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People that have been working with Food Defense will notice some things that they have previously focused on that are missing from the proposed rule for intentional contamination. In this post we will discuss one of them.
The explanation of the proposed rule uses the term "terrorist attack" throughout and clarifies that it is predominantly focused on preventing that type of attack which could result in the largest possible consequence to human health.
In the recent past, training materials from the FDA have discussed multiple additional vectors from which an intentional contamination might be made. Those include disgruntled employees, angry competitors and economically motivated adulteration.
While the focus after 9/11 was on a potential terrorist attack, recent commentary seems to indicate that acts of disgruntled employees, while potentially smaller in scope, are far more likely and therefore worthy of additional attention. In a similar way, concern for economically motivated adulteration has increased as actual events in recent years have garnered global attention.
The proposed rule all but omits all of these other vectors with its focus on a large scale event like a terrorist attack. This focus on preventing a large-scale attack is a departure from traditional food safety where we have been cautious to avoid even a single illness or death.
The proposed rule does ask for comments regarding economically motivated adulteration, which conceivably could be addressed more directly in the future. The proposed rule also points out (correctly in my opinion) that efforts which reduce the likelihood of a terrorist attack can at least help reduce the risk of attack by a disgruntled employee.
This is a "sea change" in our traditional approach in food safety and occupational safety, where our goal for incidents is zero. It will require some adjustment in our thoughts as we build our food defense programs.