Food Defense: International Collaboration in a Critical Area of Biodefense

Good morning. I'd like to thank the European Institute for the opportunity to speak today about food defense and the importance of international cooperation and collaboration to protect the food supply from intentional contamination.

Our food supply and distribution system is global in nature and poses a relatively soft target offering many points at which it could be deliberately contaminated. We often don't realize the extent to which this is true since food appears at the table without much thought about how it got there. It is only when there is the rare case of contamination and consequential recall that we realize how far and wide food items are distributed or the extent to which they are processed. As a result, it is not necessarily obvious to the consumer that the food supply and distribution system are vulnerable to deliberate contamination. Furthermore, characteristics of certain foods may make them more attractive targets because contamination of those foods increases the potential number of people impacted. Fortunately, while the food supply and distribution system are soft targets, there are many steps nations can and have taken individually and collectively to harden these targets and better enhance national and international food defense.

Distinguishing between Food Defense, Food Safety, and Food Security

Before I go further with my remarks, it's important at this juncture to clarify the terminology I will use. It has been our experience that there are some seemingly similar terms used to refer to protecting the food supply against intentional contamination. But, each of the terms means something fairly different, and the use and misuse of the various terms can cause confusion.

The term Food Defense encompasses the steps taken to minimize or mitigate the threat of deliberate contamination of the food supply, and includes identifying points of vulnerability and working to strengthen infrastructure, thereby, making the food supply a less attractive and, more importantly, less vulnerable target. Controls in support of Food Defense include physical security, for example, monitoring the premises for suspicious activity, or locking chemical storage facilities; personnel security, for example, screening employees, use of name badges; and operational security, for example, monitoring production to prevent sabotage, use of tamper-evident packaging.

This is distinct from Food Safety, which focuses on setting standards for industry regarding the safety of food, good manufacturing practices, quality control of agricultural products, and promotion of trade in food products. Control strategies to enhance food safety can also be distinct from those involved in food defense and include: risk management strategies such as Good Agricultural Practices (GAP); Good Manufacturing Practices (GMP); good hygiene practices (GHP)/ Sanitation Standard Operating Procedures (SSOP); and Hazard Analysis Critical Control Points (HACCP) to prevent or reduce microbial, chemical, or physical contamination.

Finally, Food Defense is also distinct from Food Security which is defined by the World Health Organization and others as “when all people at all times have access to sufficient, safe, nutritious food to maintain a healthy and active life.” In other words, Food Security is a concept that is often discussed in terms of dealing with famine or other national or international food shortages.

Many have used these terms interchangeably and, I would argue, erroneously, creating confusion during both national and international policy discussions. Our focus today is on Food Defense and on the ways in which it intersects with international collaboration.

Food Defense – What is the Issue?

There is a genuine terrorist threat to the global food supply, both at the production and processing stages. In May 2002, the World Health Assembly recognized this threat when it stated that “the malicious contamination of food for terrorist purposes is a real and current threat, and deliberate contamination of food at one location could have global public health implications.” Evidence suggests that terrorist groups have considered the food supply as a target. Before the September 11 terrorist attacks in the United States, many modern bioterrorism attacks were perpetrated using food products with the express purpose of extortion, corporate sabotage, terrorism, political influence, destruction of brand or company image, and/or destruction of an economic sector. Materials discovered since September 11, 2001 at Al Qaeda training camps in Afghanistan show knowledge of specific agents that could be used to contaminate the food supply (their sources, maintenance, growth and toxicity) and the potential of the food supply for the distribution of those agents.

The food supply is a relatively soft target offering many points at which it could be deliberately contaminated. In today's marketplace, food is mass produced and rapidly distributed throughout the world; if contaminated, it could cause morbidity and/or mortality on a global scale. Characteristics of certain foods make them more attractive targets because contamination of those foods increases the potential number of people impacted. Vulnerable food products include those that are mixed during production allowing uniform distribution of an agent throughout the product; those with a short shelf-life, increasing the chance that the food will be consumed prior to detection of contamination; those that are easily accessible to a terrorist (e.g., open access to food production facilities, or unlocked trucks, etc.); and those that are made in large batches allowing great volumes to be contaminated at one time. Furthermore, a number of agents could be used to contaminate food, ranging from microbial agents typically seen in unintentional outbreaks of foodborne illness, pathogenic organisms not normally associated with food consumption, to organisms that have been genetically modified to be more lethal, to highly toxic chemical agents.

