[Food Defense] Employee Training

Since the events of September 11, 2001, and the anthrax incidents that followed, there is a growing concern about new kinds of terrorist attacks. A major concern is the threat of attacks on the United States food supply. Intelligence reports have found that a terrorist attack on the food supply could pose both severe public health and economic impacts and also damage the public’s confidence in the food that we eat.

So opens the script of a new food defense video from FDA directed toward training front-line workers to help protect against intentional contamination of the food supply. It is part of the initiative, Employees FIRST, developed in coordination with USDA and CDC, focused on employees as the first line of defense in preventing, detecting and responding to potential threats to the food supply.

Implementing such defense means training workers to recognize and report signs of potential threat as well as taking steps to help ensure the hiring and placement of trustworthy employees. It is an ongoing process in which every person in the plant plays a part.

“It is everyone’s responsibility to protect the product,” said William Ramsey, corporate director of security for McCormick & Company, and member of ASIS International Agriculture & Food Security Council. As such, Ramsey said, “Training starts on the day (new employees) come to work and continues until the day they leave or retire.”

In addition to the day-to-day applications, a focused food protection training program, in food safety as well as food defense, should be conducted at least twice a year, Ramsey said.

While there are differences between the two, primarily that of food safety being protection again unintentional contamination and food defense being protection against that which is intentional, both focus on food protection, and when an incident arises, he said, “No one knows initially if it is food safety or food defense, so we all have to be on one team.”

RAISING AWARENESS. Tara Paster, president of Paster Training, also believes it is important to begin training employees on food defense immediately. “On their first day, you need to lay the foundation for their employment,” she tells employers. Employees should be told from the start that it is their responsibility to understand the company’s food protection plan, to know their specific role and to report any irregularities to management.

It can be difficult, and even daunting, for a plant to develop employee training in food defense, Paster said. How does a company teach its employees enough to be aware but not so much as to give ideas to an immoral or disgruntled worker? “You have to start with the awareness of your employees. That is your responsibility,” she said.

Thus, training should emphasize this awareness through discussion, employee responsibility and “what if…” exercises, rather than focusing on any specific ways that contamination or sabotage could occur. For example, Paster developed a food defense orientation form. Reviewed and signed by the employee, the form contains items such as:

• Be aware of who is working at a given time and where (in what area) they are supposed to be working.
• If you know an employee is no longer with your company and this person enters an “employees only” area, notify your manager immediately.
• Take all threats seriously, even if it is a fellow coworker blowing off steam about your manager and what he or 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 manager, the customer or the business.
• If you use a food product every day and it is supposed to be blue but today it is green, stop using the product and notify your manager.

CONTINUING AWARENESS. In the same way, FDA’s FIRST employee training focuses on the role of the employee in food protection.

With its simple five-step acronym for food protection and employee training kit, including the entertainingly educational video with knowledge-check questions, FDA’s FIRST is gaining ground in the industry as a means of continuing education in food defense.

The training is the second phase of industry education initiated in 2006 with the ALERT program (“Staying ALERT,” QA November/December 2007). Intended to raise the awareness of government agencies and the industry to food defense issues and preparedness, ALERT identifies five key points (Assure, Look, Employees, Reports, Threats) to which businesses should be alert for food protection.

Industry feedback on the ALERT initiative was that the product is good, said Marion Allen, a member of the FDA Food Defense Oversight Team, but that there was a need for a program that would engage employees and make them aware of their role in food defense.

Thus came the development of FIRST. Both programs are derived from the FDA Food Security Guidance documents, with the intent to simplify the message and use graphics to get the points across, Allen said, adding, “FIRST is the second phase of ALERT.”

In any industry, employees are the first ones to see what actually happens in a facility’s operations, Allen said. “They are the nuts and bolts of an operation; they are the eyes and ears of everything going on.” Training employees to recognize potential threats and bring these to management’s attention is a key step in averting intentional food contamination or sabotage.

FIRST. As symbolized by its acronym, FIRST is designed to help front-line food industry workers remember five basic steps in food protection:

• Follow company food defense plan and procedures. Understand and stay updated on the plant’s food defense plans and procedures, and be prepared and willing to put them into action if needed. Having a plan is the first step in thwarting potential terrorist schemes and threats against the food supply.
• Inspect your work area and surrounding areas. Visually inspect the work area before, during and after your shift. Inspect food materials for tampering and report anything out of the ordinary. Keep all personal items away from food processing or storage areas.
• Recognize anything out of the ordinary. This includes identifying any unauthorized access or changes in your equipment, and following company procedures to limit access to the facility and controlled areas. Never give out a keycard or access code to anyone, and be aware of individuals without proper clothing or identification.
• Secure all ingredients, supplies and
  finished product. When things are properly secured, the wrong people cannot get to them. Secure ingredients, supplies and food during preparation, distribution and storage, and store food products separate from toxic chemicals such as cleaning and sanitizing products.
• Tell management if you notice anything unusual or suspicious. This could include unlocked or open doors or equipment; unusual behavior by employees, customers, contract workers or other individuals; or suspected food or product tampering — anything that could be perceived as a threat.

