THE SANITARIAN’S FILE

By Robert W. Powitz, Ph.D., MPH

food contamination in 1984, where members of a religious cult in Oregon Food Defense for the contaminated salad bars with Salmonella typhimurium in order to disrupt a local election and causing 751 cases of salmo- Small Retail Operation nellosis resulting in 45 hospitalizations, I started my career working with institu- tions, mostly prisons and psychiatric facilities. Awareness of possible acts of sabotage was already part of the institutional culture. Before we could begin working at these facilities, newly hired professional and support personnel, including myself, had to learn about defense and incorporate it into our For those of you who work in the food craft. It was expected that any activity conducted within a secure environment manufacturing business, you have my was done with defense-minded con- straints. It did not take long for this new permission to skip this article. Most of concept to become second nature. I F applied what I had learned to my report you already have food defense quite in recommendations and added a defense component to other institutional envi- hand, or you are well on the way to hav- ronmental health-related programs for which I was responsible. To this day, I ing a fully functional defense plan. So for continue to do so. In short, food defense should become seamlessly inte- this column, I’m directing my comments to the retail side of our grated into every foodservice operation. Early on, the sanitarian’s guideline industry, particularly the small retail foodservice providers, including for food service defense came largely from the Public Health Service’s 1967 bakeries, bars, bed-and-breakfast operations, cafeterias, camps, child and 1976 Food Service Sanitation Manuals (the precursors to today’s Food and adult daycare providers, church kitchens, commissaries, commu- Code). It dawned on my professional colleagues that the prevention of cross- nity fundraisers, convenience stores, fairs, food banks, grocery stores, contamination and enforcement of personal hygiene practices were already meal services for home-bound persons, mobile food carts, restau- part of the correctional and medical staffs’ post orders and the kitchens’ rants, and vending machine operators. defense compliance mandate. Except for some idiomatic and occupation-spe- Although there are numerous well-written food defense guidelines, for all cific language, food safety and food intents and purposes, they target the larger operation. Even those from the U.S. defense were, and continue to be, syn- Food and Durg Administration Center for Food Safety and Applied Nutrition’s onymous. (FDA CFSAN) “Retail Food Stores and Food Service Establishments” guidelines In the April/May 2005 issue of are not entirely sensitive to the vast majority of mom-and-pop or smaller institu- Food Safety Magazine, I wrote about tional operations. They even make mention of this in the opening paragraphs. “Street HACCP,” which is an abbreviat- Taken in its entirety, the requirements outlined for a comprehensive, secure retail ed HACCP program ideal for small food establishment is somewhat daunting, confusing and sometimes quite illusive foodservice operations. I will try to if applied to a smaller operation of limited financial and facility resources. So for present the basic concepts of food those of you who fit into this category, please bear with me while I try to demysti- defense in much the same way: brief, fy and (I hope!) simplify this topic. concise and functional—and it is hoped, By way of introduction, long before the first real monstrous act of deliberate cost-effective.

