A Contamination Risk of Imported Food?

Ever since the discovery of contaminated wheat gluten from China that led to the deaths and illness of thousands of pets, the question has arisen whether the same kind of thing could happen with imported human food.

Some reporting today from the Associated Press suggests it could:

Just 1.3 percent of imported fish, vegetables, fruit and other foods are inspected — yet those government inspections regularly reveal food unfit for human consumption.

Add to that the contaminated Chinese wheat gluten that poisoned cats and dogs nationwide and led to a massive pet food recall, and you've got a real international pickle. Does the United States have the wherewithal to ensure the food it imports is safe?

Food safety experts say no.

With only a minuscule percentage of shipments inspected, they say the nation is vulnerable to harm from abroad, where rules and regulations governing food production are often more lax than they are at home.

"FDA doesn't have enough resources or control over this situation presently," said Mike Doyle, director of the University of Georgia's Center for Food Safety, which works with industry to improve safety.

Last month alone, FDA detained nearly 850 shipments of grains, fish, vegetables, nuts, spice, oils and other imported foods for issues ranging from filth to unsafe food coloring to contamination with pesticides to salmonella.

Each year, the average American eats about 260 pounds of imported foods, including processed, ready-to-eat products and single ingredients. Imports account for about 13 percent of the annual diet.

How did the melamine wind up in the wheat gluten [in the pet food]? Investigators still don't know.

The FDA and the USDA have adopted a "risk-based" inspection philosophy, focusing on specific foods, sources or producers that they believe represent the largest potential risk to the public's health.

"We have better control than we did a few years ago but it is largely the responsibility of the importer to make sure those products are safe," said Stephen Sundlof, the FDA's top veterinarian.

For local homeland security professionals, this is mostly a question of mitigation. It's the job of USDA and FDA to prevent the importation of contaminated food, and if they don't stop it at the border, local communities would have to deal with local effects. Recalling that the DHS Inspector General recently reported that public panic is a likely result of a major food contamination incident, it's worth giving some thought to this:

Commentators on the subject have observed that an adverse food sector event could also reduce state and local governments’ ability to maintain order and deliver essential services. A major food contamination event could engender public panic on a local or mass scale, depending on the affected food product and population, and media coverage of the incident.

(Also see this post for my summary of the report.)

Questions for local homeland security professionals include:

• What level of collaboration is there among local public health agencies, healthcare providers, and other local authorities (e.g., elected officials, law enforcement)?
• What healthcare resources are available?
• What communication plans are in place?
• How can local authorities maintain the public's confidence?
• Does everyone know their role in the event of a public health emergency?
  

A lot of these questions are relevant to other public health concerns such as pandemic flu or other biological threats. By taking a collaborative approach and addressing a range of potential hazards, local homeland security professionals can make the best use of the resources available to them.

Updated 04-23-2007: A guest column in the Washington Post by former food executive Peter Kovacs echoes some of the concerns about imported food, especially from China:

One pound of tainted wheat gluten could, if undetected, contaminate as much as a thousand pounds of food.

Often, U.S. officials don't know where or how such ingredients were produced. We know, however, that alarms have been raised about hygiene and labor standards at many Chinese manufacturing facilities.

That it was pet food that got tainted -- and that relatively few pets were harmed -- is pure happenstance. Earlier this spring, Europe narrowly averted disaster when a batch of vitamin A from China was found to be contaminated with Enterobacter sakazakii, which has been proved to cause infant deaths. Thankfully, the defective vitamin A had not yet been incorporated into infant formula. Next time we may not be so fortunate.

Protecting the Food Sector: How Is DHS Doing?

Even more housecleaning: In February, DHS' Office of the Inspector General (OIG) published an analysis of DHS' role in defending the food sector, which is one of the critical infrastructure sectors identified in the National Infrastructure Protection Plan (NIPP).

The OIG's analysis is lengthy and comprehensive, resulting in 16 recommendations. My review will be selective, focused only on a couple of those recommendations. First, some background on OIG's report:

This report examines DHS activities relating to post-harvest food, and focuses on prevention, protection, preparedness, and detection efforts.

There are four main limitations in DHS’ related efforts.

• First, DHS must improve internal coordination.
• Second, DHS needs to engage its public and private food sector partners more effectively.
• Third, DHS could do more to prioritize resources and activities based on risk.
• Finally, DHS must fully discharge its food sector responsibilities.

The report makes clear that the risk to the food sector is real:

Food products may be deliberately contaminated with chemical, biological, or radiological agents. In 2003, the FDA wrote that, “If an unintentional contamination of one food … can affect 300,000 individuals, a concerted, deliberate attack on food could be devastating, especially if a more dangerous chemical, biological, or radionuclear agent were used.”

