FoodHACCP Newsletter

Food Safety Job Openings

06/23. Assist/Assoc Food Safety Prof – Pullman, WA
06/23. Food Safety Manager – Vina, CA
06/23. Director, Quality & Food Safety – Oakland, CA
06/21. Mgr, Regional Food Safety & Qual – Franklin, MA
06/21. Food Safety & Brand Std Spec – Kalamazoo, MI
06/21. QA & Food Safety Manager – Bennington, VT
06/19. Sr. Consultant, Food Safety & Quality - Remote
06/19. Director of Quality Assurance – Boise, ID
06/19. Food Quality Control Manager - Valmeyer, IL

06/26 2017 ISSUE:762



Burger-gate over - bureaucrats burned to a crisp over new rules
Source :
By David Fisher (June 26, 2017)
Burger-gate is over - the threat to medium-rare burger patties is gone.
Steak tartare, carpaccio and other uncooked or rarely-cooked fare will also be allowed onto the menu after bureaucrats found a way for the nation to dine as it wishes.
The shift came today after under-fire bureaucrats at the Ministry for Primary Industries clarified its stance over minced meats and liver.
It followed an outpouring of frustration from the Duke Of Marlborough Hotel's award-winning chef Dan Fraser who felt forced to pull the Governor's Burger with its medium-rare pattie from the menu.
New food regulations largely developed to deal with food cooked in fast-food joints had been also been presented to thousands of restaurants, dictating cooking processes which would have stopped Fraser and others from cooking patties on a barbecue grill.
The backlash had MPI's director Peter Thomson today explaining that there was no need for any restaurant to change, as long as chefs could show food inspectors that they could produce food for customers that was safe to eat.
Thomson said the generic guidelines which had been distributed also allowed for particular types of food to be served outside the rules.
He said the generic guidelines did not account for specialist outlets or restaurants which prepared food in a particular way, but there was room to do so.
"It is designed for the average places rather than places that do something special. We have offered to work with chefs to develop a bespoke food control plan or to develop a new section to go into the template."
He said no special guidelines existed for minced meat at this stage but MPI had started work on a new template that would allow chefs to prepare food as they had - as long as it could be shown safe to eat.
"Cooking is a good final step for managing risk," he said, but there were other methods which included the sourcing of produce and the handling and storage of raw ingredients.
"If you step back all processes and manage all steps of contamination, then you can cook meat and have the risk of the meat at a very low level."
He said it wasn't a change prompted by publicity because the opportunity for restaurants to develop bespoke plans had existed at the time the new guidelines were rolled out.
"It looks like some restaurants have been working on the template plan. Any food business has a lot of things to think about and maybe they missed some of our messaging sometimes."
Minister for Food Safety David Bennett said MPI's rule were not about taking away choice but keeping people safe.
"I am pleased to hear the situation has been clarified in this case. I want people to be able to eat a full spectrum of food, just in a safe way.
"I look forward to trying one of the famous Duke of Marlborough's signature burgers."
The move by MPI to regulate chefs' kitchens brought howls of outrage and ridicule from those interviewed by the NZ Herald.
Labour's Damien O'Connor said it was "ridiculous overkill".
"We've got strict controls on how you kill and process meat. To then look at the cooking of it is nanny-state gone mad.
O'Connor said he had eaten at the Duke of Marlborough just over a year ago and had slow-roasted lamb that was "sublime".
"I would trust that chef any time to cook the meat in the way that delivers the finest and safest food for anyone."
Northland MP Winston Peters, who has eaten at the Duke of Marlborough often over the years, said "paternalistic bureaucrats" were killing New Zealand businesses.
He had written to Primary Industries minister Nathan Guy to tell him to "show some steel for a change and roll back this regulatory nonsense".
Fraser told the Herald that MPI appeared to have not consulted widely enough with chefs to understand the problem they were causing.
The new generic rules stated minced food and livers needed to be cooked at high temperatures for longer than previously to eliminate any chance of contamination.
Food safety inspectors have recommended a number of ways of eliminating risk, which Fraser had rejected as doing such awful things to food he would rather not serve it.

