Friday, June 29, 2012

Improving Security Across the Supply Chain


Terrorist attacks are designed to promote fear, create publicity, and create disruption causing as much damage as possible.  Biological attacks are a credible threat historically resulting in a significant loss of life, severe injury, and long lasting health threats. After the attacks on September 11, it was no surprise to officials that anthrax was used in a biological attack while the country was still in shock.

            In February 2009, Abdallah Al-Mafisi appeared on Al Jazeer TV (Qatar) where he outlined a plot to put four pounds of anthrax in a small suitcase and carry it through the tunnels in Mexico into the United States.  He painted a picture of standing on the lawns of the White House sprinkling “confetti” that would kill 330,000 people within one hour dwarfing the effects on September 11[i].    Extremists openly admit they have scientists, chemists, and nuclear physicists with labs in North Afghanistan.  Hazbullah is known to have labs creating biological weapons in South Lebanon selling those weapons to the highest bidder. 
            Shortly after September 11, retired colonel Randall Larson passed through security at the White House.  New security measures had been implemented that detected metal, radiation, and a thorough search of personal belongings before his meeting with Vice President Cheney.  The guards questioned Larson about a gas mask in his brief case where he provided the explanation that it was intended to be used for a demonstration.  Larson passed through the checkpoint.  During the meeting to discuss the potential of biological attacks, Larson was able to produce a vial of white powder that was smuggled into the White House demonstrating that United States security forces were not prepared for a biological attack.[ii]We are fortunate that we have not faced any large scale attacks on our food supply other than small scale product tampering or accidental contaminations.  The threat is credible as both domestic and international terrorists have outwardly spoken about agro terrorism to make political statements. 
Manufactured agents could easily be introduced into livestock feed or water spreading disease.  The economic disruption could be devastating in addition to the myriad of health risks, including loss of life.  Improvements have been made including the Bioterrorism Act of 2002 requiring the registration of food facilities, prior notice of food imports, and maintenance of records to ascertain the source of an incident, and the ability for the Food and Drug Administration (FDA) to detain food if it is believed to present a health risk[iii] but this is not enough. 
The Government Accountability Office believes terrorists would attack a food source such as livestock or crops if their intent were to negatively impact the economy, terrorists would contaminate finished products to have an impact on human life”[iv] Congressional testimony in 2003 addressed concerns about disease entering the United States from foreign imports illustrating a need to strengthen imports and ensuring agents have clear authority to investigate and take preventive measures.  There was also concern that food processors were both domestically and abroad had not implemented adequate security measures throughout the supply chain.  This report also discussed security problems at animal disease research facilities where scientists, workers, and students from foreign countries had equal access to high risk pathogens without undergoing appropriate background checks. 
Although there have been improvements within government to protect the supply chain life cycle, there are still gaps in security where improvement is needed.  By examining recent improvement and identifying those gaps, recommendations can be made to strengthen security and enforcement measures to identify and minimize risk.   
Improvements and Resources to Protect the Supply Chain
Supply chain security has been defined as: 
“The application of policies, procedures, and technology to protect supply chain assets (product, facilities, equipment, information, and personnel) from theft, damage, or terrorism, and to prevent the introduction of unauthorized contraband, people, or weapons of mass destruction into the supply chain”[v].
Protection should begin at the point of origin, with transparency and procedures to protect the supply chain.  Although it is in the best interest for private industry to participate in securing their operations to limit the impact on their organization in the event of a loss, companies are not always willing to invest the time and resources required to establish and manage an ongoing safety program.  In a globalized supply chain, there are more hands on deck with opportunities for shipping delays, natural disaster, theft, and contamination of the supply that could cause significant economic or public health risks. 
There are many organizations across the food and beverage industry that have worked with government agencies developing policies and procedures to protect the supply chain.  The Food and Drug Administration (FDA) is committed to working with consumer groups to enhance best practices and mitigate risk while promoting corporate responsibility to actively participate in food safety initiatives.  Over the last several years, the FDA has increased their presence in foreign countries providing assistance to enhance food safety measures in countries that export to the United States.  Crop Life America[vi] supports growers with information on new threats, provides education on improved growing techniques, and demonstrates a commitment to protect the supply chain.  “The crop protection chemicals industry [in partnership with Crop Life America] is working in close cooperation with the Department of Homeland Security to implement the recently finalized Chemical Facility Anti-Terrorism Standards rule”[vii].  This is a regulation requiring chemical suppliers to monitor and track the sale of toxins that are toxic, explosive, or flammable.  The regulation requires that all chemicals in the possession of manufacturers and farmers identified as a potential threat be securely stored to deter theft or diversion as well as prevent against acts of sabotage or contamination.  Professional organizations and government agencies can assist businesses to develop a plan that will comply with regulation.
Government is consistently striving to improve relationships across the supply chain offering guidance and information on threats.  The FDA formalized partnerships with Cornell’s Department of Food Science and the Illinois Institute of Technology’s Institute for Food Safety and Health establishing the groundwork for industry alliances to positively impact industry in 2012.  Grants were issued to these organizations to develop training materials and distance learning programs for the safe production of food, tools for growers to conduct self audits, and serve as a network resource for the growing industry and Federal and State regulatory agencies.  The FDA has traditionally acted in reaction to an event or loss but in recent years has changed their organization to focus on prevention by implementing “farm to table” security measures. 
