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| Agenda Item 5.4 | GF 02/13 |
second fao/who global forum of food safety regulators
Bangkok, Thailand, 12-14 October 2004
(Prepared by the FAO/WHO Secretariat)
The malicious contamination of food for political, financial and other purposes is a real and current threat, and deliberate contamination of food at one location could have global public health implications. Member States of WHO have expressed concern that chemical, biological or radionuclear agents might be introduced into food and other media to deliberately to harm civilian populations and have requested the Organization to provide tools and support to increase their capacity to respond. In response, WHO has prepared various guidelines, including guidance to prevent and respond to intentional contamination of food.
While all food safety emergencies, including intentional and unintentional incidents, may be managed by the existing food safety infrastructure, sensible preventive measures coupled with basic preparedness are needed to address threats posed by deliberate contamination. Countries should integrate consideration of acts of food sabotage into existing programmes for assuring the safety of their food supplies. Strengthening of food safety infrastructure will serve to increase countries’ capacity to reduce the burden of all foodborne illness caused by chemical and microbial agents and to respond to all contamination incidents. Improved linkages with existing communicable disease control systems will also ensure that surveillance, preparedness and response systems include the necessary metrics to identify food borne outbreaks in a timely manner and provide relevant information to facilitate an effective and rapid response.
In order to respond effectively and rapidly, countries require alert, preparedness and response systems to public health threats from actual or threatened intentional contamination of the food supply. Coordination with WHO, FAO and other international and regional organizations regarding incidents involving intentional contamination should be considered as an integral part of strengthening of national systems to respond to all food safety emergencies. In particular, countries should actively participate in the WHO Food Safety Authorities Network for Emergencies (INFOSAN Emergency) as the first step establishing essential capabilities and linkages to deal with this problem.
Threats from criminals and other anti-social groups who target the safety of the food supply are already a reality. During the past two decades, WHO Member States have expressed increasing concern about the possibility that chemical and biological agents and radionuclear materials might deliberately be used to harm civilian populations. In recent years, the health ministries of several countries have increased their state of alert for intentional malevolent use of agents that may be spread through air, water or food.
In 2002, the World Health Assembly in recognizing these threats against civilian populations, requested WHO to provide tools and support to countries in strengthening their national systems to respond to the deliberate use of biological, chemical or radionuclear agents1. It also requested WHO to continue to issue international guidance and technical information on recommended public health measures to deal with potential incidents. In response, WHO has prepared various guidelines, including guidance to prevent and respond to intentional contamination of food.2
All countries must have basic systems to prevent or deter deliberate contamination of their food supplies and, if an incident occurs, to respond rapidly to minimize potential health, economic and other adverse effects of such contamination. However, specific countermeasures should be seen as only one aspect of a broader, comprehensive food safety programme, in national and global contexts. The WHO Global Food Safety Strategy3 comprises a preventive approach to food safety, with increased surveillance and more rapid response to outbreaks of foodborne illness and chemical contamination incidents. This approach could substantially expand the abilities of countries to protect the safety of their food supplies against natural and accidental threats, while providing a framework for addressing intentional contamination of food.
For the purpose of this paper, intentional food contamination is defined as an act or threat of deliberate contamination of food for human consumption with chemical, biological or radionuclear agents for the purpose of causing injury or death to civilian populations and/or disrupting social, economic or political stability. The chemical agents in question are man-made or natural toxins, and the biological agents referred to are pathogenic microorganisms, including viruses, bacteria and parasites, that may be communicably infectious or non-infectious. Radionuclear agents are defined in this context as radioactive chemicals capable of causing injury when present at unacceptable levels. This paper covers all foods, including water used in the preparation of food, as well as bottled water.