Faces of food safety: Meet Cedric Dial of the FSIS
Source :
Editor’s note: This is a recent installment in a series of employee profiles being published by the U.S. Department of Agriculture’s Food Safety Inspection Service, republished here with permission.
Cedric Dial, a consumer safety inspector in the Dallas District, has been a USDA Food Safety and Inspection Service civil servant for 18 years, while also serving as an U.S. Army Reservist for 17 years. He is passionate about making a difference in people’s lives in both of his chosen professions.
“I love being a CSI (consumer safety inspector) and being a part of the military, because I protect the country in both jobs,” Dial said.
As a CSI, Dial said he feels accomplished when serious issues are handled properly, thus ensuring the safety of individuals who may consume that particular product. He further noted that as a CSI, he provides a service to the establishment by ensuring they are in compliance with FSIS food safety standards.
As a reservist, he teaches soldiers how to drive mine-resistant, ambush-protected vehicles.
“Those who are in my military purview also learn about food safety, especially during field trainings when we have to rely on alternative methods of washing hands when the convenience of indoor plumbing isn’t available,” Dial said.
Dial’s daily CSI duties consist of performing antemortem inspections of poultry, which is the inspection of live birds and other animals prior to being slaughtered; monitoring the establishment’s operational sanitation procedures to ensure sanitary handling and dressing processes are in accordance with regulations; and ensuring the establishment’s Hazard Analysis and Critical Control Points (HACCP) plan meets regulatory requirements.
Fast food paved his way
Dial was familiar with sanitation procedures and HACCP plans well before joining FSIS. In fact, he said the job where he learned about these procedures inspired him to explore employment opportunities in the agency.
“I worked as a cook at McDonald’s in Farmerville, LA, for five years. Within five months of starting that job, I was promoted to assistant manager, and I credit that position for helping me to understand the importance of food safety and preparation,” Dial said.
“I know what I do at FSIS is very important because I’m directly responsible for ensuring the protection of the nation’s food supply. In doing so, I am an integral part of a team in which our primary concern is keeping people from getting sick or from possibly dying.”
Dial attributes his success at the agency to his FSIS colleagues and to his military career.
“My FSIS team is a big part of my success,” Dial said. “I have a sense of pride in the quality of work my team performs, but also what they provide me on a personal level. CSIs Dorinda Nygaurd, Phyllis Frazier and Timothy Overstreet are my go-to battle buddies. If I learn something new that’s going on within the agency, I share the information with them; they give me their advice. I also share what I’m thinking with them. We have a reciprocal relationship and support each other.
“Being a Sergeant First Class, an equivalent to a GS-7 civilian position, in the U.S. Army Reserve has taught me to be a leader and it transfers into my civilian life, particularly when interacting with others. The soft people skills that I’ve learned in the military have proven invaluable because they helped me improve my interpersonal and social skills and with communicating with others by learning how to read and understand others’ verbal and nonverbal body language and personality traits.”
The Monroe, LA, native also credits his mother, Mitchell McKinney, for his civilian career choice.
“Before she passed away, my mother was my inspiration to work in the USDA,” Dial said. “She was my motivation. I felt it was important to make her proud. She encouraged me to accomplish my goal of becoming an FSIS inspector. The work ethic and determination she instilled in me has sustained me throughout my career. She died a month after I received my letter of full-time employment with the agency and having an opportunity to share this accomplishment with her was immeasurable.
“I was 24 years old, and she was very proud of me and my commitment to pursuing a career that would have a positive impact on others. Knowing that I keep people from being harmed by the food they eat provides a great sense of satisfaction. I have an additional measure of satisfaction knowing that these safety measures extend not only to my family, friends and community but to individuals that I may never meet.”
Dial shares his life with his wife Rodquel and their four children. He teaches his family about “bad bugs” that can cause foodborne illness. He says it “grosses them out” but it instills in them the need to wash their hands frequently and pay close attention to safely preparing foods and to cooking temperatures.




