An overlooked food safety topic in Africa

TRENDS IN MANAGEMENT OF FOOD SAFETY, QUALITY & COMPLIANCE IN FOOD & AGRICULTURE

By Catherine Odhiambo

Terrorism!!! Does the term ring a bell…maybe or maybe not. Perhaps the first thought that comes to mind is ‘Al-Shabaab’, a Somaliabased terrorist jihadist militant group active in East Africa. However, did you know that even food is subject to terrorist attack? Instead of bullets, grenades, and bombs, viruses, bacteria, yeasts, parasites, or chemical substances of microbial origin are used in food to cause illness or death to civilian populations and/or disrupt social, economic or political stability. This is what is referred to as ‘Bioterrorism’.

The World Health Organization (WHO) considers the malicious contamination of food for terrorist purposes as a real and current threat. Africa is particularly vulnerable to bioterrorism due to its fragile health systems that are, in all honesty, not adequately equipped to handle such a public health crisis if it ever occurred. Deterrence therefore becomes our first and maybe only line of defense.

In this article, we discuss bioterrorism as an existential threat to food systems and how effective food defence plans can help food manufacturers address food system vulnerabilities (physical, personnel and operational security) to prevent deliberate attacks on food by malicious, criminal or terrorist threats or activities.

Many toxins affect the nervous systems of mammals by interfering with the transmission of nerve impulses. Others are responsible for blocking the main cellular metabolism, causing cellular death. They are known to cause more than 200 diseases—ranging from diarrhea to cancers. Typical symptoms of food poisoning are abdominal cramps, nausea, vomiting, upset stomach, diarrhea, fever, dehydration, and others. Most isolated bacterial agents responsible for foodborne infections include bacteria from genera such as Salmonella, Shigella, Bacillus, Clostridium, Listeria, Campylobacter, Escherichia, Staphylococcus, Vibrio, Enterobacter, and Yersinia. These pathogens can sometimes be made more potent by increasing their ability to cause disease, spread, or resist medical treatment. The Centers for Disease Control (CDC) classifies biological agents used as biological weapons in bioterrorist activities into three categories. Category A contains factors characterized by high pathogenicity and mortality, as well as ease of dissemination. Category B pathogens are moderately easy to spread, with low morbidity and mortality rates, but require specific monitoring and improvement of diagnostic capabilities. Category C includes emerging pathogens that could be easily engineered as bioweapons.

Though lethal when effectively deployed, many biological toxins can be easily obtained. Simple bacterial culturing systems and extraction equipment dedicated to plant toxins are cheaply available and can even be constructed at home. This makes their potential for use by terrorists a major cause of worry by many world leaders. Africa, with its fragile health systems, porous borders and frequent migration is the perfect ground zero for the emergence of such public health threats.

Terrorists can attack food supply at several stages along the food chain. They can target livestock and crops during production, harvesting, storage or transport, what is christened ‘agricultural bioterrorism or agroterrorism’. Every major state biological warfare (BW) program we know of has included an anti-agricultural component, from the World War I German use of anthrax and glanders against animals to the Iraqi program on wheat cover smut.

They can also target processed foods during the processing, manufacturing, storage, transport, distribution or service of such foods. Depending on the type of contaminated food and the biological agent, an outbreak could be slow, diffuse and initially unremarkable, or it could result in an explosive epidemic.

In 1984, the USA witnessed the biggest bioterrorist attack with a foodborne pathogen—Salmonella typhimurium— which was used to contaminate salad bars in restaurants in Oregon. Members of the religious commune “Bhagawan Shree Rajneesh” tried to sabotage the local elections and succeeded in infecting 751 persons. In 1996, 12 laboratory staff members in a large laboratory in the USA suffered from gastroenteritis as a result of intentionally contaminated muffins and doughnuts. The investigations revealed Shigella dysenteriae type 2, identical to the laboratory’s stock strain, as the causative agent of the outbreak. Nonetheless, the origin and the purpose of this attack is still a mystery to date.

The African continent is situated within a precarious nexus of conflict, terrorism and disease, yet bioterrorism, as a dangerous combination of the latter two, is a topic that is significantly under-researched in the African context, placing the continent in a vulnerable position for the decade moving forward. As such food processors need to be vigilant against

such threats. While food safety management systems, typically based on the Hazard Analysis and Critical Control Points (HACCP) principles, shield a food business from inadvertent contamination and allows a food business to identify what

could go wrong, the HACCP system is not designed to protect from deliberate attacks from within a food business. To adequately address bioterrorism risks, food defence plans have been developed and are now a requirement by many third-party food safety management systems. Plans for food defence focus on facility, operational, cyber and personnel security, with the goal of preventing deliberate attacks on the food supply chain by malicious, criminal or terrorist threats and activities.

Perpetrators of intentional food adulteration often have different motivations for doing so. It could be due to the desire to harm, or kill, as many people as possible (terrorism); be economic; be issue orientated, where an individual or group is trying to damage a brand, company or specific industry, or extortion, where criminals attempt to gain money.

