Enhancing Food-System Resilience and Ensuring Consumer Confidence in the Aftermath of a Food-Supply Catastrophe

Posted: December 20, 2017 at 9:29 am

Print Friendly, PDF & Email
D.A. Unruh, S.E. Gragg, A.L. Nutsch, J.M. Ackleson and J.J. Kastner
Kansas State University

Introduction

If true security is achieved through “the reduction of terrorism and the ability to pursue and maintain social practices and opportunities that Americans hold dear,” then the raising, growing, production, distribution, and consumption of food must be protected.[1] American agriculture and the food system together form an essential pillar of the American way of life, and U.S. homeland security policy affirms this essentialism by the designation of food and agriculture (FA) as a critical infrastructure sector (akin to CIKR, or Critical Infrastructure and Key Resources) under Presidential Policy Directive 21 (PPD 21).[2] [3] Through public-private partnerships, multiple regulation- and policy-coordinating bodies, and an overall Department of Homeland Security (DHS) Sector-Specific Plan (SSP), the U.S. federal government seeks to ensure the security and resilience of FA.[4] Under PPD 21, the Department of Agriculture and Department of Health and Human Services are the sector specific agencies for the Food and Agriculture Sector.  As per PPD 21, they have unique roles and responsibilities, vis-à-vis DHS in ensuring critical infrastructure protection.  Furthermore, in July 2017 President Donald Trump signed an amendment to the 2002 Homeland Security Act that focuses on coordinating DHS efforts to protect food and agriculture through oversight and integration of programs and preparedness measures.[5] [6] Scholars of homeland security ought to address whether this approach is sufficient and, speculating on the future, ask what would happen if the safety, security, and operation of the FA was challenged.

This paper explores these questions in terms of the resilience of FA.  The authors—a multidisciplinary group of biological- and social-science scholars who teach, conduct research, and publish on multiple topics related to the safety and security of the global food system—assess how FA would handle a food catastrophe.  The demands of such an event on FA’s resilience is contemplated based on historical examples and current systems.  If FA—or any critical infrastructure sector—can increase its resiliency, it is more likely “to withstand adversity and to recover more quickly” if there was a major catastrophe.[7] Cutter et al. (2010) state that resilience involves “social, economic, institutional, infrastructural, ecological, and community elements.”[8] While all of these elements are important, this paper will focus on institutions and infrastructure, concluding with a commentary on which institutions and actors are in the best position to exercise leadership for ensuring food-system resilience.

Challenges to FA Resilience

Food catastrophes[9] can be intentional or unintentional.[10] While homeland security experts must focus on an intentional attack, both intentional and/or unintentional acts can test the sector’s resiliency; historical examples of both kinds of acts offer insights for a resiliency assessment.

Intentional food catastrophes are usually terroristic or economic in nature.[11] [12] By its very nature, the food system, with its scope, size, and importance to daily life, is an enticing target for a terrorist attack. Some have argued that FA is at risk because American agriculture is both widespread (e.g., large fields with lax security) and concentrated (e.g., cattle feeding operations contain many animals in a small area), susceptible to various threat agents (e.g., microorganisms and toxins that are harmful to plants, animals, and/or humans), and incredibly important to several supply chains.[13] [14] Yet, an intentional attack has yet to occur. Major outbreaks have been the result of lapses in hazard control programs or simply the result of living in a microbial world.[15] Thus, the risk exists, and given the landscape of risk (be it resulting from a bad actor or poor practices) mandates the need for resilience. It is precisely risk (i.e., intentional contamination of the food supply for the express purpose of causing significant public health impact and harm) that the FSMA Final Rule for Mitigation Strategies to Protect Food Against Intentional Adulteration is intended to address. Given the pioneering nature of the provisions of this rule, the development and implementation of food defense planning efforts has and will continue to be an evolving focus for the food industry and regulators alike.