R EPRINTED FROM F OOD S AFETY M AGAZINE, DECEMBER 2006/JANUARY 2007, WITH PERMISSION OF THE PUBLISHERS. © 2007 BY T HE TARGET G ROUP • www.foodsafetymagazine.com Assessing Risk for Defense “Incorporate food defense awareness into the First, here is the bad news. Unlike accidental foodborne illness, a breach in food defense or an act of terrorism in a food safety training program.” small food service operation can result in at least two types of economic effects: Direct economic losses attributable to The actual definition of risk assess- or other malicious, criminal, or terrorist the costs of responding to the act; and, ment is: “A report that shows assets, vul- action at each segment. To be successful, indirect multiplier effects from compen- nerabilities, likelihood of damage, esti- implementing enhanced preventive sation paid to affected customers and mates of the costs of recovery, sum- measures requires the commitment of the losses suffered by affiliated indus- maries of possible defensive measures both management and staff. tries, such as suppliers, transporters and and their costs and estimated probable Accordingly, it is prudent that both distributors. savings from better protection.” The management and staff participate in the However, here’s a bit of good news. FDA model allows us approach risk development and review the food Believe it or not, in the world of small assessment—within the confines of this defense measures within their facility. foodservice operations, most policies for definition—in much of the same way we So, now you have the logic to develop a food safety (even if they are unwritten) would complete a menu review and a food defense program using the food and the practices of rudimentary defense formal facilities plan review, but with a safety tools already in place. I have systems are already in place. All facilities defense twist. Keep in mind that some taken the liberty of highlighting, what I that are routinely inspected by the regu- of the biological and chemical agents of consider the most important FDA rec- latory community meet the most critical concern are more inclusive than the ommendations. There are five compo- defense components such as preventing usual cast of foodborne misadventure nents to each foodservice operation: cross contamination, maintaining prop- characters, and that opportunities are a Management, staff, public, facilities and er temperatures and using time/tempera- bit a bit more global than food prepara- operations, each of which can be easily ture relationships to prevent foodborne tion considerations. In short, our risk integrated into existing policy. illnesses, and, ensuring that foods come assessment goal is to prevent deliberate from approved sources. With a little contamination. But while we cannot Management attention to detail and a few enhance- prevent all terrorism scenarios, we cer- • Prepare for the possibility of tamper- ments, every small operation can signifi- tainly can minimize them. ing or other malicious, criminal, or cantly reduce its risk of intentional The Conference on Food terrorist events and assign responsi- food-related misadventures such as tam- Protection’s Plan Review Blue Book bility for defense to knowledgeable pering or other malicious, criminal or poses several questions for new and staff. terrorist actions. newly remodeled food service facilities. • Have a crisis management strategy to While it’s fairly easy to identify bro- These questions are basic to any opera- prepare for and respond to tampering ken seals, bag closures and the like, it’s tion: Will the menu offer food that and other malicious, criminal, or far more difficult to judge past tempera- requires extensive preparation? What are terrorist actions, both threats and ture abuse or the opportunity for delib- the hours of operation and service? actual events, including identifying, erate contamination with foods that do How often will food and supplies be segregating and securing affected not have defense packaging. Therefore, delivered? What is the maximum num- products. let us explore simple ways to enhance ber of employees working on one shift? • Plan for emergency evacuation, the food defense practices already in And, has everyone been trained in food including preventing defense plan place. safety, defense and HACCP principles? breaches during evacuation. To begin putting a rational spin on From the answers we can not only eval- • Familiarize yourself with the emer- food defense for the smaller operator, uate the adequacy of the kitchen equip- gency response system in the com- the FDA provided a good resource. ment, the flow of food through the munity and provide 24-hour contact Several years ago, the FDA developed a facility, the sizes and type of cold-hold- information to the local authorities. generally accepted framework for risk ing equipment and dry goods storage, • Post all emergency phone numbers assessments that was endorsed by the the adequacy of personal hygiene facili- in a conspicuous area. Codex Alimentarius Commission and ties, and the potential for human error, • Train yourself and staff about rele- the U.S. National Academy of Sciences, we can also look for potential breeches vant defense issues and have a strate- among others. The framework divides in defense; both from a facility and per- gy for communicating with the pub- risk assessment into four components: sonnel perspective. lic in the event of an emergency. (1) hazard identification; (2) hazard Like a HACCP program, we can characterization (or dose-response assess- focus our attention sequentially on each Staff ment); (3) exposure assessment; and segment of the food delivery and pro- • Provide an appropriate level of super- (4) risk characterization—all basic to a duction system that is within our con- vision to all staff, including cleaning HACCP program. trol and minimize the risk of tampering and maintenance staff, contract