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Chinese poultry: Verification must precede trust for food safety
Source :
By BRIAN RONHOLM (June 25, 2017)
There is always a healthy amount of skepticism from parents whenever children claim they were able to clean their rooms in five minutes. While the children may have met the literal requirement of the parent’s request, you wonder what surprises would be discovered if you checked under the bed, in the closet or in the dressers. The parent often ends up having to verify each time that the room definitely has been cleaned.
This scenario provides an overly simplified explanation of the equivalency process at the USDA’s Food Safety Inspection Service (FSIS). As many are aware, countries that wish to export meat, poultry, catfish, or egg products to the United States must demonstrate to FSIS that their food safety inspection system is equivalent to the U.S. system. This equivalency determination process allows FSIS to verify that a country’s food safety inspection system achieves the appropriate level of food-borne illness prevention, especially countries with a spotty food safety record.
Recently, FSIS issued a proposed rule that would allow China to ship poultry products from birds slaughtered in China. This proposed rule was the culmination of an extended process that lasted more than a decade and included a number of visits by FSIS and myriad correspondence between the agency and China. The process became prolonged for many reasons, but it always seemed that China’s intentions were always opaque or kept shifting.
During my time at USDA, I was once approached at a conference by someone who claimed to have direct knowledge into the thinking of the Chinese government on their equivalency application pending before FSIS. He explained that China was seeking a better deal than what other Asian countries had received, adding that China viewed itself as the big brother in Asia and therefore should receive special consideration under these circumstances.
Somewhat taken aback by this suggestion, I diplomatically explained that FSIS is required to follow a process in determining whether a country’s food safety system is equivalent and there could be no “deal” when it comes to ensuring the safety of imported foods into the U.S. Assuming this person did have direct knowledge into the thinking of the Chinese government, it provided some insight as to why China intentionally protracted the process. By failing to submit requested information or respond to correspondence in a timely manner, China appeared to be sabotaging itself throughout this process. In actuality, they responded by slowing down other trade-related discussions.
FSIS recently announced it was suspending fresh beef shipments from Brazil because of recurring food safety problems that stemmed from an investigation involving allegations of bribery by meatpacking facilities in exchange for the approval of spoiled meat for export. Food safety considerations notwithstanding, USDA seemed to possess some leverage in suspending these shipments because of the political scandal this caused in Brazil, and other countries already had temporarily banned beef shipments from that country.
Additionally, since U.S. beef shipments to Brazil resumed just this year, the impact of any potential retaliatory measures would seem to be minimal. If faced with a similar situation involving China, USDA is unlikely to possess such leverage, so the question becomes whether the department would be willing to take such a forceful action with China.
If and when the FSIS proposed rule becomes final, an important component of the equivalency process is continually evaluating and verifying that the equivalency determination can be maintained, as the Brazil situation demonstrates. This ongoing equivalence verification process includes document reviews, on-site audits, and point of entry re-inspection. Given China’s recent record on food safety, it will be critical for FSIS to utilize these measures and continue the due diligence — checking under the beds and in the closets — to verify that China’s food safety system maintains its equivalency status.