The FIRST training kits became available in late October 2008, to an immediate and almost overwhelming response.

“We got over 1,300 requests for the tool kit in the first two weeks after it came out,” Allen said. Although this initially caused a backlog, the agency is now catching up on the orders, she said. (The kits and other resources are available at www.cfsan.fda.gov/fooddefense.)

IT CAN’T HAPPEN HERE. One of the first tasks of any food defense training is getting past the “It can’t happen to me” mentality. Having conducted training in numerous facilities, Paster said that most employees do not really believe that an attack could happen in their business, and ask, “Why is this important to learn?” Those in small companies or rural areas, she added, tend to be shocked that the possibility even exists.

More difficult for many to comprehend is the potential of internal sabotage, she said. “The inside threat is the hardest to grasp. People don’t think that their co-workers would do that. The outside potential threat they can better grasp.”

“Workplace violence is a real issue,” Ramsey added. It’s no longer a matter of disparaging disgruntled workers and saying, “Oh, Joe wouldn’t do that!” Rather, he said, you put your brand at risk if you don’t properly investigate any potential threat — internal or external.

One way of increasing your plant’s security is to identify vulnerable areas within your plant and place your most experienced and trusted workers in those areas. For example, “I wouldn’t use a temp in a mixing area if you can avoid it,” he said. “If you can’t, you should have good management there to oversee the process and ensure integrity.”

Paster does see this as changing, however, and the industry as becoming more active in food defense. “I think now that people are discussing it more, it’s in the forefront,” she said, adding, “As an industry we’re doing a much better job.”

THE FUTURE. Ramsey sees this trend as continuing. “I see a shift toward the importance of food defense,” he said. Before Sept. 11, it was all about food safety and unintentional contamination. Food defense, he said, “really didn’t have a seat at the table.”

One challenge still facing the industry is that of having knowledgeable personnel in place to properly implement and manage food defense programs.

While plants do designate persons in charge of food safety and there does need to be a unified effort for food protection, there is a specific discipline, background and expertise needed for food defense that is separate from food safety, Ramsey said. “I believe there is a minimum of five years learning needed.”

Many of today’s food defense experts formerly held law enforcement positions; while this may not be the optimum background, it does provide security-focused expertise and way of thinking. And, Ramsey said, “If nothing else, that background shows where your interests are.”

As food defense becomes ever more prominent in the industry, experts are coming on board with ever-widening backgrounds, including university degrees or extensive research in food defense — all of which is continuing to propel the trend forward.

“We certainly have accom-plished an awful lot since 2001,” Ramsey said. In fact, he added, more has been achieved in food defense in the last seven years than had been applied in the 100 years before that.

The author is staff editor of QA magazine.

7 Signs of a Security Threat

According to a field information bulletin from the New York State Metropolitan Transit Authority Police Department Task Force, there are seven key signs of terrorist activity planning and prevention opportunities at each stage: 

1. SURVEILLANCE. Aggressors will often observe the target area to establish routes, determine strengths, weaknesses, and security levels.
Prevention: Watch for anyone recording or monitoring activities, drawing diagrams or annotating maps or having unauthorized floor plans.

2. ELICITATION. Aggressors may try to gain information by researching entry points,  questioning shipment and operational processes, or placing people in sensitive work areas.
Prevention: Watch for and advise employees to report anyone seeking information about plant personnel, facilities or operations.

3. SECURITY TESTS. Aggressors may test plant security to determine response. They often gain legitimate employment at key locations, and may try to penetrate security barriers or procedures to assess strengths and weaknesses. 
Prevention: Watch for persons observing specific areas, moving into sensitive areas and noting security response.

4. SUPPLY ACQUISITION. Aggressors may try to store explosives, weapons or harmful chemicals in the plant. Non-employees may seek false plant or security IDs to access secured or prohibited areas.
Prevention: Watch for attempts to photocopy or make false IDs; listen for employee discussion of false IDs, incendiaries or other suspicious items.

5. UNKNOWN PERSONS. This is not profiling of individuals, but of behaviors that do not “fit” because of demeanor, language usage or unusual questions.
Prevention: Watch for suspicious people around the plant who “don’t belong.” 

6. DRY RUNS. An operation will generally be rehearsed multiple times to work out flaws and unanticipated problems. This stage provides the best chance of intercepting and stopping an attack.
Prevention: Watch for anyone monitoring a police radio frequency, recording emergency response times, mapping out routes, or timing the daily flow. 

7. DEPLOYING ASSETS/GETTING INTO POSITION. This is the last chance to apprehend an aggressor before the act occurs. Remember that pre-incident indicators may come months or even years apart, so it is important to document and follow up every fragment of information, no matter how insignificant it may appear.