A motivated terrorist organization can work to acquire/recruit individuals with the scientific training, technical know-how, fiscal support, and high level planning to produce or procure a wide array of specified agents and the terrorist organization may add contaminants directly to the food or to an ingredient.

It's clear from the historical evidence that the food supply does present an appealing target to those who would wish to cause harm to human health, economic well being, or sociopolitical stability. The deliberate contamination of the food supply is neither a new nor novel threat. Throughout history, we have seen episodes of intentional contamination sicken many individuals; and we've seen these episodes not necessarily with the intent to kill, but rather, to cause economic loss. For instance, in 1978, deliberate contamination of Israeli citrus with the heavy metal mercury resulted in a dozen or so children being hospitalized in the Netherlands and West Germany. Terrorists stated they were targeting the Israeli economy.

Other U.S. and international examples in recent history include:

• In 1984, the Rajneeshee religious group contaminated salad bars in the U.S. state of Oregon in hopes of affecting the outcome of a local election. This incident caused 751 cases of salmonellosis and resulted in the hospitalization of 45 of the victims.
• That same year, Japan also dealt with deliberate contamination when someone contaminated candy in an attempt to extort money from the manufacturer.
• More recently, China had to address this issue when, in 2002, 40 people died and 200 individuals were hospitalized in Nanjing after the owner of a fast-food outlet poisoned a competitor's breakfast foods with rat poison.
• One year earlier, 120 people in China were sickened when the owners of a noodle factory reportedly laced their food with rat poison.
• In Canada in 1970, a postgraduate student tainted his roommates' food with the parasite Ascaris suum. Four of the victims became seriously ill; two of these suffered acute respiratory failure.
• Other incidents in the United States include an incident in 1996 in which a disgruntled laboratory worker deliberately contaminated food to be consumed by co-workers with Shigella dysenteria type 2, causing illness in 12 people. Four of the victims had to be hospitalized and five others were treated in hospital emergency rooms.
• Furthermore, in May 2003, a supermarket employee pleaded guilty to intentionally contaminating 200 pounds of ground beef with an insecticide containing nicotine. Although the tainted meat was sold in only one store, 111 people, including approximately 40 children, were sickened.

These are only some examples of deliberate attacks; it is believed that other attacks with more limited impact may go undetected.

A deliberate attack on food could and would be devastating, especially if a dangerous agent were used. If one looks at incidences of accidental contamination, it is not hard to extrapolate the extent of damage from a deliberate attack. Given the global movement of food, contaminated food can be distributed throughout numerous countries as seen in 1996 and 1997 when thousands of people in 21 states within the U.S. and two Canadian provinces became infected with the parasite Cyclospora after eating Guatemalan raspberries unintentionally contaminated with the pathogen. A deliberate attack on food using highly toxic or pathogenic agents, such as the deliberate contamination of Israeli citrus, could be even more devastating, with illnesses becoming deaths.

By now, we are all familiar with the recent E. coli O157:H7 outbreaks from contaminated spinach, leading to a national recall in the U.S. At last count, 26 states were affected, 204 people were sickened, and 3 people died. And the impact of this incident was international in scope. Like the U.S., Canada, for example, ended up advising consumers not to eat U.S. spinach. By some estimates, this outbreak may cost up to $74 million. Even a rumor or hoax can have a significant impact, as we saw in 2001 when rumors surfaced about Foot and Mouth Disease in Kansas. That rumor resulted in an estimated $50 million loss.

Thus, in addition to the public health impacts of intentional food contamination, the economic consequences could also be staggering. An attack on the food supply would only have to sicken or kill a few individuals to have far reaching and substantial economic consequences, including direct costs for response to an attack, disruption of food distribution, trade restrictions, long-term loss of consumer confidence, and ultimately, loss of market-share to a competing company or nation. Any of these consequences might carry a heavy economic and political toll. For example, in 1998, an unintentional contamination in the U.S. of 16,000 metric tons of frankfurters and luncheon meats potentially contaminated with Listeria monocytogenes cost the producer $50-70 million. The company spent at least another $100 million in the following two years to improve food production and convince consumers that its products were safe. The deliberate contamination in the United States in 1982 of the pain reliever Tylenol with cyanide resulted in seven deaths. This incident resulted in a significant and permanent loss of the company's market share. While not a food product, this illustrates the potential consequences of a deliberate attack. A widespread or pervasive attack would likely have even farther reaching consequences. And a perceived threat or hoax can cause the same kind of economic and political damage without a contaminated food product ever reaching a store shelf.