Souplantation restaurant implicated in shigellosis outbreak
Source :
By CORAL BEACH (June 24, 2017)
Pubic health officials in California are praising the “swift and decisive action” of the Souplantation chain, which temporarily closed a restaurant in Camarillo in the midst of a shigellosis outbreak this week.
At least eight people have been infected with Shigella bacteria, according to Ventura County Public Health officials. The public health department received notification of the outbreak Thursday, the same day Souplantation officials closed the restaurant.
“Through a series of interviews with those affected, it has been determined that a number of the cases reported to have eaten at the Souplantation in Camarillo. Of the diners interviewed, there are a total of eight individuals with laboratory evidence of Shigella infection,” the county reported Friday.
“It is not currently clear what the source of the infection is. No one food item has been indicated. All employees are being tested and will need to be cleared before returning to work. There are approximately 40 employees at the restaurant.”
All of the food in the restaurant at the time it was closed is being discarded, according to the county news release. The Souplantation location is being “thoroughly cleaned” and all employees are receiving a refresher course in sanitary training.
Ventura County Public Health staff is working with the county’s Environmental Health department, which completed two inspections of the restaurant “in the past two days,” according to the Friday news release from the county.
“We’re tracking these cases closely,” said Public Health Officer Robert Levin in the county release.
Levin praised the Souplantation corporate office for closing the restaurant location through this weekend. Three Souplantation executives traveled to the Camarillo restaurant in response to the outbreak, the chief operating officer a vice president and the company’s quality assurance manager, according to the county release.
“Souplantation’s actions have been exemplary. This is the kind of swift and decisive action, which leads to a collaboration with public health that results in a rapid resolution of the problem,” Levin said in the release.
Anyone who has eaten at the Souplantation in Camarillo recently and developed symptoms of shigellosis should seek medical attention and tell their doctors about the possible exposure.
Shigellosis is highly contagious, but some people who are infected do not have any symptoms. Such individuals can pass the bacteria to others.
Most people who are infected with Shigella develop diarrhea, fever and stomach cramps starting a day or two after they are exposed to the bacteria. Shigellosis usually resolves in five to seven days. However the elderly, young children, pregnant women and others with suppressed immune systems can develop life-threatening infections.

USDA Suspends Imports of All Fresh Beef from Brazil
Source :
By Food Safety Tech Staff (June 23, 2017)
Yesterday Sonny Perdue, U.S. Secretary of Agriculture announced that the USDA would be halting all imports of fresh beef from Brazil. The USDA has been inspecting all of the meat products entering the United States from Brazil since March, and has refused entry to 11% of fresh beef products. According to an agency press release, this figure is “substantially higher than the rejection rate of 1% of shipments from the rest of the world”. The increased inspection has resulted in refusal of entry to about 1.9 million pounds of Brazilian beef products over concerns related to public health, sanitary conditions and animal health.
“Although international trade is an important part of what we do at USDA, and Brazil has long been one of our partners, my first priority is to protect American consumers. That’s what we’ve done by halting the import of Brazilian fresh beef.” – Sonny Perdue, U.S. Secretary of Agriculture
The USDA is suspending shipments until the Brazilian Ministry of Agriculture takes corrective action that the agency finds adequate.