Gaps In Security
Although improving security and food safety is desirable, basic security measures are not always implemented and often overlooked.  Government has implemented the Food Safety Modernization Act to provide resources that will help producers identify and control critical points in their operations, however basic security and minimum requirements should be established.  As demonstrated by the escape of a cow at a New Jersey slaughterhouse[viii], perimeter fencing in this urban environment was inadequate.  Workers at the facility did not know the cow had escaped until notified by the local authorities.  The cow was easily able to escape the slaughterhouse undetected running through a heavily populated city that demonstrates the risk of an individual entering the slaughterhouse undetected to contaminate the food supply and resulting in catastrophic loss.
Transportation of food has not adequately been discussed.  Unlike other industries that regulate the transport of goods such as chemicals or pharmaceuticals, there are no requirements to establish a paper trail or maintain records on food transported.  In establishing safe transport practices preventing theft or contamination during transport, control points would need to be identified to ensure food safety.  Transportation associations have resisted government involvement claiming food safety is not at risk based on the historically low incident rate of food contamination during transport stating “there is no need for FDA involvement in the transportation of food products, unless they must be refrigerated”[ix]  Farmers and manufacturers will need to place pressure on their logistics partners to ensure they are committed to food safety and best practices.
Undocumented workers for the most part do not present a threat of terrorism, but introduce several risks that could affect public health.  Illegal immigrants create a demand for the underground production of false documentation and identities that terrorists could take advantage of by terrorist organizations.  The means used to cross the borders without detection, has already been used by terrorist cells.  The movement of toxins or disease could easily cross the borders undetected.  These workers present a health risk to the public.  They typically do not have health insurance, nor the means to pay for adequate medical care.  Health conditions often go untreated within this population bringing risk to the supply chain introducing a virus or other contaminate.  Additionally, low income families with easy access to the supply chain may become the target of a terrorist organization offering funds to introduce bio-toxins into the food or water supply.   
Recommendations
It is recommended that policies are developed cooperatively “across the enterprise and are designed end to end, including direct suppliers, critical raw material suppliers, and logistics partners”[x].   Although government can assist companies in their efforts to develop internal policies and procedures, they are not in a position to force companies to institute protective measures.  It is critical for the supplier to develop a security plan that identifies physical security features, limiting access to the public or outside sources to water supply, feed, or processing areas.  As part of the strategic plan to implement security procedures, communication across the supply chain should be an integral part of the process.  It will be critical to discuss safety measures with employees, vendors, logistics partners, and customers to ensure that all partners are committed to product safety and understand the policies and procedures established by the manufacturer.  In developing partnerships throughout the supply chain, contracts should include minimum required safeguards.  Frequent site inspections should be implemented to ensure proper safeguards and contractual obligations are being implemented
The commitment to protecting the supply chain should be embraced and discussed while implementing plans between manufacturing, logistics, and retail partners to set the expectations with all stakeholders far beyond the contract negotiation.  Ryder Trucking and hauling has demonstrated open communications across the supply chain my leading cross border security conferences to facilitate ongoing mitigation reviews and risk management in an ever changing environment.  Government agencies are often involved in conferences or other security meetings to assist businesses in identifying new risks and offer risk management suggestions. 
Government should intervene and establish a permanent solution to immigration and the risks associated with undocumented workers.  It is very difficult for some employers to find Americans who will work certain types of jobs such as dishwashers, housekeeping, farming, and general labor that may justify the hiring of a non-citizen, however, a system should be implemented that would allow an employer to legally hire foreign workers that are documented.  A system should be in place to verify the identity and eligibility for the worker.  Part of the process of documenting a worker may be the certification they are free from contagious disease to further protect the food supply.  Instituting a method to employ temporary, seasonal, or foreign workers legally will discourage undocumented workers from crossing the border and help control the underground ancillary businesses that attract terrorist groups.
Many health care providers have been establishing medical clinics in the United States to handle the growing number of uninsured workers that contribute to preventing the spread of infectious disease.  Many immigrant workers are afraid to visit the clinics because immigration officials frequently target those facilities to collect and deport those workers.  These are workers who will rent a house in a decent school district and place two or three families in the house to give their children the opportunity of education.  Untreated infectious diseases could quickly become an epidemic.
Unfortunately, not all organizations throughout the food supply chain are willing to join professional associations, or work with government to improve food quality,  safety, or transport.  Consumer demand will ultimately steer the industry forcing them to commit to food quality and safety issues whether it is through litigation in the aftermath of an incident; or through education giving consumers information understanding why they would want to make a choice to buy products that are industry approved.  Professional associations, businesses, and government entities should work towards educating consumers about food quality and the benefits of choosing food from participating association members that adhere to best practices in food safety. 