Intentional adulteration of food by a terrorist is not the only threat facing the United States. Economically motivated adulteration (EMA) occurs when inferior ingredients are used to deceive regulators or the public by using a similar, cheaper alternative.[16] A relatively recent example of EMA is the use of melamine in pet food and infant formula in China.[17] [18] [19] The melamine scandal highlighted both the impact of poor resilience in the absence of traceability and the ramifications of a highly segmented supply chain. This paper further explores such challenges related to traceability gaps and segmented supply chains.

The intentional adulteration of food—whether terrorism-related or economically motivated—can have widespread impacts. Since such events are rare, examination of unintentional adulteration is needed to empirically gauge FA resilience. One concern in an intentional contamination is the use of a “new” agent previously unseen, and the 2011 Escherichia coli O104:H4 outbreak in sprouts demonstrates such an event. This particular E. coli strain acquired new genes that made its initial microbiological classification difficult (i.e., it had never caused illness in animals prior, and the unseen genes muddied epidemiological investigations) and afforded the microbe the capability to cause severe sequelae.[20] The intentional introduction of a genetically modified or novel microbe could cause similar confusion and response delays.

Another area-of-concern regarding an intentional contamination event is the likelihood that other industries will be economically affected. Public health scientists have seen this through past cases of unintentional contamination. During a major outbreak of Salmonella Saintpaul in May 2008 in the United States, the Centers for Disease Control and Prevention (CDC) initially implicated red plum, Roma, and red round tomatoes. As time progressed, more cases were reported and further scientific analysis was conducted, prompting the CDC to include cilantro and fresh hot chili peppers (such as jalapeños) in the outbreak. By July 2008, tomatoes had been cleared as the contamination vehicle, but the damage to several food brands had already been done—the tomato industry suffered an estimated $250 million in losses as a result of the outbreak. “Finger-pointing” in a food safety outbreak can quickly implicate—and impact—an otherwise not-guilty commodity.[21] The 2011 Listeria monocytogenes outbreak in cantaloupe that damaged other melon industries is another example of the “finger-pointing” externality. While all Listeria cases were traced back to a cantaloupe farm in Colorado, the national watermelon, honeydew, and cantaloupe industries were all affected. The economic and social effects—workers laid off, brand images damaged, profits lost—must be considered when assessing FA resilience to a major food catastrophe.[22]

The Current Resilience of the FA Sector

A FA catastrophe is indeed possible. During Operation Enduring Freedom, documents were recovered from an al-Qaeda hideout that discussed bioweaponization schemes and listed potential biowarfare agents.[23] In 2004, former Secretary of Health and Human Services Tommy Thompson remarked, “For the life of me, I cannot understand why the terrorists, have not … attacked our food supply, because it is so easy to do.”[24] Furthermore, a RAND Company analysis regarding a biological attack on the food supply stated that “the United States, more by luck than by design, has not experienced the type of … food-related disasters to which other countries … have been subjected in recent years.”[25]

FA is vulnerable to an attack for many reasons: the industry is comprised of “concentrated and intensive” practices that are then conveyed through a “highly dispersed” system with surveillance and response capabilities that are lacking at-best.[26] Modern food supply chains are complex, and sudden disruptions can have reverberations down the supply chain and potentially cause “widespread economic, political, and social disruptions.”[27] Furthermore, food companies are becoming more reliant on information-technology (IT) systems, and computers can be hacked (as seen in a recent, major computer glitch that impacted Starbucks).[28]  Indeed, IT-based industrial control systems (routinely used for product formulation in food processing plants) feature potential cyber-vulnerabilities.

Oversight of the food system, particularly food safety oversight, is reasonably fragmented in the United States. A recent report from the Government Accountability Office (GAO) laments that the fact that 16 federal agencies oversee 30 federal laws ultimately leads to “inconsistent oversight, ineffective coordination, and inefficient use of resources.”[29] This fragmentation may make U.S. FA vulnerable to an intentional contamination event, or less resilient, or both.

