Disaster Planning and Response for Food Processors

Disaster, the word alone congers images of your facility in the worst possible condition, people not understanding what happened, knowing how to respond to the event, what to tell the media, if anything, and more. But it doesn’t have to be that way if you have an emergency plan in place. What is an emergency versus a disaster? Well, by definition a disaster is any event causing great harm or damage, a catastrophe; while an emergency is an occurrence demanding immediate actions. Or more importantly an emergency has a plan to respond and a disaster is a situation with no forethought or plan to cover it.

When it comes to emergency planning, you need to involve as many people as possible in framing not only the type and scope of an emergency but also in building a comprehensive plan of action for each of the situations that may arise. There is nothing outside the realm of possible scenarios for an emergency plan - from loss of a utility, to interruption in the supply chain, to labor disruption through tampering, bad weather or terrorism. If you want to plan for a meteor landing in the middle of your operation, which is up to you, you need to remember that a plan without a response falls into the category of disaster.

Natural Disasters

Natural disasters such as hurricanes, floods, and earthquakes, often impact wide geographic areas and therefore can overwhelm local and State response personnel and agencies. This leaves individuals and businesses on their own to deal with the immediate aftermath. Businesses wanting to reopen after such disasters must have comprehensive plans in place to address, at a minimum, the following primary areas: damaged food products, physical facilities, pest control, equipment, food source, and employees.

Damaged food products

The simplest form of advice for damaged food products, following a disaster, is “When in doubt, throw it out”. All food products that were submerged in flood waters must be thrown out. The one exception is canned food where the cans are hermetically sealed and no damage has occurred to the can’s seal. The cans must be undamaged, commercially prepared foods, in all-metal cans or retort pouches. Remove labels that can come off, thoroughly wash the cans, rinse them, and then disinfect them with a sanitizing solution consisting of 1 tablespoon of bleach per gallon of potable water. Finally, re-label containers that had the labels removed, including the expiration date, with a permanent marker.

Do not salvage food packed in containers with screw-caps, snap-lids, crimped-caps (soda pop bottles), twist-caps, flip-top, snap-open, and similar type closures that have been in plastic, paper, cardboard, cloth, and similar containers that have been submerged in water or have water damaged packaging.

Condemned food items must be safely disposed of in a manner consistent with federal, state, and local solid waste storage, transportation, and disposal regulations. These products must not reappear as damaged or salvaged merchandise for human consumption.

Physical Facilities & Equipment

When possible all salvageable structural surfaces and equipment should be thoroughly decontaminated and sanitized with procedures using chemical sanitization, e.g., chlorine bleach at a concentration of 100-200 ppm (1 tablespoon of bleach in 1 gallon of potable water), Quaternary Ammonium at a concentration of 200 ppm, or other approved sanitizers. When you decontaminate, do so in a manner that eliminates any harmful microorganisms, chemical residues, or filth that could pose a food safety risk.

Mold contamination is also another concern. Structural components of the building (e.g., walls, piping, ceiling, and HVAC system/ventilation systems) affected by flood waters or other damage from the hurricane, should be cleaned, repaired, and disinfected, where possible. Remove and destroy wall board that has been water damaged. Cement walls that have mold damage can be reconditioned.

Pest Control

Ensure that any pests that may have entered the facility are no longer present. Remove dead pests and sanitize any food-contact surfaces that have come in contact with pests. Seal all openings into the facility to prevent future entry of pests. Dispose of contaminated or spoiled foods products in closed containers for removal to prevent rodent and fly food sources and harborage.

Food Source (Restocking)

As is always the case, disaster or not, food products should only be received from licensed and approved sources.

Employees

When disasters strike, understand that your employees are most likely affected in their personal lives too. They will have family responsibilities and additional stress that should be considered. There will be limitations in staffing and scheduling, so it would be wise not to put all areas back into production, scaling production based on the number and type of employees available. Full production may be started when there is an adequate number of trained employees to staff each area of the operation.

As under normal conditions employees must use proper hygienic practices. Alcohol hand gels may only be used after handwashing. Alcohol hand gels are ineffective against germs on soiled hands and are therefore not a substitute for soap and water handwashing.

Food Security

Prior to 2001, food security and food safety were viewed as the same. Large food manufacturers were geared to protect their assets: materials, physical plants, employees, information systems and operations. Shipments, incoming and outgoing, were locked to protect from theft. Plants had fences and gates with limited access, employees had identification systems or security guards to check identities, computers were limited in use both inside operations and even offices, formulas, product development and equipment designs were not widely distributed. Restaurants and food service operations monitored the comings and goings of outside vendors, locked doors, controlled access to the kitchen areas and never released product formulas.

