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The threat of terrorism against our food supply is as real today as it ever has been. Whether it’s an attack on the products themselves, such as product tampering or sabotage, or a cyberattack against a company’s internet infrastructure, it can be harmful and costly if not recognized in advance. Plans should be in place to not only respond to such an attack but also to prevent it. ~ Rod Wheeler, NSF.org
National Security Memorandum
On November 10, 2022, President Joe Biden signed National Security Memorandum-16 (NSM-16) to strengthen the security and resilience of U.S. food and agriculture. This critical sector has continued to face increasing deliberate and naturally occurring threats to security and resilience, including intentional adulteration (IA), catastrophic events (e.g., pandemics that impact critical infrastructure), consequences of climate change, and cyber- and technology-related vulnerabilities.
NSM-16 replaces Homeland Security Presidential Directive 9 (Defense of United States Agriculture and Food – HSPD-9) and outlines the Administration’s guidance to:
- Identify and assess the threats of greatest consequence. This includes redefining how chemical, biological, radiological, and nuclear threats are defined; focusing on increased cyber threats and climate change impacts; and enhancing threat and risk assessments by mandating a continuous process to assess and mitigate risks and vulnerabilities.
- Strengthen partnerships to enhance the resilience of the workforce, who are typically the first line of response, and coordinate our government to act more efficiently and effectively. Essential critical infrastructure workers need guidance to work safely, while supporting operations during high-consequence incidents.
- Enhance preparedness and response by training partners on how to prepare for and respond to threats, increasing testing and diagnostic surge capacity, and standardizing diagnostic and reporting tools to facilitate timely information sharing.
Ongoing Security Actions
NSM-16 builds upon ongoing actions by the Administration to strengthen the resilience of the U.S. food and agriculture supply chains.
- U.S. Department of Agriculture (USDA) considers defense of the food and agriculture sector critical. USDA’s Food Safety and Inspection Service (FSIS), Animal and Plant Health Inspection Service (APHIS), and National Institute of Food and Agriculture (NIFA) have launched numerous programs to protect these sectors, including FSIS working to help industry partners develop effective food defense plans.
- U.S. Department of Homeland Security (DHS) Office of Health Security Health, Food, and Agriculture Resilience (OHS/HFAR) directorate is also working to help safeguard the American food supply against catastrophic incidents by bringing a national security perspective to the food and agriculture sector. In recent years, OHS/HFAR has engaged directly with partners to perform risk assessments, develop strategic guidance, and design and deliver tailored exercises to better prepare for, respond to, and recover from catastrophic events.
- U.S. Food and Drug Administration (FDA) is engaging with federal; state, local, tribal, and territorial (SLTT) governments; the private sector; and academia on the following activities:
- Conduct of vulnerability assessments
- Risk mitigation analysis
- Federal risk mitigation strategy
- Strengthening existing efforts for information sharing procedures
- Research and development
Roles of Food Safety and Food Defense
According to USDA-FSIS, to prevent, protect against, mitigate, respond to, and recover from threats and hazards of greatest risk to the food supply, preparedness efforts must encompass food safety and food defense.
Food safety provides for the protection of food products from unintentional contamination. Food defense involves the protection of food products from intentional contamination or adulteration (e.g., biological, chemical, physical, or radiological) that causes harm to public health or disrupts the economy in other ways.
The anticipated outcome of combined food safety and food defense efforts is food security. Food security exists when all people, at all times, have physical, social and economic access to sufficient, safe and nutritious food which meets their dietary needs and food preferences for an active and healthy life (United Nations Food and Agriculture Organization (FAO)).
Your Role: Food Defense Plan
Food defense involves putting security measures in place to reduce the chances of someone intentionally contaminating the food supply. FDA’s Food Safety Modernization Act (FSMA) rule on Mitigation Strategies to Protect Food Against Intentional Adulteration (IA) establishes requirements for industry to play an active role in improving the nation’s food security and resilience. This rule requires covered facilities to prepare and implement food defense plans.
The food defense plan incorporates four major elements:
- The vulnerability assessment identifies those areas in the process that pose the greatest IA risks. Each step in the facility’s process should be evaluated for the following:
- Potential severity and scale of the impact on the public.
- Physical access to the product.
- Ability to successfully alter/contaminate the product.
- Facilities must develop and implement mitigation/preventive strategies at each step in the process to address vulnerabilities and minimize the risks of IA.
- A system must be put in place to ensure implementation of mitigation strategies and to effectively manage the following:
- Monitoring mitigation strategies, including frequency.
- Corrective action response.
- Verification activities.
- Appropriate recordkeeping must be maintained for food defense monitoring, corrective actions, and verification, and key personnel must receive appropriate training.
The safety and security of our country’s food products requires developing, implementing, and enforcing policies and programs to support strong food defense. And it requires continually involving all employees in these food defense and security efforts to create a robust food safety culture. The threats to our nation’s food supply—and to those companies who work in the food supply chain—will continue. Taking an active role in controlling what you can and proactively managing your organization’s food defense efforts can play a significant role in securing the food supply chain.