USDA Stops Imports of Brazilian Beef
Source :
By Linda Larsen (June 23, 2017)
The USDA is halting imports of Brazilian beef, according to a press release from that government agency. There are “recurring concerns about the safety of the products intended for the American market,” according to the release. Brazil is one of the world’s largest beef importers, and is the fifth largest beef supplier to the United States.
USDA’s Food Safety and Inspection Service (FSIS) personnel have been inspecting all, or 100%, of meat products imported from Brazil into the United States since this spring. FSIS has refused about 11% of those imports; that number is much higher than the typical rejection rate of 1% of all food shipments from the rest of the world.
FSIS has refused entry to 106 lots, about 1.9 million pounds, of Brazilian beef products for public health concerns, sanitary conditions, and animal health issues. The release states that “none of the rejected lots made it into the U.S. market.”
The Brazilian government was supposed to address those concerns. They self-suspended five facilities from shipping beef to America. This action today supersedes the self-suspension. China, Mexico, Japan, the EU, Hong Kong, Egypt, Switzerland, Canada, and Chile stopped imports of Brazilian beef this spring when an investigation into meat inspectors in that country was publicized.
In Brazil, a scandal named “Carne Fraca,” (weak meat) erupted earlier this year. Inspectors at a Brazilian exporter allegedly let meat tainted with Salmonella bacteria and spoiled meat sold. That facility was accused of trying to cover up the rotten meat’s odor by using water and manioc flour. Investigators say that health inspectors at that plant were bribed to allow these sales.
Brazilian Association of Beef Industry has claimed that corrective actions have been taken. One of the problems with this meat being sold into the United States is that we have no “country of origin” labeling on products. American consumers have no way of knowing where their beef comes from.
Wenonah Hauter, Executive Director of Food & Water Watch said in a statement, “Three months after allegations surfaced that Brazilian meat exporters bribed inspectors to approve tainted beef for sale and export, USDA is finally halting meat shipments from Brazil. The question is, why did it take so long?
“Brazil has a checkered history when it comes to food safety, and the latest revelations of corruption—bribery, using chemicals to cover up rotten meat, sending salmonella-contaminated meat to Europe and falsifying health certificates—raise questions about its meat exports and its equivalency system.
“What has happened recently in Brazil is not new. In 2005, USDA’s Food Safety Inspection Service (FSIS) conduced five equivalency audits in Brazil. One of these audits revealed that FSIS inspectors were not paid by the federal government and were receiving subsidized meals and transit from the companies they were inspecting. Their medical bills were also covered by the same companies. This revelation lead to the temporary suspension of meat exports to the U.S. Subsequent problems included the discovery of drug traces on Brazilian meat, as well as an outbreak of BSE.
“Last week, food safety officials in the European Union reported finding serious problems with Brazil’s meat exports. Shipments stopped at the border tested positive for salmonella, drug residues, E.coli and other serious problems.
“We praise Sen. Jon Tester (D-MT) for stepping up to protect American consumers and ranchers by pressuring the USDA to suspend meat shipments from Brazil, and we’re pleased to see the agency finally take action, but it’s not enough. We also call on the Trump administration to revoke Brazil’s equivalency status until it can clean up its act.”
Secretary of Agriculture Perdue issued this statement about the ban: “Ensuring the safety of our nation’s food supply is one of our critical missions, and it’s one we undertake with great seriousness.  Although international trade is an important part of what we do at USDA, and Brazil has long been one of our partners, my first priority is to protect American consumers. That’s what we’ve done by halting the import of Brazilian fresh beef.  I commend the work of USDA’s Food Safety and Inspection Service for painstakingly safeguarding the food we serve our families.”

Six-Step Program for the Alcoholic Beverage Industry to Comply with FSMA
Source :
By Michael Kalish (June 20, 2017)
Winemakers, brewers and distillers are faced with the daunting task of evaluating their compliance with an extremely fragmented regulatory landscape. The new U.S. Food and Drug Administration (FDA) regulations, applicable to the Alcoholic Beverage Industry (ABI), are derived from The Food Safety Modernization Act (FSMA) rules, and are scattered across different parts of the Code of Federal Regulations. While this industry is known for people with high tolerances, confusion is high.
The Stakes
If growers and commercial processors of ingredients intended for alcoholic beverages do not identify, address and comply with, these requirements, they can be charged with performing a “Prohibited Act” and their product can be considered “Adulterated.” The stakes are high and the industry needs a hand.
The Game Plan
You need to recognize that this is a project, not a task. Here are six steps you can take to methodically address the requirements and to assuage your anxiety and fear over FSMA:
1. Assemble the Applicable Code
Identify all the applicable code and put it in one place. You can have it in a checklist format or in a spreadsheet. Just make sure you have a spare column to keep notes.
2. Read the Regulations
Break it up, set weekly goals and engage a team (or a partner). When you reach a regulation that is confusing, flag it and keep going. The rules aren’t changing anytime soon and they dictate what industry must do to stay in business.
While a winery and a facility preparing ready-to-eat salads may be subject to the many of the same regulations, FDA provides flexibility by adding qualifiers to the regulations: “as adequate,” “as necessary” and “appropriate.” If you haven’t done so already, contact a trade association to familiarize yourself with industry standards.
3. Identify Gaps
If you read the regulations and can identify evidence that your operations and facility are in complete compliance, congratulations! If you fail to identify evidence that you are complaint with a regulation, then you have a gap that will need to be addressed.
4. Collect and Build Evidence
Compliance is not always best demonstrated by a single piece of evidence. Sometimes, a combination is best. For example, if you develop a training procedure, you may also want a training record for those trained. But not all evidence is the same. Evidence can be reduced to two types: desk and facility.

