F O O D P R OT E C T I O N CO N N E C T I O N

1 HOUR SAN

Food
Defense
Requires a Great Offense
by Melissa Vaccaro, MS, CHO

A s professionals in the foodservice industry,

we are hospitality driven. We invite everyone into our
establishment to enjoy our services and food. That
be fearful or suspicious of strangers that are visiting your
establishments, but to create a proactive plan, be educated
about food defense and know that should something go
invitation does not come without risk. As much as we badly, you and your employees are prepared to handle the
may hate to admit it, some people are just out to cause situation. By all means, don’t have an “it won’t happen to
harm and panic. Although the U.S. has relatively few me” attitude.
threats to our food supply at the retail level, they have
It can happen.
happened and cannot be ignored. The concept is not to

10 Nutrition & Foodservice Edge | November-December 2016

 10 people to become ill and the investigation of 586
individuals that had access to the refrigeration room.
• In 2003, a disgruntled supermarket employee added a
nicotine-based pesticide to 200 pounds of ground beef.
Their action triggered illness in a reported 92 people.
• In 1993, an angry former employee contaminated a tray
of doughnuts and muffins with Shigella dysenteriae
Type 2, which caused 12 employees to suffer severe
gastrointestinal illness and four employees were
hospitalized.
• In 1984, several cult members in Oregon added
salmonella to multiple restaurant salad bars in an
attempt to affect the outcome of local elections. This
incident resulted in 751 illnesses and hospitalization of
45 people.

Food defense is not the same as

food safety.
Food safety focuses on protecting food from
unintentional or accidental contamination.
Food defense focuses on protecting food from
deliberate contamination intended to cause harm.

Since 9-11, numerous federal agencies have focused on

food defense and have created forms, plans, educational
C R E AT E A videos, and documents to educate all of us, including
regulators, industry, academia, and the public. The focus of
FOOD this segment is to overview some strategic proactive food
DEFENSE PLAN defense concepts, and to provide resources to gain further
knowledge on the concept of food defense.
F O R YO U R
S TA N D A R D O P E R AT I N G P R O C E D U R E S
FA C I L I T Y FOR FOOD DEFENSE
Your Food Defense Plan should include Standard
Operating Procedures (SOPs). SOPs are specific written
procedures that establish acceptable practices and
EXAMPLES OF INTENTIONAL procedures for the facility and its employees. SOPs are
INCIDENTS only effective if they are understood and followed. SOPs
• In 2010, a disgruntled restaurant employee contaminated need to address four key concepts: Employees, Customers,
salsa with pesticide. This incident caused a reported 48 Vendors, and Facilities. These SOPs are based on
people to become ill. awareness, but you should certainly develop more detailed
• In 2007, an unhappy temporary employee contaminated SOPs to address specific items such as reporting, forms, or
Gyoza—better known as Japanese potstickers—three procedures.
times with a pesticide. This incident caused a reported Continued on page 12

Nutrition & Foodservice Edge | November-December 2016 11

 Continued from page 11

Managers have an enormous obligation when it comes to • Make sure labeled chemicals are in a designated storage area.
food defense. Managers must: • Make sure you and your coworkers are following
• Encourage communication among all employees. company guidelines. If you have any questions or feel
• Decrease susceptibility by having written strategies, company guidelines are not being followed, ask your
including recall procedures, training, and practice drills. manager for assistance.
• Decrease availability of potential contamination by • Take all threats seriously, even if it is a fellow coworker
having secured areas for storage of chemicals, proper blowing off steam about your manager and what he or
labeling, and access by employees. she wants to do to get back at your manager or your
company; or if he or she is angry and wants to harm the
• Identify possible inside threats by conducting
manager, the customers, or the business.
background checks, keeping track of employees, and
restricting personal items at the workplace. • If the back door is supposed to be locked and secure,
make sure it is!
• Identify possible outside threats by purchasing only from
approved vetted vendors, requiring vendors to have • Be alert to inconsistencies. If you use a food product
their own food defense plan, knowing when deliveries every day and it’s supposed to be blue but today it’s
are expected, inspecting delivery vehicles, securing green, stop using the product and notify your manager.
the perimeter of the facility via fences, cameras, locked • If you know an employee is no longer with your
doors, and sufficient lighting. company and this person enters an “employees only”
• Monitor customer and public areas. area, notify your manager immediately.
• Hold food employees accountable and continually • Cooperate in all investigations.
educate them on your Food Defense SOPs. • Do not talk to the media; refer all questions to your
corporate office.
E M P LOY E E S O P s
• If you are aware of a hoax, notify your manager
• Be a responsible employee. Communicate any potential immediately.
food defense issues to your manager.
• Be aware of your surroundings and pay close attention CUSTOM ER SOPs
to customers and employees who are acting suspiciously. • Be aware of any unattended bags or briefcases
• Limit the number of personal items you bring into your customers bring into your operation.
work establishment. • If a customer walks into an “employees only” area of
• Be aware of who is working at a given time and where your operation, ask the customer politely if he or she
(in what area) they are supposed to be working. needs help, then notify a manager.
• Periodically monitor the salad bar and food displays. Continued on page 14

FOUR STEPS FOR REPORTING A SUSPECT PRODUCT

1. If you suspect product tampering, report it poultry (such as seafood, produce, or eggs),
to the Person in Charge (PIC) immediately. notify the Food and Drug Administration.
2. The PIC should immediately report a For emergency questions, call the FDA’s
suspected tampering incident to your local 24-hour emergency number at 1-866-
police department. 300-4374 or 1-301-796-8240. For non-
emergency questions, call the FDA Food
3. If the food contains meat or poultry, call
Information Line at 1-888-SAFEFOOD.
the U.S. Department of Agriculture’s Meat
and Poultry Hotline at 1-800-535-4555.
4. If the food does not contain meat or

