Food Defense Tabletop Exercise: Schools as a Target

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Food Defense Tabletop Exercise: Schools as a Target Presented by Douglas Conwell Instructor National Food Service Management Institute 1

What Is Food Defense? FOOD DEFENSE is defined as the protection of food products from intentional adulteration by biological, chemical, physical or radiological agents In contrast, FOOD SAFETY is defined as the protection of food products from unintentional contamination by agents 2

Why Target the NSLP? NSLP offers: Vulnerable population Major emotional impact of harming children Very large numbers of servings per day Very large batches of single food dispensed in any given day Transportation of foods Approximately 1/3 of the U.S. population attends, works for, or has children in schools

Who? Terrorists Activists Disgruntled insiders Others? 4

How? They can choose: A contaminant A food A place 5

FDA Vulnerable Foods Infant formula Breaded food Baby food Milk Yogurt Ice cream Soft drinks Water, bottled Produce Canned food Honey Peanut butter Seafood, cooked Deli salad Fruit juice Flour Food Defense: FDA s Role in Protecting America s Food Supply; International Symposium on Agroterrorism; May 3, 2005; LeeAnne Jackson, PhD; FDA

Where Are We Vulnerable? Opportunity for attack at several levels Crops Livestock Processing Distribution Storage Transportation Foodservice

Central Kitchens as a Target 4 factors make certain operations a more likely target: Large Batches Uniform Mixing Short Shelf-Life Easy Access

Central Kitchen Vulnerabilities High-risk areas in Central Kitchen operation: Transport Ingredients Measuring liquid and dry Mixing and Cooking large batch Storage Dry Cooler Freezer

Highlights: Central Kitchen Counter Measures Dual control 2 people always present Retrofit open systems (kettles, mixers) Restrict access in critical areas; secure when not in use Develop Policies and Procedures

Warehouse Vulnerabilities Personnel Receiving Storage/Access

Counter Measures: Personnel Screening Daily work schedules Identification Training Unusual behavior

Counter Measures: Receiving Request locked and sealed vehicles/containers Look for evidence of tampering or counterfeiting Reject suspect food Establish pick-up and delivery schedules

Counter Measures: Storage/Access Establish product tracking procedures Secure and limit facility access Investigate missing or extra stock/chemicals Secure hazardous chemicals

We All Have a Part in Your Part: Food Defense Train Plan Drill Repeat

Train Food Defense Training: Include food defense in food safety and facilities security training Heighten employee awareness Be proactive rather than reactive ALERT and FIRST - FDA materials 16

FIRST Initiative for front line staff Follow company food defense plans and procedures Inspect your work area and surrounding areas Recognize anything out of the ordinary Secure all ingredients, supplies, and finished product Tell management if you notice anything unusual or suspicious

Plan Components of a food defense plan: Assessment of operation Identification of strategies Implementation Coordination with state/county/district Includes training schedule and drills or tabletop exercises 19

Definition of Tabletop Exercise (TTX) Tabletop Exercise (TTX)--A tabletop exercise involves key personnel discussing simulated scenarios in an informal setting. TTXs can be used to assess plans, policies, and procedures.* *https://hseep.dhs.gov/support/hseep_101/pdf 20

Drill Why Conduct a Table Top Exercise (TTX)? Dispels the myth It can t happen here Provides good first step to exercise plans and identify strengths and gaps Defines stakeholder roles and responsibilities for food safety/food defense Establishes your contacts in the event of a real incident 21

What is the TTX Package? A turn-key TTX package that States or districts can use to conduct a TTX concerning food contamination in schools Compliant with Department of Homeland Security requirements so grant funding could be sought from DHS to conduct the exercise Availability to be determined 22

Terrific Town School District Food Defense Activity

Terrific Town School District 26 schools in the district 15,000 students enrolled NSLP participation (avg) = 12,150 24

Week 1 Current Status Week 1 absenteeism in Terrific Town school district including students, teachers and food service staff. Symptoms: nausea, vomiting, diarrhea Total number ill = 35

Week 1 Discussion 1. What do you do and who do you report to regarding this level of absenteeism? 2. Are there existing plans, policies, or procedures that might be triggered by an increased level of absenteeism?