As with all health and safety problems, prevention is usually the most desirable option. Prevention is considered first line of defence against intentional contamination. The key to prevention is awareness of this potential threat and the implementation of basic security and precautionary measures. Working in cooperation with government, the food industry is in the best position to rapidly address such threats throughout the food supply system from production to consumption. Government food safety authorities may provide necessary guidance and other coordination functions to assist industry, as in the case of product tracing and recall. As production methods and quality programmes are often proprietary, the food industry has both the knowledge and the capacity to reduce the likelihood of deliberate contamination of food, from the raw materials to product distribution. Governments should support industry in strengthening existing food safety management systems, to include consideration of deliberate contamination. Governments also have a role in promoting preventive food safety, through various voluntary and regulatory mechanisms4. It is important to note that a number of the preventive activities described in this paper relate to 'industrialized' food production systems. Although industrialized production probably also present the most likely targets for intentional contamination, it is very likely that more traditional production systems, including systems with short distribution lines, present problems that need separate consideration.
Food can be contaminated deliberately by chemical, biological or radionuclear agents at any point in the food chain. Food safety management programmes offer opportunities for the prevention, detection and control of food sabotage. Understanding the relationships between the production system, ingredients, people, utensils, equipment and machinery can help in identifying where critical failures of the system might occur. Methods of sabotage and the extent of a threat might be identified as a part of this analysis and would provide the basis for a risk analysis. Typical food safety management programmes within the food industry, include good agricultural and manufacturing practices and ‘hazard analysis and critical control point’ (HACCP) systems. Newer systems based on a scientific assessment of the risk are now increasingly being used to develop risk reduction options along the food supply continuum from farm to table.
Governments should work closely with industry to incorporate prevention and response to intentional contamination into food safety management programmes. Not all countries have the infrastructure needed to assist industry, especially small and less developed businesses, to apply such programmes throughout the food production, processing and preparation continuum. Capacity building for such competence is vital for the prevention of both intentional and unintentional contamination of food. The generic actions that may be taken by governments to assist industry in this respect include:
Prevention of intentional contamination does not always require high technology or great expense. Increased awareness of the problem and enhanced vigilance are among the effective measures that can be taken. Awareness can be heightened by auditing food safety management programmes. In the event of an incident, information from early surveillance could be shared with the food industry to facilitate prompt action to address consumer concerns and contain and mitigate the threat.
The knowledge and capacity to prevent deliberate sabotage of food lies mainly with the food industry and must be applied throughout the food chain. Potential contamination with chemical and biological agents and radionuclear materials and interruption of food supplies need to be considered in the development and review of food safety management programmes, which may vary from rudimentary to well developed.
Opportunities for deliberate contamination of food can be minimized by increasing the security for both people and premises. All segments of the food industry should consider improving security and response plans for their establishments. For example, sources of raw materials and storage facilities and transport systems could be safeguarded; access to all critical areas in production, processing, transport and storage could be controlled and documented to minimize opportunities for contamination.
Regarding personnel, employers could consider screening their staff to ensure that their qualifications and background are compatible with their work and responsibilities. Sanitation, maintenance and inspection workers, who have access to critical areas, could also be screened from a security perspective. Appropriate mechanisms could be established to allow staff to report suspicious behaviour and activities.
While it is impossible to describe all the possible scenarios for food sabotage, WHO has developed basic guidance for the food industry for strengthening food safety management programmes to prevent intentional contamination of food with harmful agents5. This guidance offers a range of options that should be considered by industry, taking into account available resources and the perceived threat. Plausible risks need to be considered at every point in the food chain to ensure the safety of the food produced. A number of useful documents prepared by certain countries6,7,8 and industries9 offer examples and guidance for analysing risks in the production and processing of specific foods. Not all of these documents will be applicable in their entirety to smaller, developing businesses, but the general principles of assessing vulnerability apply across all businesses and sectors10,11.
While preventive measures are essential, the opportunities for intentional contamination of food are just too numerous to ever be able to completely prevent such incidents. However, effective and rapid monitoring and surveillance programmes coupled with preparedness planning can do much to respond to such threats. Many governments have, or are developing, food safety infrastructures to ensure that food produced for both domestic consumption and export meets acceptable safety standards. Strengthening national food safety programmes requires that national policies and resources to support the infrastructure are in place and that food legislation, food contamination monitoring laboratories, food inspection, foodborne disease surveillance, education and training are adequate and up to date. Above all, the possibility of intentional contamination needs to be an integral part of safety considerations.