Desk evidence includes written policies, procedures or forms. Consider a training standard operating procedure, an employee training log and job descriptions. These examples altogether could be a combination of documentation that be used to ensure you, and demonstrate to FDA, that employees meet the definition of Qualified Individuals. Desk evidence can also be some other type of documentation, such as a carrier contract or FDA registration. Anything documented!
Facility evidence is an activity or design that FDA can observe during an inspection to gauge compliance. For example, FDA may inspect the exterior of your facility to see that the ground is sloped, thus preventing the pooling of water. No need for a daily log or standard operating procedure for inspecting and recording that the grounds are still sloped.
5. Train Your Team
Once you have organized your documented and facility evidence, it is time to use it to train your staff so you can effectively align your company standards with the law of the land. There may be parts that you would like to outsource (e.g., Good Manufacturing Practices) and other parts you’d like to maintain in-house (e.g., job descriptions). I prefer to use the documentation that I generate as training material and performance criteria, which makes it doubly important that this documentation is easy to read and concise.
6. Conduct an Internal Audit
Now that you have all of the evidence, training and evaluations needed to demonstrate full compliance with FSMA, you are ready to conduct an inspection of your facility and an audit of your records. You can re-purpose the same list of requirements that you used before, just add another column to add “Compliant” or “Not Compliant” and some space for notes.
When Should I Hire an Attorney or Consultant?
The most costly relationship you can have with an attorney or consultant is when you enter a consulting session unprepared and without an agenda. By doing the initial footwork, you’ll be better prepared to ask the critical questions and make immediate use of consulting advice.
Michael Kalish is managing member of Food Safety Guides, a progressive food safety and quality systems consulting firm that specializes in FSMA compliance, HACCP, third-party audit preparation and food safety and quality plan development. Michael is also Senior Technical Advisor for Food Safety at the University of California – San Diego and a Food Safety Preventive Controls Alliance Lead Instructor for Human and Animal Food.