BIBLIOGRAPHY

Another 9/11 Coming? Biological Attack in the US..scary Stuff." YouTube. March 23, 2012. Accessed June 02, 2012. http://www.youtube.com/watch?v=obXAy1i5RPU.

Bautista, James. "750-pound Cow Escapes Slaughterhouse, Runs through Paterson Streets." The Record. April 10, 2012. Accessed June 8, 2012. http://www.northjersey.com/news/Cow_runs_loose_in_Paterson_after_escaping_slaughterhouse.html.

Betts, Richard K. "The New Threat of Mass Destruction." Foreign Affairs. January/February 1998. Accessed June 02, 2012. http://www.foreignaffairs.com/articles/53599/richard-k-betts/the-new-threat-of-mass-destruction.

"Emergency Preparedness and Response." Counterterrorism-Related Legislation. June 12, 2002. Accessed June 02, 2012. http://www.fda.gov/EmergencyPreparedness/Counterterrorism/BioterrorismAct/default.htm.

Enslow, Beth. "Risky Business: Tackling the Rising Supply Chain Risk Threat." Risky Business: Tackling the Rising Supply Chain Risk Threat. Accessed June 20, 2012. http://www.mmc.com/knowledgecenter/viewpoint/Tackling_the_Rising_Supply_Risk_Threat.php.

"Food Safety Modernization Act." US Food and Drug Administration. May 5, 2011. Accessed June 21, 2012. http://www.fda.gov/Food/FoodSafety/FSMA/ucm254310.htm.

Fox, Maggie. "After 9/11, Anthrax Attacks Seemed Too Natural." NationalJournal.com. September 1, 2011. Accessed June 02, 2012. http://www.nationaljournal.com/911-anniversary/after-9-11-anthrax-attacks-seemed-too-natural-20110901.

Hylton, Wil S. "Warning: There's Not Nearly Enough Of This Vaccine To Go Around." The New York Times. October 30, 2011. Accessed June 02, 2012. http://www.nytimes.com/2011/10/30/magazine/how-ready-are-we-for-bioterrorism.html?pagewanted=all.

"Industry Groups Wary of Plan from FDA on Food Transport." Review. Transport Topics, September 13, 2010. Accessed June 21, 2012. http://search.proquest.com.ezproxy1.apus.edu/docview/752000309?accountid=8289.

Kloss, David, Cheri Speier, and Dounglas M. Voss. "A Framework for Protecting Your Supply Chain." Logistics Management 47, no. 9 (September 2008). Accessed June 5, 2012. doi:197209740.

"Worker Protection Standards." Crop Protection & Pesticide Worker Safety Standards : Issues. Accessed June 21, 2012. http://www.croplifeamerica.org/pesticide-issues/worker-protection.

ENDNOTES


[i] "Another 9/11 Coming? Biological Attack in the US..scary Stuff," YouTube, March 23, 2012, Introduction, accessed June 02, 2012, http://www.youtube.com/watch?v=obXAy1i5RPU.
[ii] Wil S. Hylton, "Warning: There's Not Nearly Enough Of This Vaccine To Go Around," The New York Times, October 30, 2011, Introduction, accessed June 02, 2012, http://www.nytimes.com/2011/10/30/magazine/how-ready-are-we-for-bioterrorism.html?pagewanted=all.
[iii] "Emergency Preparedness and Response," Counterterrorism-Related Legislation, June 12, 2002, Introduction, accessed June 02, 2012, http://www.fda.gov/EmergencyPreparedness/Counterterrorism/BioterrorismAct/default.htm.
[v] David Kloss, Cheri Speier, and Dounglas M. Voss, "A Framework for Protecting Your Supply Chain," Logistics Management 47, no. 9 (September 2008): pg. #, accessed June 5, 2012, doi:197209740.
[vi] "Worker Protection Standards," Crop Protection & Pesticide Worker Safety Standards : Issues, section goes here, accessed June 21, 2012, http://www.croplifeamerica.org/pesticide-issues/worker-protection.
[vii] Ibid
[viii] James Bautista, "750-pound Cow Escapes Slaughterhouse, Runs through Paterson Streets," The Record, April 10, 2012, section goes here, accessed June 8, 2012, http://www.northjersey.com/news/Cow_runs_loose_in_Paterson_after_escaping_slaughterhouse.html.
[ix] "Industry Groups Wary of Plan from FDA on Food Transport," review, Transport Topics, September 13, 2010, pg. #, accessed June 21, 2012, http://search.proquest.com.ezproxy1.apus.edu/docview/752000309?accountid=8289.
[x] Beth Enslow, "Risky Business: Tackling the Rising Supply Chain Risk Threat," Risky Business: Tackling the Rising Supply Chain Risk Threat, section goes here, accessed June 20, 2012, http://www.mmc.com/knowledgecenter/viewpoint/Tackling_the_Rising_Supply_Risk_Threat.php 



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