Food defense is becoming an increasingly hot topic in our expanding global food industry. FDA’s new Food Protection Plan places equal emphasis on food safety and food defense program implementation. Unfortunately, with pressures from an unsteady economy, sustainability demands and food safety issues at hand, small and mid-size food facilities find it difficult to allocate time and money for food defense. However, in order to be successful in today’s competitive market, these companies need some way to prove to their customers that they are taking proactive measures to prevent crisis situations.
Today’s technological advancements make food defense planning a much easier task for food companies of any size. There are low-cost and even free (yes, free) tools available that allow facilities to measure their risks and develop plans to prevent intentional contamination.
CARVER + SHOCK. What company doesn’t like free resources? Especially free resources that will save immeasurable dollars by taking proactive measure to prevent intentional product contamination?
Last year, FDA sponsored the development of free downloadable CARVER + Shock software that allows members of the food processing industry to conduct confidential vulnerability assessments of their facilities and processes. This offensive-minded prioritization tool allows the user to think like an attacker to identify the most attractive targets for an attack. By conducting a CARVER + Shock assessment of a food production facility or process, the user can determine the most vulnerable points in the infrastructure, and focus resources on protecting them.
WHAT DOES CARVER + SHOCK MEAN? CARVER is an acronym for the following six attributes used to evaluate the attractiveness of a target for attack:
- Criticality — measure of public health and economic impacts of an attack
- Accessibility — ability to physically access and egress an area
- Recuperability — measure of the time it will take to recover from an attack
- Vulnerability — the ease of accomplishing an attack or introducing threat agents
- Effect — the amount of direct loss from an attack as measured by loss in production
- Recognizability — ease of identifying target
A seventh attribute, Shock, has been added to the original six to assess the combined health, economic and psychological impacts of an attack within the food industry.
HOW TO CONDUCT AN ANALYSIS. Once you download and install the CARVER + Shock software, there is a series of instructions on how to complete the vulnerability assessment.
Before any scoring can begin, the scenarios and assumptions you wish to use in the analysis must be established in order to guide all further steps. As a food safety professional, you need to determine what you are trying to protect and what you are trying to protect it from. This will help focus your food safety efforts.
Next, a team of subject matter experts should be organized to conduct the assessment. The team will apply the CARVER + Shock method to each element of the food system infrastructure and assign a value from one to 10 for each attribute.
The analysis begins by developing a description of the system under evaluation. A flowchart of the system and its subsystem, complexes, components and nodes should be developed to facilitate this process.
When the infrastructure has been broken down into its smallest parts (nodes), these can be ranked for each of the seven CARVER + Shock attributes to calculate an overall score for that node. The nodes with the highest overall scores are those that are potentially the most vulnerable, and therefore the most attractive targets for an attacker. Once countermeasures are in place, you can measure annual improvements with the score system.
SOFTWARE AVAILABILITY. CARVER + Shock software is a great basic tool that any size facility can use to define risks, determine countermeasures, and communicate needs to decision-makers. This free, user-friendly program is invaluable for small companies with limited funds for food defense planning. It can be accessed at any time from any computer. To download the software and begin a risk assessment today, go to: http://www.cfsan.fda.gov/~dms/carverdl.html.
FOOD DEFENSE PLAN. Once you define risks, the next step is to develop a food defense plan to establish countermeasures that minimize the attractiveness of potential targets. This plan would include physical, personnel and operational security enhancements that minimize access to the product or process.
Many regulatory agencies, customers and third-party inspectors require some type of food defense plan to be developed and implemented in food facilities. USDA’s Commodity Credit Corporation (CCC) agreement requires regulated facilities to develop a security plan. USDA inspectors now are reviewing these during visits. Food companies involved with the Customs Trade Partnership Against Terrorism (C-TPAT) program also must implement a food defense plan. Although FDA does not require a food defense plan at this time, its inspectors do discuss security during regular GMP visits.
Although a CARVER + Shock assessment is a great start, there are additional resources that support it to complete a more complex food defense program and offer more advanced protection. AIB’s Food Defense Plan Template (FDPT) helps any size food facility develop a plan that incorporates its specific physical and procedural needs.
There are 21 sections in the template. Users fill in the blanks in each section and include additional relevant information for their facilities. Once completed, a detailed food defense plan is generated. The FDPT sections include:
- Food Defense Plan Management
- Area Emergency Assistance and Places of Refuge
- Facility Schematics
- Vulnerability Assessment Report
- Product Recall Procedures
- Personnel Security Procedures
- Information Technology Security Procedures
- Outside/External Facility Security
- Inside/Internal Facility Security
- Processing Areas Security
- Product/Chemical Storage Areas Security
- Shipping/Receiving Areas Security
- Evacuation Plan/Shelter-in-Place Plan
- Medical Emergency Plan
- Water/Ice Security
- Mail Handling Security
- Homeland Security Threat Conditions
- Guard Services Security and Training
- Business Continuity and Recovery Plans
- Additional Programs and Resources
- Change Log
This CD sells for $225, a minimal cost compared to the time saved and valuable benefits produced. For more information or to order online, go to: www.aibfooddefense.org.
The CARVER + Shock software and AIB’s Food Defense Plan Template are an excellent, affordable way to create a Food Defense Plan or make improvements to your existing program. Small and mid-size companies with limited funds can breathe a sigh of relief with these low-cost resources that produce phenomenal results.
The author is Publication Coordinator, AIB International.