Food contamination response: When prevention fails

As the old health and safety saying goes, prevention is the best defence. It’s an important principle for the food processing industry. After all, the best way to prevent potentially dangerous food or drink products reaching the market is to maintain high standards of hygiene, staff training and quality control.

Despite the high priority given to contamination prevention by most food processors, food scares and recalls are still fairly commonplace, whether caused by human error, slipping hygiene practices or even sheer bad luck.

So there clearly needs to be a second line of defence, one that sits beyond prevention, to stop contaminated products getting into the hands of consumers and find out what went wrong and where.

Unsurprisingly, food contamination response has been the subject of a large body of research and best practice documents. In the UK, the Food Standards Agency (FSA) published in 2008 an in-depth guide to preventing and responding to food incidents, and the agency has been researching the impact of food safety issues across the food chain for several years.

The US Food and Drug Administration (FDA), meanwhile, released its food related emergency exercise (FREE-B) toolkit in June 2011, presenting five distinct food emergency scenarios to help the food industry assess its own response procedures when it comes to food safety emergencies. Here we look at FREE-B and other initiatives to gather industry and regulatory best practice on how to minimise the damage if the worst case scenario comes to pass.

Tracing foodborne illness back to the source

Although President Obama’s Food Safety Modernization Act, passed into law in January 2011, primarily focuses on shifting the FDA’s focus to preventing food industry contamination before it causes an incident, it also seeks to improve response times for food safety incidents.

The Act requires the FDA to establish two pilot projects (one for produce and one for processed foods), as well as establish recordkeeping standards to help trace products that may have caused illness. The agency clearly decided to kill two birds with one stone, establishing two new projects looking into food tracing in September.

Working with the Institute of Food Technologists, the FDA is investigating new technologies and methods for tracking food products, ranging from ways to connect the food supply chain, data that could be useful for tracing foods and speeding up the delivery of vital information to the FDA for investigation.

The pilots will also feed into new legislation on recordkeeping for high-risk foods, as well as the criteria judged to be high-risk, making them easier to account for in the case of an emergency. These criteria will stem from factors including "the known risks of a food based on foodborne illness data, the likelihood that a particular food has a high potential risk for contamination, and the likely severity of an illness attributed to a particular food", said a statement from the FDA.

FDA deputy commissioner for foods Michael R. Taylor noted that improving tracing methods could accelerate industry and regulatory response to a food safety incident. "We can prevent illnesses and reduce the economic impact to the food industry if we can more quickly determine what foods may be causing an outbreak and what foods can be eliminated from consideration," he said.

"We recognize the importance of engaging stakeholders throughout the process and will consider what is practical for facilities of varying sizes and capabilities."

FDA’s FREE-B

FREE-B, released by the FDA this summer, is a set of five archetypal food safety scenarios designed to provide guidance to companies in setting protocols for a range of contingencies. Being prepared for these scenarios, according to Taylor, "is critical to a rapid and effective response".

The scenarios were developed with the Centers for Disease Control and Prevention (CDC) and the US Department of Agriculture; the director of CDC’s National Center for Emerging and Zoonotic Infectious Diseases Beth P. Bell was also keen to stress their importance.

"It is critical for decision-makers involved in a food safety incident to appreciate the varied roles each must play to reduce foodborne illness, from data collection and analysis to traceback efforts to communicating with the public about how to protect themselves. FREE-B will give stakeholders such an opportunity."

The scenarios, put together from experience of real-life incidents, are designed to present food companies with challenging sample incidents, stressing the need for a ‘whole community’ response in which all stakeholders are aware of their roles and are able to collaborate across disciplines quickly.

One scenario, dubbed Stealthy Situation, describes a regional Salmonella outbreak caused by food bought from a local restaurants and food outlets. The document lays out the ramifications across a wide range of organisations, including the food outlets that supplied the contaminated food, the local processors that may be implicated, hospitals treating infected patients and laboratories investigating the cause and extent of the outbreak.

According to the incredibly detailed guide, local food processing facilities should be asking themselves questions including: "If needed, can you reach your suppliers quickly? What product information do you expect them to be able to be able to provide, and within what time frame?"

By posing these questions to all affected organisations, FREE-B hopes to intricately map out the roles of all stakeholders and encourage communication between them, facilitating the ‘whole community’ reaction that it is emphasising.

Intentional contamination

Two of FREE-B’s five scenarios detail the threat of intentional contamination of food products as a strain of biological contamination.

One looks into the response required after an intentional infection of cattle with foot-and-mouth disease, while another presents participants with the deliberate contamination of raw meat products in a processing environment by bringing them into contact with a chemical agent.

It might be surprising that the FDA dedicates such a large chunk of its guidance to a threat that is far less common than simple human error or substandard hygiene, but many credible institutions see terrorism involving the food chain as a serious future risk. The World Health Organisation’s (WHO) Department of Food Safety, Zoonoses and Foodborne Disease ominously said that "much of the scientific knowledge required to produce chemical and biological agents that could be used to contaminate food deliberately is in the public domain."

The threat was considered severe enough for the WHO to publish an international document in 2002 to guide governments and the food industry in preventing and responding to intentional food contamination. A 2008 update to the paper only reinforced the WHO’s position on the threat terrorism poses to the world’s food supply.

The paper recommended that member states maintain or improve a number of key systems in order to respond effectively to intentional food contamination incidents. For example, effective surveillance and health monitoring systems are required for speedy response.

Well-developed disease surveillance systems should be able to highlight suspicious clusters of illness from an early stage to provide predictive data on an outbreak’s size and severity.

The WHO paper said many member countries don’t have surveillance systems sophisticated enough to detect foodborne disease outbreaks until it’s too late. "In the light of terrorist threats," the report stated, "their capacity to detect and investigate foodborne disease outbreaks rapidly will require the addition of parameters specific to food and potential foodborne agents."

The paper notes that systems like the Foodborne Diseases Active Surveillance Network in the US, Enter-Net in the EU and OzFoodNet in Australia have the capacity to track foodborne disease, although it also notes that even these sophisticated networks need to accelerate their reporting, as intentional contamination events can progress much more rapidly than those that occur naturally.

The contamination of food, whether intentional or unintentional, represents a significant threat to public health on a macro scale, and organisations both private and public must be prepared for the worst if it should happen. Two underlying themes are repeatedly stressed in official guidance: data-gathering and communication.

Systems need to be in place to both identify a disease and its foodborne source, and to facilitate rapid, meaningful communication between large numbers of responsible parties. Once the threat of food contamination has become real, getting the right information and being able to disseminate it as quickly as possible is key to minimising the danger to the public.