12 Nutrition & Foodservice Edge | November-December 2016

 Continued from page 12

VENDOR SOPs
• Check the identification of any vendor or service person • Document any equipment, maintenance, and security issues.
that enters a restricted area of your operation and do not • Be aware of the inside and outside of your facility,
leave him or her unattended. including the dumpster area, and report anything out of
• Monitor all products received and look for any signs of the ordinary. E
tampering.
• When a vendor is making a delivery, never accept more Melissa Vaccaro, MS, CHO is the Vice
items than what is listed on your invoice. If the vendor President of Consulting for PTI Consult-
attempts to give you more items, notify your manager. ing Group, a division of Paster Training,
Inc. Vaccaro is a 24 year alum of the PA
• When receiving deliveries: Department of Agriculture as a Food
Step 1. Always request identification. Program Specialist, and is an Executive
Board member for the Central Atlantic
Step 2. Stay with the delivery person. States Association of Food and Drug
Step 3. Do not allow the person to roam freely Officials (CASA). She is co-author of
throughout your operation. the SURE ™ Complete HACCP Food
Safety Series.
FAC I L I T Y S O P s
melissa.vaccaro@pastertraining.com
• Report all equipment, maintenance, and security issues
to your manager.

14 Nutrition & Foodservice Edge | November-December 2016

 Review Questions FOOD PROTEC TION CON N EC TION

Reading Food Defense Requires a Great Offense and successfully completing these questions
online has been approved for 1 hour of sanitation CE for CDM, CFPPs. CE credit is available 1 HOUR SAN

ONLINE ONLY. To earn 1 San CE hour, access the online CE quiz in the ANFP Marketplace. Visit
www.ANFPonline.org/market, select “Publication,” then select “CE article” at left, then search
the title “Food Defense Requires a Great Offense” and purchase the article.

1. Food Defense is: 4. If you suspect tampering you should immediately:

A. The unintentional or accidental contamination of food A. Tell the PIC
B. The deliberate, intentional contamination of the food B. Call the FBI
supply in order to cause harm C. Tell your regulator
C. The assurance of a two-year supply of food in case of 5. Managers need to:
an emergency A. Train employees one time in food defense
2. An example of an Employee SOP is: B. Encourage employees to mind their own business
A. Limit the number of personal items you bring into C. Encourage communication among all employees
your work establishment 6. SOPs are:
B. Monitor all products received and look for any signs of A. Specific written procedures that establish
tampering acceptable practice and procedures for the facility
C. Document any equipment, maintenance, and security and its employees
issues B. Specific procedures that establish acceptable
3. An example of a Facility SOP is: practices and procedures for the facility and its
A. Be aware of the inside and outside of your facility, employees
including the dumpster area, and report anything out C. Specific written procedures that establish practices
of the ordinary for the facility managers
B. Train employees regularly 7. Your food defense plan should include:
C. Ask for identification when a delivery is made A. Food Safety Standards
B. Standard Operating Procedures
C. Standard Operational Guidance

RESOURCES
1. Food Defense 101 delivers training in preparedness against an intentional attack against our food supply. The courses
provide an understanding of and guidance for developing a food defense plan(s) based on a common-sense approach. This
course includes training on ALERT (Assure, Look, Employees, Reports, Threats). http://www.fda.gov/Food/FoodDefense/
ToolsEducationalMaterials/ucm353774.htm
2. Employees FIRST is an initiative that food industry managers can include in their ongoing employee food defense training
programs. Employees FIRST educates front-line food industry workers from farm to table about the risk of intentional food
contamination and the actions they can take to identify and reduce these risks. http://www.fda.gov/Food/FoodDefense/
ToolsEducationalMaterials/ucm295997.htm
3. FDA Food Defense Plan Builder is a user-friendly software program designed to assist owners and operators of food facilities with
developing personalized food defense plans for their facilities. This tool harnesses existing FDA tools, guidance, and resources for
food defense into one single application. The Food Defense Plan Builder guides the user through the following sections: Company
Information; Broad Mitigation Strategies; Vulnerability Assessment; Focused Mitigation Strategies; Emergency Contacts; Action
Plan; and Supporting Documents. http://www.fda.gov/Food/FoodDefense/ToolsEducationalMaterials/ucm349888.htm
4. Food Related Emergency Exercise Bundle (FREE-B) is a compilation of scenarios based on both intentional and unintentional
food contamination events. It is designed to assist government regulatory and public health agencies in assessing existing food
emergency response plans, protocols, and procedures that may be in place, or that they are in the process of revising or even
developing. http://www.fda.gov/Food/FoodDefense/ToolsEducationalMaterials/ucm295902.htm
5. Food Defense and Recall Preparedness: A Scenario-Based Exercise Tool: This scenario-based exercise tool highlights the
importance of having a voluntary functional food defense plan and written recall procedures. http://www.fsis.usda.gov/wps/
portal/fsis/topics/food-defense-defense-and-emergency-response
6. Food Safety and Inspection Service (FSIS) Food Defense and Emergency Response website: http://www.fsis.usda.gov/
FoodDefense
7. Food and Drug Administration (FDA) Food Defense website: http://www.fda.gov/food/fooddefense/
8. Guidance for Industry: Retail Food Stores and Food Service Establishments: Food Security Preventive Measures Guidance
(2007) - http://www.fda.gov/Food/GuidanceRegulation/GuidanceDocumentsRegulatoryInformation/ucm082751.htm
9. “If You See Something, Say Something” Campaign: http://www.fda.gov/downloads/Food/FoodDefense/UCM245306.pdf
(English Version)
10. Active Shooter Preparedness: http://www.dhs.gov/active-shooter-preparedness

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