Though the direct and indirect costs associated with the food sabotage are difficult to fully track or anticipate, reports from unintentional contamination incidents are important indicators of the possible economic consequences if a large-scale deliberate event were to occur. The U.S. Department of Agriculture, for example, estimates that food-borne illnesses linked to just five pathogens cost the U.S. economy $6.9 billion annually. The psychological effects on consumer behavior as a result of fear and anxiety over the possibility of a contaminated food product (loss in consumer confidence) can also have a ripple effect on other aspects of the economy. Given that agriculture and food supply and distribution systems are a positive contributor collectively to the U.S. economy, a significant attack on the food supply could have strong negative impact on the economy. This problem is not exclusive to the U.S. Given Europe's experience with natural outbreaks of Bovine Spongiform Encephalopathy ( BSE or “Mad Cow Disease”) and incidences such as the Belgium dioxin contamination episode in 1999, European officials are acutely aware of the potential impact of a deliberate contamination in terms of human life, shorter term economic cost, permanent market loss, and potential political fall-out would be significant. While the human death toll from CJD in the UK was relatively low (158), the linkage between BSE and human health led to international bans of British beef imports, depressed markets for British beef, crippled the UK's cattle industry, and destroyed consumer confidence in the UK's ability to handle a health and agriculture threat. These outcomes ultimately resulted in the creation of a new food regulation authority in the UK . In fact, several years ago during a meeting with counterterrorism officials from a European partner, when we began talking about agroterrorism and food defense issues, they said they were comfortable with the conversation provided that we did not utter the phrases “Foot and Mouth Disease (FMD)” and “Bioterrorism” in the same sentence, such was the concern about the consequences of even hinting at the possibility of using the disease as a deliberate bioterrorism attack.

U.S. National and International Food Defense Efforts

To begin making the food supply system less attractive to a potential terrorist, the U.S. has begun taking many proactive steps.

Within the U.S., we are taking a multi-pronged approach.

• At the national policy level, Homeland Security Presidential Directive/HSPD 9 established a national policy to defend the agriculture and food system against terrorist attacks, major disasters, and other emergencies. This Presidential Directive gives key federal agencies responsibility for identifying and prioritizing sector-critical infrastructure and key resources for establishing protection requirements; developing awareness and early warning capabilities to recognize threats; mitigating vulnerabilities at critical production and processing nodes; enhancing screening procedures for domestic and imported products; and enhancing response and recovery procedures
• The Public Health Security and Bioterrorism Preparedness and Response Act of 2002 (usually referred to as The Bioterrorism Act) established national provisions to inspect food offered for import at ports of entry into the U.S, with the greatest priority given to inspections to detect the intentional contamination of food. Regulations to enhance Food Defense under the Bioterrorism Act provide for the registration of food facilities, prior notification of imported food shipments, establishment and maintenance of records, and administrative detention of any food for up to 30 days when there is credible evidence that the food poses a serious threat to humans or animals
• Vulnerability assessments, the U.S. Departments of Agriculture, Homeland Security, the Department of Health and Human Services' Food and Drug Administration, and the Federal Bureau of Investigation are working closely together with the private sector to identify the most critical nodes or vulnerabilities along the food supply and production system, using the vulnerability assessment tool, CARVER + Shock. EPA has also used this tool to analyze the drinking water infrastructure in the US. CARVER is an acronym which stands for Criticality, Accessibility, Recuperability, Vulnerability, Effect, and Recognizability -- all attributes used to evaluate the effectiveness of a target for terrorist attack. In addition to CARVER, the tool evaluates a seventh attribute, the combined health, economic, and psychological impacts, or the “Shock” attributes of an attack.
• Surveillance, the U.S. has established individual diagnostic laboratory networks which monitor human, animal, and plant health, as well as the food and water supplies. These individual networks are now working together under the Integrated Consortium of Laboratory Networks, or ICLN and play a significant role in monitoring the food supply as it moves from “farm to fork.” This increasing ability to quickly identify outbreaks of foodborne illness helps ensure that outbreaks or unusual patterns of illness are investigated quickly. As part of this surveillance, the U.S. is increasing national participation in the first Internet-based food safety system: eLEXNET (Electronic Laboratory Exchange Network). This shared electronic data system consolidates and shares microbial food contamination findings among federal, state and local laboratories. Helping ensure increased speed, awareness, and coordination to prevent or respond to deliberate threats to the food supply.
• Working with private industry to reduce threats and contain outbreaks of foodborne illness. In this process, U.S. agencies have issued new industry guidance on security measures, and have encouraged specific additional industry security measures in response to the increased threat level. These guidances help food producers, warehouses, importers, stores, restaurants, and other food establishments minimize the risk that their food will be subject to intentional contamination or tampering.
• Intelligence gathering/Information sharing – The Strategic Partnership Program Agroterrorism (SPPA) initiative is a close collaboration between the partners I just highlighted. One of its goals is to gather information to enhance existing tools that both USG and industry employ as well as provide stakeholders with comprehensive reports including warnings and indicators, key vulnerabilities, and potential mitigation strategies.