Lessons Learned from Military History Aid Food Defense
Source :
By Robert A. Norton, Ph.D (June 20, 2017)
Food defense is at its best when it is proactive. When a food defense plan fails, all that is left is damage to the brand, the cleanup, remediation and often litigation. Adversaries, both inside and outside food production and processing corporations, are for real and not the result of overactive imaginations. Corporate decision makers don’t have to look far to find people or groups who really do want to damage their company or brand, steal its secrets and take a share of profits for their own.
A common reaction when things go bad is for corporations to try and set blame. Someone had to be responsible. Somebody had to be at fault. As painful as the truth often is, looking back at corporate disasters frequently reveals just that. Someone is indeed at fault and therefore partially responsible—because they enabled an adversary to succeed. Corporate decision makers who chose to ignore the warnings, but do so very much at the peril of the company. Eventually, the decision to ignore impending threats enables those threats to mature, causing an impact of greater magnitude than had they been dealt with the threat more expeditiously.
Military Lessons Learned
As odd as it may seem, food defense practitioners could learn a lot by studying history. After commemorating the 75th anniversary of Pearl Harbor, that example of ignoring maturing threats might be a good place to start. The article “The First Attack: Pearl Harbor, February 7, 1932” dissects the warnings that were ignored. To save time for busy food defense personnel and corporate decision makers, I have summarized the lessons learned and translated the lessons into “food defense speak:”
1. War was expected with Germany and Japan, but President Roosevelt wanted to concentrate on Germany first, fearing that seeking to defeat Japan would divert efforts needed to defeat Germany.
Translation: The best-laid plans always fall when realities strike. Planning for one contingency while ignoring another gives time for the other threat to mature to the point that it becomes pre-eminent. In the end, both threats materialize, stretching resources to very uncomfortable limits.
2. As soon as President Roosevelt promised the American people that “…no American boys would be sent to fight in Europe,” the chief of naval operations and no less than Albert Einstein warned him that if the United States failed to help Great Britain in defeating Germany, then Europe, Africa and the Middle East would be lost.
Translation: Be very careful what you promise to company officials, stockholders, etc. Reality bites. This is a slight variation to what was said in lesson one.
3. Before declaring war on Germany, the United States began patrols in the North Atlantic and Caribbean to discourage German U-boat operations. The America First committee widely criticized the president for being provocative toward Germany.
Translation: Ignore the critics and do what is right for the company. Although the critics may howl, it is not they who will have to deal with the consequences, should right decisions not be made. Second lesson: Prepare the battlefield for future operations. Putting things in place so they can be used to full effect eventually is often the best option when difficult decisions have to be made.
4. American code breakers had broken many of the codes being used by both Japan and Germany. Intelligence being gathered indicated impending threats, but the use of that information was unorganized, and the military suffered from a lack of Japanese translators. Rapid turnover of code breakers and intelligence analysts, who remained largely disrespected by the larger military, exacerbated problems. “Spying” in those days was still considered by some as not being a “gentlemen’s game.”
Translation: Intelligence (yes, your corporation is going to have to start gathering “intelligence”) is no good if it is not organized and capable of feeding the appropriate information to corporate decision makers. Corporate decision makers, on the other hand, are going to have to learn to trust and respect their food defense professionals, including individuals serving the “intelligence” function. Otherwise, they will suffer the consequences of either not hearing or not listening. Second lesson: Bite the bullet and hire the people you need. Good intelligence professionals do not come cheap these days, but the investment is quickly paid back when disaster is diverted.
5. The warning of impending attack was sent to Pearl Harbor by a Western Union telegram because atmospheric conditions impeded radio transmissions. The warning was finally received by Navy forces in the middle of the first wave of attacks.
Translation: Communication is essential. Sending warnings after the fact does no one any good! Timeliness is everything when trying to defeat an adversary. Second lesson: Having a communication system, or any food defense mechanism for that matter, in place but not working properly increases liability rather than decreasing liability.
6. A war game conducted by U.S. Navy aviator Admiral Harry Yarnell and his aircraft carrier group on February 7, 1932, foreshadowed almost every aspect of the actual attack by the Japanese on December 7, 1941. The Navy was exceedingly embarrassed by the results (the battleship fleet symbolically sunk in Pearl Harbor) and ignored the findings, accusing Yarnell of “cheating.”
Translation: War gaming and red teaming are exceedingly useful practices for food corporations. Learn how to do these exercises, do them and then hear and listen to the results, which likely will not be the pretty first time around. Second lesson: Remediate deficiencies and harden defenses so adversaries choose to go elsewhere.
In the end, a food defense plan is only as good as the people who make it a reality. Food defense is the obverse side of the food safety coin. Neither food safety nor defense functions properly without the other. Given the complexity of the modern food production, processing and distribution systems, we have moved well past the point where an employee can be charged with having both responsibilities. Both food defense and food safety are full time jobs, requiring corporate leadership support and investment.
Our adversaries are not going away, and therefore all in the business of providing a safe, reliable and economical food supply must practice eternal vigilance, preparing for the inevitability of new and evolving threats. To do anything less is to cede to the enemy and invite disaster that could potentially cause significant damage to the corporation and, more importantly, human tragedy. We cannot and must not fail.





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