While most of the knowledge and capacity to prevent food safety emergencies lies within the food industry, governments have a lead responsibility for detecting and responding to actual or threatened food contamination incidents as well as other food safety emergencies. In the event of an intentional food safety emergency, the potential consequences to public health, the economy and social or political stability must be managed by an effective, rapid emergency response system, at all levels. The effectiveness of a response depends to a great extent on preparedness plans that are developed and implemented long before any event occurs. Public health preparedness planning for emergency situations has been considered in some detail in various WHO publications and is therefore not discussed in detail in this document12.
The nature of a preparedness and response system is based on an assessment of specific threats of deliberate food contamination and their priorities in relation to other public health problems. The priorities are determined as part of an assessment of vulnerability performed as part of the development of preparedness plans for intentional contamination. Threats could be ranked from high to low, on the basis of their impact on health and their potential social, economic and political consequences.
Vulnerability is assessed on the basis of the prevailing scientific, economic, political and social circumstances of a country, to measure the extent of a threat and to set priorities for resources. Priorities must be set to ensure that the action taken to deal with the threat is commensurate with the severity of the inherent consequences of the threat. The purpose of an assessment of vulnerability is to identify the properties and potential consequences of deliberate contamination of food by harmful agents, to identify relative priorities and to commit national resources in a proportion consistent with these priorities. Technical experts in food and food safety should participate in any assessment of vulnerability specific for intentional contamination. Information on the toxicology of chemicals and the characteristics of microbial agents is a necessary component of such an assessment, together with an assessment of potential exposure, which will determine the potential impact of the agent.
Response to emergencies caused by intentional contamination of food has common features to emergencies caused by unintentional contamination. Often the two cases cannot be distinguished, especially during the early phases of an outbreak. For these reasons, preparedness plans should include response to both intentional and unintentional incidents. Where preparedness plans already exist food safety emergencies, intentional contamination of food needs to be integrated into existing l plans, making maximum use of existing emergency response infrastructure and resources. The resources and protocols for a medical response, including rapid transport, supplies, personnel and patient evacuation, are an integral part of communicable disease preparedness, and these have been described elsewhere13. A well-designed public health emergency response system should also include the capacity to respond to food contamination incidents. In planning for food safety emergencies, the following points are emphasized:
For incidents involving intentional contamination of food, effective interaction between emergency response and law enforcement components is very important. Preparedness planning may include specific requirements of the criminal justice system, such as a signed chain of custody for any specimens and other evidence.
Preparedness plans should be tested in exercises involving agencies responsible for emergency responses to intentional food contamination. Any new components should be tested for effective response to intentional incidents. Evaluation of the results of real incidents and emergency response exercises should be used to identify the need for further resources, refine the roles of various agencies and their interaction and improve emergency plans.
The performance of surveillance systems for detecting foodborne disease clusters and epidemiological investigations to identify the food and hazardous agent give an indication of the capacity of the system to respond to intentional incidents. Timely response to food emergencies requires effective linkage of preparedness planning and emergency response systems in all relevant agencies. Linkages with food safety authorities are needed to provide specialized support related to an investigation that may involve food. Availability of qualified food safety inspectors and laboratories are important requirements for preparedness. For example, the timely sampling, transport and analysis of suspected foods should be addressed as part of preparedness planning. Countries need to inventory their laboratory capacities for possible threat agents. Rapid testing for unusual agents, such as dioxin and ricin, can be facilitated by international programmes, such as the Global Environment Monitoring System / Food Contamination Monitoring and Assessment Programme (GEMS/Food), which maintains a network of food safety laboratories in over 80 countries around the world.14
Public health preparedness and response systems focus mainly on communicable diseases, and most emergency response systems do not yet include consideration of the use of food as a vehicle for threat agents. Few countries are able to respond rapidly and effectively to intentional food contamination in their current state of development. Food safety emergency response may be initiated by either a plausible threat or an actual act of deliberate contamination of food.