The effects could be significant:

The Centers for Disease Control and Prevention (CDC) estimates that the United States experiences 76 million illnesses, 325,000 hospitalizations, and 5,000 deaths from unintentional food contamination each year. Recent USDA estimates place the annual cost of premature deaths caused by a single common foodborne illness, salmonellosis – an illness resulting from infection with Salmonella bacteria – at over $2.1 billion.

Commentators on the subject have observed that an adverse food sector event could also reduce state and local governments’ ability to maintain order and deliver essential services. A major food contamination event could engender public panic on a local or mass scale, depending on the affected food product and population, and media coverage of the incident.

As I indicated, the OIG made 16 recommendations, but I'm going to focus on the ones that deal with DHS' relationships with other agencies and the food industry. My two emphases will be collaboration and information sharing.

Collaboration

The OIG report clearly indicates that DHS needs to improve its collaborative relationships. Everyone is not singing from the same songbook:

Vibrant cooperation and support between government and the private sector are needed to fully understand vulnerabilities, study possible consequences, prepare for threats, and implement mitigation measures.

One major complication to effective collaboration is the sheer size and complexity of the food industry:

The post-harvest food industry accounts for 12% of the nation’s economic activity and employs more than 10% of the American workforce. It consists of enormous subsectors, including business lines addressing processing, storage, transportation, retail, and food service. Statistics on just two of these subsectors serve to illustrate the magnitude of the sector.

The National Restaurant Association projects that the industry’s 925,000 U.S. locations will reach $511 billion in sales for 2006, serving over 70 billion “meal and snack occasions” for the year. Meanwhile, the nation’s $460 billion food retail business consists of more than 34,000 supermarkets, 13,000 smaller food markets, 1,000 wholesale club stores, 13,000 convenience stores, and 28,000 gas station food outlets.

Regulatory systems are equally complicated, encompassing all levels of government:

Regulation of the food industry is divided between federal, state, and local agencies. State, territorial, and local governments conduct oversight of food retail and food service establishments within their jurisdictions. These levels of government oversee restaurants, institutional food service establishments, and hundreds of thousands of food retailers. Within the federal government, primary responsibility for food safety rests with two agencies. The Food Safety and Inspections Service of the U.S. Department of Agriculture (USDA) oversees the processing of red meat, poultry, and processed egg products. The Food and Drug Administration (FDA) of the Department of Health and Human Services (HHS), in turn, regulates the processing of virtually all other food products. In addition to these two, several other federal agencies provide oversight of food processing, distribution, and retail.

But this complexity makes effective collaboration even more critical:

External coordination is essential for DHS to succeed in executing its responsibilities for food defense and critical infrastructure protection. Relationships with food sector partners are important because of the operational control and regulatory sway that they have with the sector. Related input from public and private sector partners is particularly valuable in light of DHS’ limited food sector experience. Partnerships with governmental entities are also vital because DHS shares so many food sector responsibilities.

To that end…

The Food Information Sharing and Analysis Center (Food ISAC) was established in February 2002…

According to industry representatives, the Food ISAC distributed some useful threat and vulnerability information to food industry associations and firms in 2002 and early 2003. By mid 2003, however, DHS’ Office of Infrastructure Protection had concluded that, as implemented, the Food ISAC was not well-suited to serve the department’s full range of information sharing and analysis objectives.

…and in 2003 many of the functions of the Food ISAC were moved to other newly created organizations …

In August 2003, Office of Infrastructure Protection managers assembled more than 200 food and agriculture sector representatives to discuss the department’s vision for information sharing and coordination. According to the Office of Infrastructure Protection, the assembled sector representatives were then given the opportunity to develop a new organizational structure. Two bodies emerged from this DHS-facilitated process – the Food and Agriculture Government Coordinating Council and the Food and Agriculture Sector Coordinating Council.

Meanwhile, the Food ISAC's output was not effectively replaced. A potentially valuable collaborative partnership was being spoiled:

By spring 2006, the Food ISAC’s contact with the government had deteriorated to the extent that, according to the ISAC, it did not have a dedicated DHS point of contact. This has contributed to a decline in the volume and scope of information disseminated to industry by the ISAC. Industry representatives reported that the flow of information from the ISAC to the private sector had declined, and that this decline had not been offset by increased information flow from other sources.

Instead of drawing on the food industry’s post-9/11 momentum on critical infrastructure protection efforts, DHS effectively alienated the ISAC’s leadership and disengaged from its operations. Meanwhile, as we discuss later, the coordination and information sharing mechanisms DHS instituted to address the ISAC’s limitations have been slow to develop and are only partially successful.