An intentional contamination event would likely be chemical or microbial in nature.[30] Introducing a pathogen into the supply chain requires compatibility between the microbe and the food product in which stability of both is maintained and organoleptic changes in the food do not occur.[31] Microorganisms (and associated toxins) listed as “Select Agents”[32] that are uncommonly associated with foods are of greatest concern.[33] An examination of food safety plans (known in the industry as Hazard Analysis and Critical Control Points, or HACCP, plans) may illuminate vulnerabilities in the system. HACCP should control for unintended catastrophes. However, for intentional contamination, HACCP systems in place could be bypassed.[34] Conducting a hazard analysis is a critical step in HACCP plan development that aims to identify significant hazards, which are hazards that are both likely to occur and cause consumers harm that must be addressed in the HACCP plan in order to produce a safe food product.[35] HACCP may be used as a tool to address both intentional and unintentional contamination of food; however, including intentional contamination is not a requirement of the HACCP process. While intentional contamination may be deterred or detected by the numerous precautions that are taken to assure food safety, it is also important to specifically consider who the perpetrator might be in an intentional contamination event, what their motivation might be, as well as the impact of such an attack in order to more effectively use HACCP to address intentional contamination scenarios.[36]

While Select Agents could cause large-scale loss of life, the financial impact of a large outbreak, be it caused by a Select Agent or not, can be similarly enormous: “The fiscal downstream effect of a major act of sabotage against the food industry would [could] be multidimensional, reverberating through other sectors of the U.S. economy and ultimately impacting directly on the American consumer.”[37] Indeed, terrorists are likely to target a food product with “lingering potential impact on consumer confidence and the economy.”[38]

In the event of an intentional food catastrophe, the first task for U.S. leadership would be to deploy public health resources and agencies, including leadership from DHS, HHS (particularly the Food and Drug Administration [FDA]),[39] USDA (particularly the Food Safety and Inspection Service, and the Animal and Plant Health Inspection Service), the CDC, and others.[40]  Other key regulatory actors, such as state and local departments of health, would be involved, too.  Assuming an event of international (and trade-related) scope, such multilateral bodies as the World Trade Organization (based in Geneva, Switzerland) and the food safety standard-setting Codex Alimentarius Commission (based in Rome, Italy) would have an indirect, but neither direct nor immediate, role to play; instead, the nation-state governments of involved trading partners would be most involved, and cross-border cooperation (e.g., between U.S. agencies and their counterparts in other countries) would be an important part of resilience.  Following the realization of the catastrophe, a product recall would be both necessary and complex. The stress placed on U.S. food transport networks in such a scenario could hinder the speed of recalls, and the already-difficult task of locating specific products along complex global supply chains could be made harder by rising political instability elsewhere in the system. These “positive feedback” effects could serve to add complexity and cost to a product recall.”[41]

Next, assuaging public concern and demonstrating that the U.S. is “in control” would be important. In fact, resilience must be assured, because a major outbreak could damage the trust of the government and foment social instability. Attacks could “elicit fear and anxiety.”[42] An attack on livestock used for human food is concerning, too. Public angst would increase as “[g]raphic images of diseased cows and sheep would likely appear in the media, serving to demonstrate the extreme susceptibility of animals to disease and the vulnerability of all animal life, including humans, to deadly pathogens.”[43]

Moving Forward: Who is in the Best Position to Exercise Leadership in FA Resilience?

Who, or what institution, is in the best position to lead in a time of crisis? The crisis, first and foremost, will be a time of tremendous public anxiety.  Resilience, one might argue, would involve institutional leaders responding in the midst of such anxiety.  The late scholar Edwin H. Friedman states that there are five aspects of anxiety in society, the most critical aspect being a lack of what he terms well-differentiated leadership.[44] Well-differentiated leadership is true (effective) leadership, and it involves what Friedman terms “self-regulation,” “adaptation to strength,” “response to challenge,” and the “capability to allow time for processes to occur.”[45]  In the case of a food catastrophe of international origin, the stakeholders themselves (particularly private actors) are in the best position to exercise well-differentiated leadership.  Food corporations, including transnational firms, connected with an intentional catastrophe must deploy resources to address the problem, and the work of public-private partnerships must flourish.  The interplay between DHS, USDA, and HHS is critical to improve and exercise resilience in light of an event.