An effective public health response to a deliberate food contamination incident will depend on the timeliness and quality of communication among numerous agencies and sectors, including health services, public health authorities at local and national level, clinicians, infectious disease specialists, laboratories, poison information centres, forensic pathologists, other agencies and organizations and the food industry. An effective emergency response must also be tailored to the circumstance and should include links with law enforcement and intelligence agencies, tracing and food recall systems, risk assessment specialists and the food industry as well as the more traditional sectors of health care providers, laboratories and emergency services.
Linkages between existing national alert and response systems and food safety systems allow effective detection of and response to such incidents. Improved links with food safety agencies will allow access to relevant information about food and about methods and analytical techniques for testing food and harmful agents. Experts in food safety could assess the risks associated with chemicals and microbiological hazards to ensure that the response is proportional to the risk. Identification and recall of affected foods are important features of a food safety emergency response. Tracing information is necessary for estimating the scale of potential exposure and for removing the affected food from sale. It may also assist in a criminal investigation of a food contamination incident. Recalls are usually implemented by the food industry in cooperation with food safety authorities. Quarantine and customs agencies have information about food imports necessary for tracing and recall and can undertake rapid seizure of food at the point of entry. Coverage ‘from farm to fork’ needs to be incorporated into response planning for food safety emergencies, including the intentional contamination of the food supply.
Finally, the recovery of the food supply system needs to be considered as part of a response system. Verification of the effectiveness of the response in removing or otherwise decontaminating the food involved is necessary before relaxing restrictive measures and reassuring consumers of the safety of the food supply. While situations will vary, continued sampling and analysis will likely be a common feature of most recovery scenarios.
Swift and effective communication among all components of an emergency response system is essential and should be included in preparedness planning. Communication with international components, such as Global Outbreak Alert and Response Network (GOARN)15 and the International Food Safety Authorities Network for Emergencies (INFOSAN Emergency),16 should be considered essential in the light of the potential international spread of disease and trade in food. The FAO/WHO Codex Alimentarius Commission has recently provided guidance on the sharing of exchange of information during food safety emergency situations.17 Secure Web-based resources can facilitate communication during an emergency response.
Because perpetrators may sometimes seek to create panic and fear in the population, good communication with the mass media and the public is essential during a food safety emergency and should be included in preparedness planning. Timely press releases and other information should be released to the public to prevent unwarranted speculation and to forestall rumours. Food safety experts with good communication skills are valuable for this purpose. A balanced approach should provide information without unnecessarily increasing anxiety. Cultural aspects should be considered in communications about threats and incident response. An FAO/WHO publication on risk communication for food safety matters provides some guidance on this issue.18 Suggestions for communication during outbreak situations are also available in other WHO publications.19
An effective communication channel should be opened with the relevant food industry to share information with government authorities about intentional contamination incidents. In communicating with the public, some industry bodies have developed protocols for responding to such threats and have formulated model questions and answers for dealing with such situations.
The key to prevention of intentional contamination of food is to promote awareness of this potential threat. Working in cooperation with government, the food industry is in the best position to rapidly address such threats through implementation of basic security and precautionary measures. Government food safety authorities may provide necessary guidance and other coordination functions to assist industry, as in the case of product tracing and recall.
The emergency response to intentional contamination incidents needs to follow detailed and thoroughly tested preparedness plans. The responsibilities of lead agencies, whether they be health agencies responding to a medical emergency, law enforcement agencies responding to criminal acts or food safety authorities responding to a contaminated food, need to be clearly identified as part of the plan. Emergency response plans to food contamination threats require a high degree of cooperation among public health and law enforcement agencies of governments, as well as with the food industry. Food safety agencies can coordinate tracing and food recalls, and generally have well-established links with the food industry to effect rapid removal of unsafe food from circulation. Finally, the recovery phase following an incident should be emphasized to restore availability of safe food to the market as soon as possible. Again, a close working relationship with the food industry is necessary to reassure consumers that the incident has been resolved.
A few developed countries have taken significant steps in safeguarding their food supplies against intentional contamination. Many developing countries are only beginning to take action. However, even with the best precautions in place, no country is immune to public health emergencies caused by unsafe food considering the potential for natural, accidental and intentional contamination. With the globalization of the world's food supply, coordination of efforts internationally is increasingly seen as vital to the rapid detection of incidents, identification of causative agents and foods and the prompt and effective response to contain and mitigate any adverse health and economic effects. The management of threats to food safety in the Twenty-first Century, including intentional contamination, requires countries to maintain sensitive and rapid alert systems, detailed and well-tested preparedness plans and rapid and effective emergency response systems with links to relevant international networks.