Meanwhile, as DHS was working to establish the two new councils, another problem was developing. According to food industry personnel, there was a lack of cooperative spirit:

Past and present council members attributed this sluggish start to DHS. They reported that DHS had taken a “top-driven” approach to its critical infrastructure protection leadership role, and that this detracted from the vitality of the councils and sapped the cooperative spirit from the process.

This approach reportedly created a difficult environment for the growth of collaborative efforts and did little to foster productive working relationships with industry leaders and government experts. Several council participants we interviewed said that DHS needed further growth as a business partner.

In its work with the councils, DHS in some ways acted more like a boss than a partner:

Early Sector Coordinating Council and Government Coordinating Council meetings did not foster efforts to formulate policy, and when DHS solicited the ideas and recommendations of council members on policy matters, the solicitation process was sometimes regarded as flawed. One limiting factor for policy development during meetings was a shortage of time to comment on draft documents. Some Sector Coordinating Council members reported that their association members generally did not comment on DHS drafts because they were provided insufficient time to do so. This made it hard for food associations to communicate their members’ concerns. DHS may have thus lost out on important insights from major components of the nation’s food sector.

And the results were less than optimal - a view which is furthered by GAO reporting on the National Infrastructur Protection Plan (NIPP). See this post for a summary of GAO's recent findings.

[NIPP] Sector-Specific Plans, which are authored by the Sector-Specific Agencies, discuss how each sector will address infrastructure protection. While DHS reportedly developed the Sector-Specific Plan template over the course of a year, it allowed the Sector-Specific Agencies just two months to complete their draft Sector-Specific Plans. This was an especially challenging task because the Sector Specific Agencies were asked to consult with their stakeholders as part of the Sector-Specific Plan formulation process. As a result, staff from the Sector-Specific Agencies indicated that Draft Sector-Specific Plans were assembled hurriedly and were not as valuable as they could have been.

As a result, the councils have also slumped …

Frustration with the slow pace of council progress and disenchantment with DHS’ management style and level of engagement may have led to declining participation in the Government Coordinating Council. Our analysis of Government Coordinating Council meeting minutes shows a difficulty achieving what the Council’s charter calls a “decision-making quorum.”

… and they're feeling unneeded …

[D]uring the crisis following Hurricane Katrina, the Federal Emergency Management Agency was asked to attend a joint session of the councils, but did not do so. The councils were an untapped resource that could have been more involved in getting food and bottled water to affected citizens. We were told that, due to DHS’ perceived unresponsiveness, companies used their own connections to provide food assistance to hurricane victims.

So, what's the answer for DHS? The same as it was in the beginning - foster trusting relationships. Collaboration is not a simple transactional relationship. It is built on mutual respect and trust – and it takes time.

DHS’ ability to foster and maintain a positive relationship with the coordinating councils will do much to determine the department’s overall effectiveness in providing leadership, coordination, and support of food defense efforts.

Information Sharing

There are also issues with information sharing between DHS and the food sector. One problem deals with the ever-troubled Homeland Security Information Network (HSIN):

The Homeland Security Information Network Food and Agriculture portal is a web-based tool for sharing threat and analytical information with sector representatives. DHS engaged food sector representatives in the design and online layout of the portal starting in October 2004. More than a year-and-a-half later, these discussions were still ongoing.

Another problem? Redundancy:

While food sector representatives were aggrieved by the portal’s early stage of development, [the OIG is] concerned that the HSIN's Food and Agriculture portal may essentially duplicate an FBI effort. A limited access web community with information on threats, vulnerabilities, and protective efforts related to the food and agriculture sectors, the FBI’s AgInfraGard became operational in March 2006. As described by the FBI and food sector representatives with access to the web community, much of AgInfraGard’s content is similar to that of the Homeland Security Information Network’s portal. The FBI believes its system is developing more quickly than the Homeland Security Information Network’s and has greater capability for information exchange. Meanwhile, according to one FBI analyst, the DHS system “takes information but it doesn’t give a lot.”

A different struggle has arisen regarding the type of information to share. In trying to analyze the food sector, DHS has focused on identifying assets. But they're not getting the full information on food assets:

As of January 2006, the National Asset Database had information on 77,069 infrastructure assets around the nation. Of those, 6,486 assets, or eight percent, were listed as relating to the post-harvest food sector.

Despite the broad geographic distribution of food industry assets and the prevalence of major food processing, transit, retail, and service facilities in all major U.S. cities, all but 2 of [the 20 most populous U.S.] counties had fewer than ten food assets listed in the National Asset Database.

