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Food Safety & Defense

Food Defense

Why TACCP is Required
Installation Phases of the TACCP
Threats and Examples of Measures
Food Defense Drill Example

What Does Food Defence Mean?

We had the following definition about food safety: “to protect a food from all dangers that may be harmful to human health and to take necessary measures for it”. So when we say that a portion of food becomes harmful to human health, we are talking about not intentional situations.

On the other hand, food defence means taking measures to avoid and prevent food from being intentionally harmful. There may be many purposes of the person or groups who perform this intervention in these deliberate interventions. Examples include damaging trade economically, damaging brand reputation, causing panic and anxiety among the public, undermining trust in the power of public authority, and paralysing strategic goals. Different approaches are followed when managing food defense, and tools are used according to food safety, but they play a role as complementary to each other in the two systems.

Internal Threats
  • Subcontractors
  • Temporary Workers
  • Personnel with access to chemicals
  • Malicious people among employees

External Threats

  • Visitors
  • Competitor Companies
  • Activist Groups
  • External Service Providers
Knowing how to make food harmful deliberately will play a critical role in determining the measures to take. We can express these methods under four (4) basic categories by evaluating them as a threat.

Threat Categories

Microbiological

Pathogens
Viruses

Chemical

Cleaning Chemicals
Allergens
Maintenance Chemicals
Pest Control Materials

Physical

Metal
Glass

Radiological

Radioactive Substances
These deliberate attacks, which have been used many times throughout human history to achieve the desired outcome, can be given as an example from a recent event:
Case Study: In 2018, there were reports of sewing needles in strawberries taken by consumers in 6 different states of Australia. Subsequently, the Australian Minister of Health stated that the incident was “a malicious attack aimed at creating an atmosphere of public panic”.
While some brands were withdrawn from the market, New Zealand’s largest grocery stores had to stop selling Australian-origin strawberries as a precaution.
Threats and Examples of Measures

These attacks, which have been experienced until today, have actually brought the sensitivity of the food supply chain to the agenda more and new measures have been added by authorities such as official authorities and standard preparation institutions within the scope of food defense throughout the supply chain. Establishing a system for food defense, which is one of the issues that came to the agenda more and started to be addressed, especially after bioterrorist attacks, is indispensable for food to reach consumers safely.

Threat Assessment at Critical Control Points (TACCP), which is known as the food defense risk management system, is defined as the practices for evaluating threats with a knowledgeable and reliable team, identifying vulnerabilities, ingredient/material, product, purchasing, production, environment, distribution networks and control of business systems.

Objectives of the TACCP:

  • Reduce the likelihood of a deliberate attack
  • Mitigate the impact by considering the consequences of a successful attack
  • Protect the organisation’s reputation
  • Reassuring customers, the press and the public that appropriate steps have been taken to protect the products
  • Meeting international expectations and supporting the work of trading partners
  • Demonstrate that acceptable measures have been taken to protect the Products and that due diligence has been provided
1. Establishment of the Defence Team
2. Training of the Defence Team and Related Employees
3. Food Defence Plan and Threat Assessment
4. Performing Food Defense Risk Analysis
5. Preparation of Emergency Response Plan

1. Establishment of the Defence Team

A team should establish the Food Defense system and then ensure its continuity. This team should consist of different units such as Security (HR/Administrative Affairs), Production, Quality, Maintenance, Supply Chain, IT and persons with sufficient competence.

2. Training of the Defence Team and Related Employees

The established team should receive training from an appropriately competent institution (experienced in food defence standards and practices). After the system installation, this trained team should also provide training to all relevant factory employees.

3. Food Defence Plan and Threat Assessment

This plan aims to determine the threat points in a food processing facility or throughout the entire supply chain and to prepare a plan for the actions to be taken at these points. Food producing companies are responsible for taking measures against threat elements that require food defense. The first objective of the threat assessment is to identify potential threats and points that may be targeted for intentional contamination, similar to “hazard analysis”, one of the components of Hazard Analysis and Critical Control Point (HACCP). With the Food Defense plan, information such as the control methods performed/ to eliminate the threats or reduce their impact, who will perform these controls, how often they will be performed and where they will be recorded are determined.

4.Performing Food Defence Threat Rating (Risk Analysis)

An assessment should be made of the level of accessibility (probability) and vulnerability (severity) for each threat. While the level of vulnerability is defined as the degree to which the event can cause harm, accessibility is expressed as the level of ease/difficulty in carrying out a threat. The purpose of risk analysis is to identify the highest threats encountered in food defense and to bring down the level with the mitigation measures to be taken afterwards.