Since the events of September 11, all food manufacturers had to begin gearing up, thinking about persons that wanted to do malicious acts to injure or kill large numbers of people from a single incident or to damage an entire brand by getting media attention for a type of food. Nobody can afford to be reactive any more. There is no safety in saying that 'we didn’t know'. The bar is higher now and you cannot think it sufficient to say that you have taken all of the steps toward protecting against those issues as in the past.

Most people focus on the issue of bio-terrorism and when food is brought into the discussion it will be the intentional incorporation of a pathogen into a food product. The first documented bio-terroristic action in the United States targeted at food was in Oregon in 1984 by the Rajneeshpuram who wanted to incapacitate the voting population of the town in order to further their zoning agenda. Over 750 individuals became ill with Salmonella. Two perpetrators were indicted, convicted and spent 29 months in Federal prison. Since 9/11, the anthrax-laced envelopes and assessments of our vulnerability in our food and water supplies a rule-out of bio-terrorism is somewhat standard practice in the investigation of some types of food and water-borne disease outbreaks. The FBI does respond when there is suspicion by a local or state department of health and/or agriculture or another federal agency that bio-terrorism is suspected.

When we think of bio-terrorism, immediately the infliction of disease by a biological agent is conjured up. However, of equal importance is that of agri-terrorism against either our crops or our animals that are raised for food. Clearly there is concern, especially in the important areas such as the Salinas Valley in California, if someone were to spray our fruit and vegetable crops with a plant pathogen that would cause the crop to fail.

Image courtesy USDA

What if the plane was spraying a plant or human pathogen rather than insecticide?

Equally of concern would be the introduction of an animal pathogen such as the putative agent of Foot and Mouth Disease, a Picornavirus which basically is not considered transmissible to humans, however, it is extraordinarily contagious from animal to animal. It is estimated that pigs excrete between 10 million and 10 billion infective doses per day. The incubation period can be as short as 26 to 36 hours with clinical signs and symptoms appearing in an animal as early as 12 hours after the initial exposure. Illness in an exposed animal is close to 100% in susceptible domestic animals and mortality is extraordinarily high, especially in younger animals.

Image courtesy USDA

Foot and Mouth Disease- Bovine Tongue

However, with the manner by which animals are breed, kept in feed lots and transported to slaughter during an incubation period an animal could traverse numerous states and infect large populations of other animals. In both of these examples of agri-terrorism the cost to human health would be negligible but the cost from economic and nutritional perspectives could be disastrous. Therefore, bio-security needs to be in place literally from the farm to the fork.

Simply adding a biological or chemical agent that looks like any ordinary ingredient could contaminate our products. We start with the incoming ingredients that show up in bulk, bag or box. Seals on trucks are a must for large manufacturing or matching the invoice to the actual products that show up on the dock or the back door. Open bags, boxes, missing seals for bulk deliveries, improper invoices could all be signs of product tampering and should be reported immediately to supervision. Under no circumstances should the employee alone determine that the product is okay to be used, this is all part of the emergency plan pre-incident procedures that needs to be as natural as breathing to the entire staff.

Another layer of defense relates to vendors, visitors and even auditors that would gain access to some of the most sensitive areas of the facility. People that do not belong in an area or people that you have not seen in the past, or even those that have been in the facility in the past but are no longer in the employ of the contractors that you normally use should never be in any area of the facility without being accompanied by a trusted staff member. Furthermore, people trying to sneak into the facility, people asking questions specifically about the facility that do not work there in order to get information that only the employees need to know are to be denied an entrance and, if necessary, dealt with from a security perspective. These people should never get past the guard gate or, if there is no guard gate, the vestibule of a secured outer office.

Let’s not limit suspicion to people that are outside the normal staff. Note your employees that are now acting suspicious, somehow different from the way they would normally act; unrest among the employees or labor tensions toward management and/or people who are not being compliant with their assigned tasks and/or job descriptions. Heed early warnings and err on the side of caution. We need to be aware of any changes in the normal actions and reactions of employees to the everyday occurrences, this could be the evidence we need to put our action plans into motion and protect someone else.

In summation, we do have vulnerability in our food supply from farm to fork whether it be from a natural disaster such as a hurricane, a drought or a derailed tanker of toxic materials as well as from those who are trying to do us personal, societal or economic damage via terrorism. Every single employee, every single manager and every single owner of every single company is on the front lines of food defense and food safety.

Contact EHA Consulting Group today for more information about how we can assist your company.