One problem: Information about food assets is not being fully shared among federal agencies:

One reason data limitations such as these persist is that the Office of Infrastructure Protection has been unable to exploit existing federal information about food industry assets. Office of Infrastructure Protection staff reported that, in one case, this was the result of the FDA’s unwillingness to share information. Office of Infrastructure Protection staff advised us that they had sought the registered food facility list that FDA is required by law to maintain, but said that FDA had resisted sharing this information.

A bigger problem may be that analyzing systems, not assets, is probably the most appropriate means of analyzing the food sector:

The USA PATRIOT Act defines critical infrastructure to include systems and assets, yet the National Asset Database emphasizes assets. To date, the most advanced step by DHS to define parts of the food system has been the development of a sector taxonomy to support the classification of National Asset Database assets.

Industry and federal partners…held that DHS had focused too intently on assets, and devoted too little thought and energy to understanding the food sector as a system.

It doesn't have to be that way. Other federal agencies use a systems approach to analyze the food sector:

USDA and FDA ... focus their vulnerability and consequence assessments on particular industry subsystems and food products, rather than on particular assets.

And private sector representatives agree:

Food sector representatives said that DHS’ asset-orientation would result in an understatement of food sector risk for three reasons.

• First, they perceived that the DHS’ focus on assets led the department to emphasize the effects of asset destruction over asset exploitation. As discussed earlier, the greatest concern to many in the food sector relates to the exploitation of the sector to distribute intentionally adulterated foods.
• Second, food sector representatives pointed out that important links in the food supply chain are not easily captured in an asset-based model.
• Finally, food sector representatives expressed concern that DHS’ asset-orientation would lead it away from an understanding of the second- and third-order effects of a food contamination incident. In focusing on a particular food industry asset, they believed DHS would lose perspective on upstream and downstream consequences of an incident affecting that asset. For example, contamination at a processing facility might not just affect that facility.

Accordingly, to grasp the second- and third-order effects of an adverse food event at a single facility, DHS must first understand that facility’s place within the food supply chain and larger economic system.

The OIG suggests, once again, better dialogue. The risk to the food system is not going to be fully understood unless DHS casts a wide net and listens to its partners.

A more effective dialogue between DHS and its partners is needed to address concerns about asset exploitation, assets that do not have fixed coordinates, and system-wide impacts that the malevolent exploitation of food sector assets might have.

Without effective collaboration and information sharing, risk analysis and resulting interventions are not likely to be optimally effective.

Agroterrorism: Local Law Enforcement, You're in Charge

The Department of Justice (DOJ) just published a really interesting 4-page research brief on agroterrorism. According to the report, one aspect of our preparedness is falling far short:

Many believe that public health officials would lead the response to an agroterrorism attack, but this might not be the case. The laws of most States require that such an event be handled as a crime scene investigation, giving law enforcement primary responsibility. Ill-equipped to handle the magnitude of responsibilities that would follow an act of agroterrorism, local police departments would be pushed to the limit.

For example, how many law enforcement agencies - especially smaller agencies in rural areas - are ready to do this:

Research points to the first priority of local law enforcement after an agroterrorist attack: establishing and enforcing a 6-mile radius quarantine (113 square miles) around the point of origin to control the spread of the virus. The second priority would be to set up statewide roadblocks to enforce stop-movement orders. Such a tremendous effort— requiring that all vehicles coming into or going out of the impacted State be stopped and inspected— would require a coordinated response by local, State, and Federal officials.

In the brief, DOJ points out that, by the USDA's estimate, the economic cost to taxpayers of a major foot-and-mouth outbreak could be $60 billion (and a DHS official recently estimated the cost would be in the hundreds of billions). Given this, the DOJ calls for action:

Because terrorists rely on a lack of preparedness, law enforcement agencies should start now to develop a plan for preventing an agroterrorism attack—and the interruption of basic services, civil and emotional stress, and public health concerns that likely would follow.

DOJ also provides some specific steps local law enforcement can take:

On the local level, law enforcement agencies bear a responsibility for intelligence gathering … Local jurisdictions are also in the best position to conduct vulnerability studies of area farms and feedlots.

And perhaps most importantly at the beginning - DOJ suggests whom to collaborate with:

Partnerships—the best way to prevent an agroterrorism attack and the only way to contain one—must be created among local farmers, truckers, feedlot owners, and other critical members of the food-supply chain. A working relationship between criminal investigators and veterinarians and animal and plant health inspectors must be established.

The brief is sort of a good primer for preparedness: There is a threat. We are not fully ready or organized for it. Dealing with the threat could be a massive undertaking. So to get ready, we need to work together and plan now.