In addition to this work within the U.S. , we have also begun raising the issue of Food Defense internationally. In my international travels, I often hear skepticism about U.S. perceptions of the threat of bioterrorism or of the needed actions. The degree to which bioterrorism is seen to be a significant security threat affects our individual and collective willingness to invest resources in biodefense. And the nature of each other's threat assessment will help structure the kinds of programs put in place to defend against bioterrorism.

But, we have found that Food Defense is often the exception to this international skepticism. When raising food defense and agroterrorism issues, officials overseas seem to “get it” and often indicate that they share the same concerns, probably because of the potential widespread consequences to an economy and the supporting infrastructure.

For example, in 2004, the U.S. introduced bioterrorism onto the agenda for the G8 leaders, leading to the G8 leaders' statement that year covering the issue of “Defending Against Bioterrorism.” One component of that work articulated by G8 leaders was to increase protection of the global food supply. In 2005, G8 nations built on this policy foundation and put together some of the first-ever international technical and policy events looking at initial steps in food defense.

Taking this work even further, a t U.S. initiative, the Asia Pacific Economic Cooperation (APEC) forum has enthusiastically embraced the Food Defense issue. This year, for the first time ever, all 21 APEC economies signed onto a U.S.-Australia-Chile co-sponsored Food Defense Initiative to “Mitigate the Terrorist Threat to the APEC Food Supply.” Earlier this month, technical and policy officials from 17 APEC economies, as well as the private sector, met in Bangkok to review food defense vulnerability assessment methodologies. And less than two weeks ago, the APEC leaders statement welcomed new U.S.-led APEC initiatives to protect our food supply systems from deliberate contamination. We view the APEC Food Defense Initiative as extremely promising work, but it is only a first step. We are planning for APEC economies to further share strategies and work next year to develop Food Defense best practices or recommendations for the region.

Challenges to International Food Defense-Related Discussions

We face several key challenges when discussing food defense internationally: looking at increased awareness, and at international collaboration in response to an event (real or a hoax).

Overall, I have found international colleagues, for the most part, to be receptive and enthusiastic to collaborate on food defense. At the same time, even among close allies, I have been surprised by some of the questions and concerns that international colleagues have raised. For example, proposing food defense collaboration can lead to the question “What do you know that I don't?” The U.S. must often explain that, even in the absence of a specific threat to a particular food or area, we believe that putting the time, energy, and resources into food defense represents a prudent contribution to all of our efforts to combat bioterrorism as well as protect against unintentional food contamination, simultaneously helping strengthen overall protections for the global food supply system.

Additionally, sometimes international partners voice concerns (or, more often, hint at concerns) that collaborative work on Food Defense will affect cross-border trade somehow inadvertently creating unexpected trade restrictions or barriers. In these international discussions, it is important to recognize the ways that implementing new or enhanced food defense measures might affect various components of the food industry, especially small and medium enterprises. At the APEC Food Defense workshop in Bangkok earlier this month, for example, some participants representing both the public and private sectors were concerned about ways that possible enhanced regulation and oversight could affect the global trade in food and agriculture. It is clear, though, that some multinational companies as well as the largest exporters are already paying attention to the political landscape in countries to which they are exporting and understanding that Food Defense is a legitimate concern for governments. For example, some representatives from Australia have indicated that they have modified some Australian practices in responses to the U.S. ' 2002 Bioterrorism Act and its food import screening measures. Small and medium enterprises must begin to address these same concerns to remain competitive in the global marketplace.

In the event of a terrorist attack (or even a hoax), the international challenges could be different. As we all know, internal coordination for any government may often be particularly difficult in the midst of a crisis, especially if multiple ministries or sectors are involved as would be the case in the event of an attack on the food supply. Now imagine having to coordinate not one, but multiple countries in response or mitigation. Bans on food imports, and the potentially permanent loss of markets, could be immediate impacts of such a situation. Furthermore, not being able to effectively coordinate a food defense response among multiple nations has the potential to create, in the short term, tension among trade partners, and over the longer term, lasting diplomatic tensions.