Shocks to FA can last for many years.[46] To bolster resilience, regulators must first understand the risk. They must learn to model and quantify the impact of a catastrophe on the implicated food market and the subsequent ripples in related industries.[47] Of course, this raises the problem of forecasting the catastrophe—one cannot know which industry it will be nor the magnitude of a future event. The science (and maybe better put, the “art”) of seeking out unknown unknowns to better characterize risk should be developed.

Scholars must “explore opportunities for coordinated risk management” in which “governments, international institutions, and businesses develop contingency plans and establish early warning systems.”[48] Multilateral organizations such as the Codex Alimentarius Commission could contribute by developing methodologies to do this. Resilience includes “good PR”: The Chilean grape scare is an example of “how poor risk and crisis communication can cause far more damage to the economy than any actual terrorist incident.”[49]

Finally, the U.S. must “invest in strategic storage.”[50] This includes storage not only of medical stockpiles (for both humans and livestock) but also stockpiles of food and seeds (in the case of a major plant pathogen). Regardless of the food product implicated or the agent used, public-private partnerships must exercise strong leadership to foster resiliency. Supremely, while DHS must play a coordinating role, it will be private firms  that are in the best position to exercise leadership.  Nevertheless, such sub-agency units as the DHS Office of the Inspector General (OIG), must be involved.  As documented in a 2007 report, the DHS OIG is federally mandated to audit and monitor the effectiveness and efficiency of DHS and its work; we posit that future auditing and monitoring by the OIG should explicitly involve an examination of public-private partnership effectiveness.  While progress was made early on to both establish a Food Information Sharing and Analysis Center (ISAC) and engage with logical industry partners (e.g., the Food Marketing Institute),[51] further work needs to be done to ensure that all private stakeholders are indeed engaged in an overall food-system resilience strategy.

Conclusion

While policy efforts must continue in Washington, it will take public-private partnerships and innovation in food safety systems to ensure the safety of the American food supply from coast to coast and border to border. As one industry leader aptly stated, “[t]here can’t be national security without a secure food supply.”[52] Unfortunately, that national security faces challenges that are ever-present. While this paper aims to explore both the threat of a food system catastrophe and the resiliency of the system, it is important to realize that, as authors Gary LaFree and Martha Crenshaw state, there is no simple solution to terrorism.[53] Namely, counterterrorism efforts “must succeed all the time, the terrorist only once.”[54]  But the authors of this paper are hopeful; it is indeed possible for America to enhance its food-system resilience through the actions of well-differentiated leading institutions and robust public-private partnerships.


References

[1] Annette D. Beresford, “Homeland Security as an American Ideology: Implications for U.S. Policy and Action,” Journal of Homeland Security and Emergency Management 1, no. 3 (2004), p. 16.

[2] Department of Homeland Security, “Food and Agriculture Sector-Specific Plan,” (Washington, D.C.: Dept. of Homeland Security, 2015).

[3] Barack Obama, “Presidential Policy Directive/PPD-21 — Critical Infrastructure Security and Resilience,” ed. Office of the Press Secretary (Washington, D.C.: The White House, 2015).

[4] Department of Homeland Security, “Food and Agriculture Sector-Specific Plan.”

[5] Food Safety News Desk, “President Trump Likely to Sign Popular Agro-Terrorism Bill,” Food Safety News, http://www.foodsafetynews.com/2017/06/president-trump-likely-to-sign-popular-agro-terrorism-bill/.

[6] 115th Congress of the United States, “Security Our Agriculture and Food Act,” in H.R. 1238 (Washington, D.C.: U.S. Government Publishing Office, 2017).

[7] Susan L. Cutter, Christopher G. Burton, and Christopher T. Emrich, “Disaster Resilience Indicators for Benchmarking Baseline Conditions,” Journal of Homeland Security and Emergency Management 7, no. 1 (2010), p. 1.

[8] Ibid., p. 6.

[9] From this point forward, we refer to “catastrophe” as being a major food contamination event, likely from microbial or chemical sources.