Communication and sharing information through internationally coordinated networks will provide timely risk assessment and management. Coordination with WHO, FAO and other international and regional organizations regarding incidents involving intentional contamination should be considered as an integral part of strengthening of national systems to respond to all food safety emergencies. In particular, countries should actively participate in the INFOSAN Emergency as the first step establishing international communications and building essential capabilities to deal with this problem. WHO is now in the process of preparing a handbook for INFOSAN Emergency contact points that will provide practical guidance in preparedness and response to intentional contamination incidents.
Finally, it is important to recognize that while countries must address all plausible threats to their food production systems posed by intentional contamination, resources for more traditional foodborne disease outbreaks, including the so-called "silent epidemic" consisting of large numbers of sporadic cases, need to be maintained. These traditional outbreaks are presently causing major problems for health and development, especially in developing countries. This again emphasizes the need for ensuring that prevention and response systems in food safety be considered in a fully integrated manner, irrespective of the source of the outbreak.
1 Resolution 53.15, Fifty-fifth World Health Assembly, WHO, Geneva (18 May 2002)
2 Terrorist Threats to Food: Guidance for Establishing and Strengthening Prevention and Response Systems, which can be downloaded at http://www.who.int/foodsafety/publications/fs_management/terrorism/en/ Copies are also available on request to the WHO Food Safety Department, CH-1211 Geneva 27, Switzerland
3 WHO global strategy for food safety (available in the six official languages of WHO) http://www.who.int/foodsafety/publications/general/global_strategy/en/ (2002)
4 Assuring food safety and quality. Guidelines for strengthening a national food control systems. Food and Nutrition Paper 76, FAO on behalf of FAO/WHO, Rome (2003)
5 Specific measures for consideration by the food industry. Appendix to Terrorist Threats to Food: Guidance for Establishing and Strengthening Prevention and Response Systems, Food Safety Department, WHO Geneva (2002)
6 Notice to food processors and distributors, suggestions for improving security. Canadian Food Inspection Agency, http://www.inspection.gc.ca/english/ops/secur/protrae.shtml.
7 Notice to food retailers, suggestions for improving security. Canadian Food Inspection Agency. http://www.inspection.gc.ca/english/ops/secur/retdete.shtml.
8 Notice to livestock operations, suggestions for improving security. Canadian Food Inspection Agency. http://www.inspection.gc.ca/english/ops/secur/livebete.shtml-
9 Food safety and security: operational risk management systems approach (ORM). Food and Drug Administration, Center for Food Safety and Applied Nutrition, Washington, DC (November 2001)
10 Guidance for industry, food producers, processors, transporters, and retailers: food security preventive measures guidance. Food and Drug Administration, Center for Food Safety and Applied Nutrition, Washington, DC ( 2002) http://www.cfsan.fda.gov/~dms/secguid.html.
11 Guidance for industry, importers and filers: food security preventive measures guidance. Food and Drug Administration, Center for Food Safety and Applied Nutrition, Washington, DC (2002) http://www.cfsan.fda.gov/~dms/secguid2.html.
12 Health sector emergency preparedness guide, WHO (1998), http://www.who.int/disasters.
13 Public health preparedness for biological terrorism in the USA by A.S. Khan, Morse and S. Lillibridge, Lancet, 356:1179–82 (2000)
14 http://www.who.int/foodsafety/chem/gems/en/
15 http://www.who.int/csr/outbreaknetwork/en/
16 http://www.who.int/foodsafety/fs_management/infosan/en/
17 ftp://ftp.fao.org/codex/reports/al27_41e_advance.pdf
18 The application of risk communication to food standards and safety matters. Report of a joint FAO/WHO expert consultation. Food and Nutrition Paper 70, FAO, Rome (1999)
19 http://www.who.int/emc-documents/tse/docs/whocdscsraph20018.pdf