R EPRINTED FROM F OOD S AFETY M AGAZINE, DECEMBER 2006/JANUARY 2007, WITH PERMISSION OF THE PUBLISHERS. © 2007 BY T HE TARGET G ROUP • www.foodsafetymagazine.com workers, and especially, new staff. • Monitor public areas, including the that they are appropriately secured. • Conduct routine defense checks of serving or display of foods in self- • Establish delivery schedules and not the premises, including utilities and service areas and entrances to public accept unexplained, unscheduled critical computer data systems. restrooms for unusual or suspicious deliveries or drivers, and investigating • Investigate suspicious activity and activity. delayed or missed shipments. threats or information about signs of • Supervise all off-loading of incoming tampering or other malicious, crimi- Facility: Physical Defense materials. nal, or terrorist actions and alert • If possible, protect non-public • Reconcile the product and amount appropriate law enforcement and perimeter access with fencing or received with the product and public health authorities. other deterrent. amount ordered and the product and • Examine the background of all staff, • Secure all doors, including emer- amount listed on the invoice and including seasonal, temporary, con- gency exits when not in use and not shipping documents, and investigate tract and volunteer personnel, and being monitored, secure windows, shipping documents with suspicious consider their access to sensitive areas roof openings/hatches, vent open- alterations. of the facility and the degree to ings, ventilation systems, utility and • Inspect incoming products and prod- which they will be supervised. storage rooms, loft areas and trailer uct returns for signs of tampering, • Provide some recognizable form of bodies, and bulk storage tanks for liq- contamination or damage or counter- identification for each employee. uids, solids and compressed gases. feiting and reject suspect food. • Change combinations, rekeying locks • Use metal or metal-clad exterior • Alert appropriate law enforcement and/or collecting the retired key card doors to the extent possible and min- and public health authorities about when staff who are in possession of imize the number of entrances to evidence of tampering, counterfeit- these are no longer associated with non-public areas. ing, or other malicious, criminal, or the establishment. • Establish a key tracking and defense terrorist action. • Restrict the type of personal items system. allowed in non-public areas of the • If possible, monitor the defense of Operations: Storage establishment and prevent staff from both the interior non-public areas • Have a system for receiving, storing bringing personal items such as lunch and the perimeter of the premises, and handling distressed, damaged, containers and purses into nonpublic including the parking area, and pro- and returned products, and products food preparation or storage areas. vide enhanced lighting to these areas. left at checkout counters, that mini- • Regularly inspect staff personal stor- • Minimize to the extent practical, mizes their potential for being com- age areas. places in non-public areas that can promised. • Incorporate food defense awareness be used to temporarily hide inten- • Keep track of incoming products, training into the food safety training tional contaminants. materials in use, salvage products, program for employees; provide for • Keep customer, employee and visitor and returned products. periodic retraining and encourage parking areas separated from • Investigate missing or extra stock or staff support in food defense plan- entrances to non-public areas, where other irregularities and reporting ning and the food defense awareness practical. unresolved problems to appropriate program. law enforcement and public health • Watch for unusual or suspicious Facility: Storage of Poisonous authorities. behavior by staff, including person- and Toxic Chemicals • Minimizing the reuse of containers, nel who, without an identifiable pur- • Limit poisonous and toxic chemicals shipping packages, cartons, etc. pose, stay unusually late after the end in the establishment to those that are of their shift or arrive unusually required for the operation and main- Operations: Foodservice and early; access files/information/areas tenance of the facility and limit their Retail Display of the facility outside of the areas of access. • Periodically check products displayed their responsibility; remove docu- • Keep an inventory and track poison- for retail sale for evidence of tamper- ments from the facility; or ask ques- ous and toxic chemicals kept on the ing or other malicious, criminal or tions on sensitive subjects or bring premises, and, investigate missing terrorist action, such as checking for cameras to work. stock or other irregularities and alert off-condition appearance, proper local enforcement and public health stock rotation, evidence of resealing, Public agencies about unresolved problems. condition of tamper-evident packag- • Restrict entry to the non-public areas ing, and the presence of empty food of the establishment and prevent Operations: Incoming Products packaging or other debris. access to food preparation, storage • Use only known and appropriately • Regularly monitor self-service areas and dishwashing areas in the non- licensed/permitted (where applicable) for evidence of tampering or other public areas of the establishment, sources for all incoming products. malicious, criminal or terrorist including loading docks. • Inspect delivery vehicles to ensure action.

R EPRINTED FROM F OOD S AFETY M AGAZINE, DECEMBER 2006/JANUARY 2007, WITH PERMISSION OF THE PUBLISHERS. © 2007 BY T HE TARGET G ROUP • www.foodsafetymagazine.com Operations: Defense of Water Validate Your Program and Utilities Finally, it is a good idea to review Forensic sanitarian Robert W. Powitz, • Request a periodic review all mandat- and verify, at least annually, the effec- Ph.D., MPH, RS, CFSP, is principal con- ed utility protection components tiveness of the defense management pro- sultant and technical from the local building and health gram and revise the program according- director of Old Saybrook, departments. ly. It is also prudent to keep this infor- CT-based R.W. Powitz & Associates, a professional • Limit access to controls for airflow, mation confidential. Just a reminder: No corporation of forensic water, electricity and refrigeration. defense program can completely protect sanitarians who specialize • Secure non-municipal water wells, against terrorism. Likewise, no defense in environmental and pub- hydrants, storage and handling facili- program is complete without validation. lic health litigation support services to law ties. In order to ensure that your newly creat- firms, insurance companies, governmental • Ensure that all water systems and ed or newly modified food defense pro- agencies and industry. For more than 12 components are equipped with back- gram contains all the elements necessary years, he was the Director of Environmental flow prevention. to minimize risk, I strongly recommend Health and Safety for Wayne State • Regularly testing non-municipal that it is reviewed by a correctional pro- University in Detroit, MI, where he contin- water sources for potability, as well as fessional such as a sheriff’s deputy or ues to hold the academic rank of adjunct being alert to changes in the profile correctional officer who work at a local professor in the College of Engineering. of the results. jail or prison. Their job is defense, and Among his honors, Powitz was the recipi- • Identify alternate sources of potable they can provide ideas, constructive crit- ent of the NSF/NEHA Walter F. Snyder water for use during emergency situa- icism and suggestions for enhancement, Award for achievement in attaining environ- tions where normal water systems effectiveness and efficiency of your pro- mental quality, and the AAS Davis Calvin have been compromised (for exam- gram. I’ve regularly worked with these Wagner Award for excellence as a sanitari- ple, bottled water, trucking from an professionals for several decades and I an and advancing public health practice. approved source, treating on-site or never met one who was unwilling to Contact Bob at [email protected] or via maintaining on-site storage). share their knowledge. n his website at www.sanitarian.com.