[10] Shaun P. Kennedy and Frank P. Busta, “Biosecurity: Food Protection and Defense,” in Food Microbiology: Fundamentals and Frontiers, ed. M.P. Doyle and L.R. Beuchat (Washington, D.C.: ASM Press, 2007).

[11] Jerry Jaax, “The Bio/Agro Terrorist Threat,” in A Multidisciplinary View of Food Safety and Security (Manhattan, KS: Kansas State University, 2004).

[12] Food terrorism is “an act or threat of deliberate contamination of food for human consumption with chemical, biological or radionuclear agents for the purpose of causing injury or death to civilian populations and/or disrupting social, economic or political stability.” (see: World Heath Organization, “Terrorist Threats to Food: Guidance for Establishing and Strengthening Prevention and Response Systems,” in Food Safety Issues (Geneva, Switzerland: WHO, 2008).)

[13] Peter Chalk, “Hitting America’s Soft Underbelly: The Potential Threat of Deliberate Biological Attacks against the U.S. Agricultural and Food Industry,” (Arlington, VA: RAND Corporation, 2004).

[14] Trevor Maynard, “Food System Shock,” in Emerging Risk Report – 2015 Innovation Series (London, UK: Lloyd’s of London, 2015).

[15] Kennedy and Busta, “Biosecurity: Food Protection and Defense.” Note: Hazard control typically occurs under the guidance of a HACCP program, which stands for Hazard Analysis Critical Control Points, a preventative approach to eliminate chemical, biological, and physical hazards in food production.

[16] Mark C. Sanchez, “Adulteration,” in Food Law and Regulation for Non-Lawyers: A U.S. Perspective, ed. Mark C. Sanchez (Switzerland: Springer International Publishing, 2015). In fact, economic adulteration came to be following the allegations made in Upton Sinclair’s The Jungle (1904-1906).

[17] Melamine behaves similar to protein in certain analytical tests. Thus, by supplementing a product with melamine, a producer can increase the perceived protein content without actually increasing protein.

[18] Nearly 60 million packages of pet food exported to the U.S. were recalled after 14,000 pets were sickened (see: David Barboza and Alexi Barrionuevo, “Filler in Animal Feed Is Open Secret in China,” The New York Times, April 30, 2007.)

[19] The use of melamine in infant formula resulted in the death of six infants and sickened 294,000.T. Alcorn and Y. Ouyang, “China’s Invisible Burden of Foodborne Illness,” Lancet 379 (2012).

[20] Alexander Mellmann et al., “Prospective Genomic Characterization of the German Enterohemorrhagic Escherichia coli O104:H4 Outbreak by Rapid Next Generation Sequencing Technology,” PLoS ONE 6, no. 7 (2011). This severe sequelae included 830 cases of hemolytic uremic syndrome (HUS) and 46 deaths.

[21] Kathryn Krusemark and Cobus Block, “Historical and Contemporary Cases Illustrating the Vulnerability of Specific Commodities and Sectors,” in Food and Agricultural Security: An Historical, Multidisciplinary Approach, ed. Justin Kastner (Santa Barbara, CA: ABC-CLIO, 2011).

[22] Sanchez, “Introduction to Statutory Framework and Case Law.”

[23] Jaax, “The Bio/Agro Terrorist Threat.”

[24] FoxNews.com, “Attacking the U.S. Food Supply,” December 9, 2004, http://www.foxnews.com/story/2004/12/09/attacking-us-food-supply/.

[25] Chalk, “Hitting America’s Soft Underbelly: The Potential Threat of Deliberate Biological Attacks against the U.S. Agricultural and Food Industry.”, p. xii. Those countries are the UK, Malaysia, and Taiwan.

[26] Ibid.

[27] Maynard, “Food System Shock.”, p. 2.

[28] Anonymous, “Starbucks Computer System Crashes,” CBS Chicago, May 16, 2017, http://chicago.cbslocal.com/2017/05/16/starbucks-computer-system-crashes-computer-hack/.

[29] United States Government Accountability Office, “Food Safety: A National Strategy Is Needed to Address Fragmentation in Federal Oversight,” (Washington, D.C.: GAO-17-74, 2017).