5. Preparation of Emergency Response or Contingency Plan

A well-constructed response plan helps to provide an effective response as soon as possible if business management, employees and emergency response personnel are suspected of intentional contamination. The response plan also provides a roadmap to prevent damage against deliberate contamination and restore safe production levels more quickly. According to this plan, the persons to be reached should be available 24/7. Contacts and telephone and address information of these persons should be kept up-to-date. The information of the persons to be contacted in case of emergency should be available in appropriate places in the respective facilities.
  • The factory site is fenced, gated and walled
  • Security Availability
  • Lighting
  • Visitor registration and visitor card, accompanying visitors policy
  • Camera system
  • Emergency alarm systems
  • Lock (card pass), seal or sensor applications on external doors
  • Door, window, roof, ventilation openings
  • Piping and pumping stations, tanks and silos of bulk products are locked, etc.
  • Pre-use control of materials
  • Camera system
  • Identification of areas with restricted in-factory access and prevention of unauthorized access
  • Visitor, subcontractor safety rules (not to be left unattended)
  • Employee and visitor hygiene rules, not bringing personal belongings into the production area
  • Traceability systems
  • Keeping chemicals locked, preventing unauthorized use
  • Waste Control
  • Limitation of access to water wells etc.
  • Quantity control of the use of limited ingredients
  • Separate storage of allergens
  • Limitations of entry, etc.
  • Checking the history of employees (Criminal record)
  • Ensuring that employees are provided with training and immediately notify suspicious and unusual situations
  • Entry into business as registered
  • Regular control of lockers, etc.

After the Food Defense system installation is completed, the following activities should be carried out to ensure the system’s sustainability without losing its effectiveness:

Implementation Phases of the Food Defence System

  • Minimum annual review of the Food Defence plan and threat assessment
  • Recording of routine checks and minimum annual review
  • Checking the system in Internal Audits,
  • Providing Refresher Training
  • Annual Drills
  • Discussing the issues of Food Defense in Quality and Food Safety meetings
  • Quality and Food Safety meetings

The Food Defense drill aims to see whether the current food defense system operates at the desired performance in the closest scenario and avoids the system deficits by eliminating the deficiencies. Different methods can be used in the industry for the drill. One of these methods, the “Penetration Test”, is one of the most effective and known methods. The “Penetration Test” briefly proceeds through a scenario where an unauthorized person attempts to access a sensitive area.

Drill Stages:

  1. The method is determined. In this example, we will consider the “Penetration Test”. The test is to uncover potential vulnerabilities.
  2. Since the test can be started at different points, a starting point should be selected. E.g. from outside the factory land, from the interior area or the shipment.
  3. It should be specified exactly what is planned, with the information of what, when, how, who and next step information.For example, A person who is not recognized by the factory employees but is known by the management will try to reach the dough preparation/mixer area starting from the outside of the factory land and passing through the main entrance and will wait in this area for a certain period of time (5-10 minutes). In advance, it should be determined how this person will identify himself/herself, how he/she will dress, and how he/she will respond if stopped by a staff member.
  4. During the drill, it should be ensured that designated personnel observes the process without revealing himself/herself.
  5. The success and failure criteria of the drill should be determined. What will happen if the food defence procedures are 100% operational, what will happen if the food defence procedures are partially operational; and finally, what will happen if the procedures and systems are in a complete failure state.
    • If the intruder is waiting for the target time in the targeted area and does not encounter any obstacles up to that point, this means that the food defense system has completely failed.
    • If the intruder is stopped and warned by an employee, but the person is able to reach the goal by convincing the employee in some way, this may mean that the food defense system has partially failed.
  6. A food defense exercise report should be prepared to describe the whole process/flow when the drill is completed. Some extra items that should be included in the report:
    • Management approval
    • Employees with knowledge of the exercise
    • Whether the employees in the targeted area have received food defense training
    • Procedures to be applied
    • Signatures of the authorities
  7. The report should also include those who have knowledge of the drill.
  8. The drill results should be analysed by meeting with the Food Defense Team.
  9. If there is a failure in the system, corrective actions should be determined by performing root cause analysis related to this failure and should be closed according to the appropriate deadline.
  10. Although the drill has been successful according to the relevant scenario, evaluation should be made for possible improvement suggestions.