Industrial Security Risk: Food and Agriculture Defense

ABS Group Safety, Risk and Compliance Services

Food and Agriculture is one of the 16 critical infrastructure sectors designated and protected by the United States Department of Homeland Security (DHS) Presidential Policy Directive 21 (PPD-21). With assets, systems and networks that form one of our most critical infrastructures, this sector is so vital to our society's well-being and security that its incapacitation or destruction could have catastrophic consequences, not only for national public health and safety but also for our economic security.

Food Safety vs. Food Defense

Food defense involves protecting food products from intentional contamination or adulteration intended to cause public health harm or economic disruption. Food safety considers only the accidental, as compared to intentional, adulteration of the food supply. Food defense is more complicated because it implies that an adversary is knowledgeable in the process and methods of protection. This knowledge is of concern because it presumes that an intelligent adversary wants to circumvent your food safety measures to cause harm.

Another very important distinction between food safety events and food defense is that in the case of a food defense event, a crime or act of terrorism may have occurred. In an intentional adulteration event, a criminal investigation would need to be conducted to determine the appropriate course of action to follow.

In May 2016, the Food and Drug Administration issued the final rule on "Mitigation Strategies to Protect Food against Intentional Adulteration," which will take effect in 2019. The Intentional Adulteration portion of the regulation was designated in the U.S. Code of Federal Regulations as Title 21, part 121 also known as 21 CFR 121.

Economic Impact

According to the DHS, the Food and Agriculture sector is very diverse and includes approximately 2 million farms, more than 900,000 restaurants and more than 114,000 supermarkets, grocery stores and other food outlets. There are also approximately 90,000 facilities registered with the Food and Drug Administration (FDA) in the U.S. and another 116,000 foreign food facilities registered with the FDA. These numbers do not include the nearly 7,000 facilities that process meat, poultry, processed egg products and some imported products regulated by the United States Department of Agriculture (USDA) Food Safety and Inspection Service (FSIS).

How high are the stakes? Consider that the U.S. Food and Agriculture sector is almost entirely under private ownership and accounts for roughly one-fifth of the nation's economic activity, according to the DHS. If the U.S.  Food and Agriculture sector were dismantled, the consequences would impact the global food supply.

A History of Using Food as a Weapon

There are numerous examples throughout history where the food supply was considered a viable target. In 590 B.C., an Ancient Greek association was reported to have used a chemical to poison and contaminate the city of Kirrha's water supply during the First Sacred War, or Cirraean War. In 1984, cult members in Dalles, Oregon, contaminated 10 public salad bars with Salmonella Typhimurium bacteria, which sickened 752 people in the local area. This incident was reportedly a "dry run" for a much larger bioterror attack to disrupt a local election by sickening voters so that the cult could gain control of the county commission and sheriff's department. 

As recently as 2002, documents seized by U.S. agencies have referenced targeting the Food and Agriculture sector, such as poisoning water and food supplies. In addition to organizations, disgruntled employees may also pose a threat. In 2013, for example, an employee working in an industrial manufacturing facility used a pesticide to intentionally contaminate a range of frozen food items. The incident resulted in a reported 2,800 illnesses and a recall of 6 million food packages.

Protecting Supply Chains

As threats to the Food and Agriculture and Industrial Manufacturing sectors continue to grow, and as the challenges for businesses to protect their supply chains increase, security risk management is mission-critical. We understand the complexities of protecting our industrial clients' proprietary information and goal to operate safely and reliably. Services provided to the global food industry include safety management, risk management, criminal investigations and root cause analysis. Our team members are also experts in understanding regulatory compliance, having helped draft the original rule enacted by the FDA in 2011. 

Due to our extensive background in the food sector and risk management expertise, our Risk and Safety Management and Public Sector advisors are uniquely qualified to work with companies registered with the FDA to identify, prioritize and mitigate the compliance risks associated with 21 CFR 121. Explore our capabilities in our Food Defense Regulatory Compliance Services factsheet and Security Risk Management solutions.