[30] For microbial-based contaminations, the reasons for this are ease of growth and reproduction—a single colony can be replicated in a basic laboratory setting many times over (the use of Salmonella in the The Dalles, Oregon, in 1984 shows such precedence). For chemical-based contaminations, the melamine scandal in China demonstrates precedence.

[31] Kennedy and Busta, “Biosecurity: Food Protection and Defense.”

[32] Select-agent status is determined by CDC and includes a wide variety of pathogens and associated toxins, including botulinum neurotoxins, hemorrhagic viruses, ricin, and pathogens that are highly damaging to plants and livestock. (see: 7 CFR Part 331, 9  CFR Part 121, and 42 CFR Part 73).

[33] Kennedy and Busta, “Biosecurity: Food Protection and Defense.”

[34] Ibid. This “by-passing” could include the use of microorganisms not accounted for in the hazard analysis or having an insider disable certain hazard-controlling production processes.

[35] Carol A. Wallace, William H. Sperber, and Sara E. Mortimore, “Developing a HACCP Plan,” in Food Safety for the 21st Century (Chichester, West Sussex, United Kingdom: Wiley-Blackwell, 2011).

[36] Louise Manning and Jan Mei Soon, “Food Safety, Food Fraud, and Food Defense: A Fast Evolving Literature,” Journal of Food Science 81, no. 4 (2016).

[37] Chalk, “Hitting America’s Soft Underbelly: The Potential Threat of Deliberate Biological Attacks against the U.S. Agricultural and Food Industry.”, p. 5.

[38] Kennedy and Busta, “Biosecurity: Food Protection and Defense”, p. 92.

[39] In fact, the FDA has recently issued the Mitigation Strategies to Protect Food Against Intentional Adulteration Final Rule, which will be discussed in this paper’s presentation.

[40] DHS: Department of Homeland Security; HHS: Health and Human Services; USDA: United States Department of Agriculture; FSIS: Food Safety and Inspection Service; APHIS: Animal and Plant Health Inspection Service; CDC: Centers for Disease Control and Prevention.

[41] Maynard, “Food System Shock.”

[42] Chalk, “Hitting America’s Soft Underbelly: The Potential Threat of Deliberate Biological Attacks against the U.S. Agricultural and Food Industry”, p. 25.

[43] Ibid., p. 22.

[44] Edwin H. Friedman, A Failure of Nerve: Leadership in the Age of the Quick Fix (New York: Seabury Books, 2007).The other four are reactivity, herding, blaming, and a quick-fix mentality.

[45] Ibid., p. 24.

[46] Maynard, “Food System Shock.”

[47] Rob Bailey et al., “Extreme Weather and Resilience of the Global Food System,” in Final Project Report from the UK-US Taskforce on Extreme Weather and Global Food System Resilience, ed. The Global Food Security Programme (UK2015).

[48] Ibid., p.2.

[49] G.R. Dalziel, “Food Defence Incidents 1950-2008: A Chronology and Analysis of Incidents Involving the Malicious Contamination of the Food Supply Chain,” (Centre of Excellence for National Security (CENS): S. Rajaratnam School of Interational Studies at Nanyang Technological University 2009), p. 12. Briefly, someone called the U.S. embassy in Santiago claiming grapes destined for export were poisoned with cyanide. Only trace amounts were found.

[50] Bailey et al., “Extreme Weather and Resilience of the Global Food System.”, p. 11.

[51] Department of Homeland Security Office of the Inspector General, The Department of Homeland Security’s Role in Food Defense and Critical Infrastructure Protection (Washington, D.C.: U.S. Department of Homeland Security, 2007), p. 31.

[52] Curtis Meier, “Opinon: We Must Do More to Protect Our Farms from Terror Threats,” The Des Moines Register 2017.

[53] Anonymous, “No Simple Solutions for Counterterrorism: Lafree and Crenshaw Book Talk Feb. 23,” START http://www.start.umd.edu/news/no-simple-solutions-counterterrorism.

[54] Ibid.

Write to the Editors at ciprpt@gmu.edu