Ham and Syringes

The recent discovery of syringe casings around the production line at a meat packing plant in Canada is a reminder of the threat of food and agricultural terrorism.

The Canadian Food Inspection Agency and Maple Leaf Foods have recalled some ham and sliced meat products after police were called in to investigate a small number of syringe casings found at an Ontario plant ... Police said it was the third such discovery reported by employees in the past two weeks.

So far, there have been no reported illnesses associated with eating the products, and no tampered meat has been found on shelves.

This type of terrorism involves a vast array of potential access points. The food industry is inherently vulnerable.

For the local homeland security professional, preparedness and collaboration are vitally important. In the event of a widespread threat, public health officials and law enforcement would have to work closely. Communications planning is also vital. The public will have to be kept informed of the exact nature and extent of the threat.

One final thought: The selection of ham as the target (if this was in fact an act of tampering/terrorism) raises eyebrows. Could certain food products be more attractive to certain types of terrorists? For example, I could see jihadists being attracted to ham as a target, because Islam forbids the consumption of pork. Or radical animal-rights groups might be attracted to meat products of all kinds.

DHS Discusses Foot-and-Mouth Threat

Nothing new here, but the agricultural threat of foot-and-mouth disease got some notice in the recent comments of a DHS official, GovExec reports:

The Homeland Security Department's senior adviser for weapons of mass destruction said late last week that the introduction of foot-and-mouth disease on American soil would have a tremendous effect on the U.S. economy, whether the outbreak is intentional or accidental.

Maureen McCarthy, the weapons adviser, on Friday told attendees of the Association for Intelligence Officers' annual convention that such an outbreak would cost the American agriculture economy "hundreds of billions" of dollars and could shutter some trade borders for "years" if officials deem it necessary.

"It will happen instantly," she said of the financial and trade impact, "even if there are no deaths."

During a discussion that in part focused on how biological agents might be used against the United States, McCarthy said foot-and-mouth disease could be used by terrorists.

Agricultural terrorism is a potentially major vulnerability. Collaboration with state and federal veterinary services is an important part of being prepared.

Successful Interventions by State Public Health Systems

In a new report, the Association of State and Territorial Health Officials highlights some recent successful interventions taken by state health departments to prevent and prepare for serious health threats. Most of the efforts involve improved collaboration and/or information sharing. Some highlights of the report:

The Arizona Department of Health Services ... has created a working network of food professionals from all segments of the food industry to increase food security awareness.

The Missouri Department of Health and Senior Services contracted with the Missouri School Boards Association to create a secure, web-based tool to assist schools in planning and training for emergency events. Beginning April 1, 2006, all schools in the state could upload critical information such as floor plans, students with special needs, staff information, and utility shut-off locations to aid the response to events such as infectious disease outbreaks and hazardous materials incidents.

In South Carolina, the Division of Acute Disease Epidemiology at the Department of Health and Environmental Control summarizes daily epidemiological reports for the state’s intelligence fusion center ... Health data such as summaries of calls to the state poison control center, reports on over-the-counter retail sales of certain medications, calls handled by the 24/7 consultant on-call, and chief-complaint information from hospitals are analyzed each day and summarized by the department prior to submission.

In New York City, the Emergency Data Exchange Network (EDEN) allows different agencies to share environmental health monitoring data. Using wireless Bluetooth technology, field staff are able to collect and automatically transmit environmental information including air and radiological monitoring data. The environmental handheld project is just one of the many data sources for EDEN.

The Ohio Department of Health used its public health communication system to rapidly establish a secure, Web-based reporting system for Clostridium difficile infection. Beginning January 1, 2006, more than 120 local health departments have weekly access to the system and the capacity to provide and update reports for the hospitals and long term care facilities within their own jurisdictions.

Tennessee ... merged tabletop and full-scale exercise activities of its public health, animal health, homeland security, and emergency management agencies under one umbrella. By doing so, the state has improved overall collaboration and gained a better understanding of how efforts are integrated during an emergency response.

The report also highlights some other examples, but I found these to be the most intriguing. Especially interesting to me are the ways that South Carolina and New York City have improved their situational awareness by using information-sharing technology.

Maritime Terror Risks

The RAND Corporation released a new report yesterday, Maritime Terrorism: Risk and Liability. The authors used a threat-vulnerability-consequence methodology and concluded that the greatest risks in terms of threat and vulnerability are:

• Ferries: Onboard bombings
• Cruise Ships: Onboard bombings (followed closely by standoff artillery assauts and food or water contamination)
• Cargo Ships: Radiological Dispersal Device (i.e., dirty bomb)