As earlier discussed, terrorism against the food system occurs to cause fear, public health harm, or social and economic disruption. Sabotage can present itself in the form of resentful employees, consumers, or competitors who are out to harm a company’s reputation through recalls when they carry out intentional adulteration. Employees represent intelligent adversaries with special access to and knowledge of your food production process and food defence program. This familiarity with your facility, procedures, security, and preventive control measures makes them of heightened concern. Consumers and extreme activists often carry out or threaten attacks on the food system to highlight a cause, such as using products thought to cause environmental harm. On the other hand, Economically Motivated Adulteration (EMA) most commonly known as food fraud involves the intention to make money fraudulently, evade regulation, or gain an unfair economic advantage. This can be achieved by substituting expensive ingredients with cheaper ones to increase profit, adding unapproved ingredients to increase taste or volume, or mislabeling ingredients to avoid tariffs.

Motivation often determines the adulterant and tactics that a perpetrator chooses to use. In addition to the threat itself, a manufacturer must understand these potential drives for adulteration to help address vulnerabilities in their process and keep the food system secure.

A food defense plan is a set of written documents that is based upon food defence principles and incorporates a vulnerability assessment, includes mitigation strategies, and delineates food defence monitoring, corrective action, and verification procedures to be followed. It is essential for a manufacturer to significantly minimize or prevent significant vulnerabilities related to intentional adulteration of food.

A food defence plan can be created by adapting the USDA’s Food Safety and Inspection Service (FSIS) four conditions on food defence plans to the unique needs of your business. These are the four steps to creating your own food defense plan:

The planning step involves coming up with a team that will create a food defence plan based on assessments of vulnerable critical control points in food production and handling and this is where terms like TACCP and VACCP come in. Threat Assessment and Critical Control Points (TACCP) and Vulnerability Assessment and Critical Control Points (VACCP) are relatively new programs based on the more familiar HACCP program, but they address threats and vulnerabilities instead of hazards.

TACCP focuses on tampering, intentional adulteration of food, and food defence. It generally requires a wider range of employee involvement than HACCP, as it covers issues

Outside Security Potential tampering of incoming shipments

Inside Security Suspicious packages and unexpected inventory changes

Personnel Security Lack of awareness to security measures

Incident Response Security Product spoilage due to equipment failure Careful examination of incoming raw materials (e.g. incoming inspection) Establish SOP for reporting to appropriate personnel Periodic food defence training

Upgrade food defence system with preventive alerts (e.g. temperature and humidity sensors by SafetyCulture)

such as manufacturing plant and transportation security, IT security, and employee background checks. Some points such as tamper-proof seals and various quality control checks will overlap with HACCP. Meanwhile VACCP focuses on food fraud as well but widens the scope to include systematic prevention of any potential adulteration of food, whether intentional or not, by identifying the vulnerable points in a supply chain. It is especially concerned with economically motivated adulteration (EMA). Examples include product substitutions, unapproved product enhancements, counterfeiting, stolen goods and others.

Similar to HACCP, both programs require a control plan that covers mitigation strategies and correction procedures. They may require audits of the entire supply chain, assessments of various suppliers and extensive quality control checks of ingredients.

There are also tools available that can help build a customized food defence plan. The Food and Drug Administration (FDA) has created a user-friendly desktop tool known as ‘The Food Defence Plan Builder (FDPB) version 2.0’. It is designed to help owners and operators of a food facility in the development of a food defence plan that is specific to their facility, and may assist them with meeting the requirements of the Mitigation Strategies to Prevent Food Against Intentional Adulteration regulation. This tool harnesses existing FDA tools, guidance, and resources for food defence into one single application.

Once done with the planning stage, it is critical to engage the employees and get their buy-in when implementing a food defence plan. Conducting employee training and meeting with stakeholders is key in getting everyone proactively involved in promoting the safety of food products.

Thereafter, internal audits need to be carried out to catch gaps or non-conformance with the implementation of a food defence plan. The USDA and the FDA have both developed food defence self-assessment tools. The documents are excellent resources that any processor, large or small, may use to evaluate its commitment to food defence. Ideally, the assessment should be done by the in-house person assigned to manage the food defence program. The person conducting the assessment should have received prior training on food defence.

Since change is inevitable, FSIS recommends a yearly review of the food defence plan while other organizations like the FDA recommend every three years or sooner if there are changes in operations. Based on audit reports, industry best practices, the latest regulations on food safety, and new hazards, determine if the food defence plan needs to be updated or improved to keep up with new and changing threats to food defence. FSA

All food processors should understand that building a well-documented food safety management program will help ensure a good start on building a food defence system. As they say, prevention is better than cure.

Bacillus anthracis Anthrax

Clostridium botulinum Botulism

Yersinia pestis Plaque

Brucella spp

Enterobacteria Brucellosis

(Salmonella spp, Shigella spp., Escherichia coli O157:H7) Salmonellosis, dysentery, other gastrointestinal diseases

Staphylococcus aureu Food intoxication

Clostridium perfringen Food intoxication, gas gangrene