Prevention of and response to an international food contamination event in Europe poses challenges different from those in any other region of the world, due to the role of the European Union in cross-border coordination. The EU's role has been rigorously tested by real-life events such as BSE and others as mentioned previously. On some issues, the added layer of coordination and regulation by the EU can save lives and protect economic interests. Perhaps there are lessons for the rest of the world to learn from the EU's ability to coordinate food defense work across borders. It is also possible that there are ways that the EU can leverage its ability to coordinate across nations to be even more effective on food defense issues.

One final challenge to stimulating and continuing this international dialogue is that of competing priorities. Food Defense, prudent as it may be, is simply not high on the agenda for some nations. For some countries, food safety issues are perceived as a more significant concern enough that it makes it difficult to get some countries to look beyond food safety concerns to protecting the food supply from deliberate contamination. Identifying the synergies, then, between food defense and food safety are critical to helping nations identify ways in which the needs may not be competing but may instead be interdependent -- helping strengthen mechanisms for both national protection and international cooperation.

Key Recommendations

There are a number of ways that nations and the international community can work together to address the challenges of food defense and international cooperation:

• Strengthen public-private partnerships to address food defense. Much of the expertise and relevant infrastructure for food defense is in the private sector. Thus, their buy-in, leadership, and partnership are key to hardening the soft targets. In the context of the recent APEC Food Defense workshop in Bangkok , for example, the participation of the private sector was vital to the meeting's success -- illuminating some of the ways in which governments and private industry are interdependent, and that it is in their mutual interest to develop cooperative strategies to protect the food supply.
• Multi-sectoral engagement is essential. Many government agencies, many different disciplines, many parts of society all play critical roles in defending against the terrorist threat to the food supply. Food defense efforts in the U.S. include coordination and collaboration among Agriculture, Health, Homeland Security, Intelligence, Environment, and Law Enforcement -- and also include substantial involvement by the private sector. In addition to working with national entities within the U.S. , systems must also ensure that local authorities such as law enforcement or public health are equally involved.
• “Translate” this multi-sectoral engagement into cross-border cooperation. In the event of an attack on the food supply requiring an international response, it will be imperative that all sides -- and all nations involved -- are equally coordinating their efforts. In order to improve multi-sectoral interoperability, we need to be working now to develop, promote, and conduct regular transnational, multi-sectoral training courses and exercises on preventing, preparing for, containing, and responding to attacks on the food supply. Due to the existence of the EU, in some respects Europe is ahead of the world on this issue.
• Communication is key. There are two parts to this recommendation. The first is the need for creating and enhancing effective risk communication to the general public (consumers), both domestically and internationally. Without such communication, governments and private industry will have great difficulty mitigating the impact of a deliberate attack on the food supply. People need to make sense of random and terrifying events, but attacks on food may elude quick and easy explanation – presenting an unprecedented challenge for policymakers both nationally and internationally. Frank, open, and transparent dialogue between nations will also be critical addressing any potential impact on trade, as well as handling the crisis as it unfolds. 
• Information sharing particularly when a nation suspects a potential threat to the food supply and distribution system. Thus, we need to be working now to strengthen national and international abilities to identify and quickly detect unusual disturbances in the farm to fork continuum which could indicate a bioterrorist attack and the ability to rapidly share that information with appropriate national and international policymakers.

Fortunately, if I may use an agricultural metaphor, we are starting to see international food defense cooperation efforts bear fruit. Thanks to food defense initiatives like those within the G8 and APEC, nations are talking to each other in a productive manner about protecting the food supply from deliberate contamination -- and are working to identify ways to collaborate. As governments, we are also starting to see the private sector -- at least the very largest multi-national firms -- begin to incorporate food defense practices around the globe.

Finally, I'd like to leave you with three sets of questions for your consideration in this morning's discussion.

• First, what are ways to help motivate and develop international collaboration on food defense issues? Where are the natural synergies between nations? What are the obstacles to enhanced global cooperation, and what should we collectively be doing to address those obstacles? Can the EU serve as a leader and a model in these efforts?
• Second, what are the best ways to involve the private sector in the ongoing discussion? Are there effective strategies to “incentivize” voluntary adoption of food defense practices? What are some of the lessons we may learn from similar endeavors in the past, from other security practices, or from collaboration with other industries?
• And, finally, what are the implications of food defense strategies for international trade? There are clear linkages -- and potential impacts. How do we best ensure that enhanced food defense does not interfere with continued and growing global commerce? What are the ways to make these efforts complementary and not conflicting?

Thank you again for this opportunity to talk about our vision for international cooperation on food defense -- and I look forward to this morning's discussion.