Week 2 Current Status 9 deaths of ill children Total number ill = 880 Food histories point to food served in school Food samples are being tested Parents stop sending children to school

Week 2 Discussion 1. Do you have plans that cover handling a large foodborne illness outbreak? 2. What actions do you take? What other state/local agencies are involved? 3. Who is the lead spokesperson and who decides what the key message is?

Week 3 Current Status 53 deaths of children or adults who had been ill with the symptoms Total number ill = 2118 Schools in the district are closed by the superintendent A terrorist group claims responsibility for contaminating a food product shipped to schools CDC confirms a substance found in the suspect food product was an agent that could cause death.

Week 3 Discussion 1. Do you have plans, policies, and procedures to respond to food defense issues? How are activities coordinated? Are law enforcement agencies involved? 2. What actions are taken to track, locate and recall food products? Who is involved? 3. Where does the community go for information? What information is released? How is that determined and coordinated? Authorized?

Week 10 Current Status Ten weeks post-event 176 deaths (5% of the 3,530 who fell ill) Suspects arrested No new cases, many still hospitalized Several hundred suffered permanent damage to their respiratory and nervous system Dozens remain on respirators and in longterm care facilities

Week 10 Discussion 1. What actions are taken to recover from the incident? What has to occur to allow the schools to re-open and provide food again? 2. What was the impact on your department? What did this do to staffing, budget, supplies, etc.? 3. What triggers local, state or federal support for recovery operations? What support is available? 4. How can you regain the confidence of the community?

Creating Your Own Food Defense Plan Creating Your School Food Defense Plan template on the USDA/FNS website 33

FNS Resources http://www.fns.usda.gov/fns/food_safety.htm 34

Four Steps to Creating Your School Food Defense Plan Step 1 Assess School Food Defense Measures Step 2 Assemble the Pieces Step 3 Complete Your Plan Step 4 Use and Maintain Your Plan 35

Step 1 Assess School Food Defense Measures a) Outside Security What food defense measures does your school have in place for the exterior of the building? 36

The school grounds and/or buildings are secured (e.g., by locks, seals, or sensors) during the school day to prevent entry by unauthorized persons through: Outside doors and gates Windows Roof openings Vent openings The school grounds and/or buildings are secured (e.g., by locks, seals, or sensors) after hours and on weekends to prevent entry by unauthorized persons through: Outside doors and gates Windows Roof openings Vent openings Access to external refrigeration and/or storage facilities for school nutrition programs is restricted to designated employees only? Access to the following systems or controls for the following systems is restricted, controlled, or monitored (e.g., by locked door/gate or limiting access to designated employees, seals, equipped with a sensor device) to prevent access by unauthorized persons: Heating, ventilation and A/C systems Propane Gas/ Natural Gas Water systems Electricity Chemical/disinfection supplies and systems 37 The school has procedures for all visitors.

Step 1 Assess School Food Defense Measures (con t) b) Inside Security What food defense measures does your school or school foodservice operation have in place inside the building? 38

There is an emergency lighting system in the school. Yes No N/A The school has monitored security cameras. The school has an emergency alert system that is tested regularly. The locations of controls for emergency alert systems are clearly marked. All restricted areas (i.e., areas where only authorized employees have access) are clearly marked. Visitors are restricted to specific areas or accompanied by school personnel. Maintain inventory of keys to secured/sensitive areas of the school. Emergency exits are alarmed and self-locking doors are only able to be opened from the inside per local and state fire and building codes. The agency or authority that would serve as a first responder(s) based on specific emergency situations has been determined. There are procedures for communicating with students, parents, and with the media when necessary (for example, notices of incidents or a press release). There is a list of emergency contact information for local, state, and federal government homeland security authorities and public health officials. Someone in the school has called each emergency contact to verify they are the correct point of contact. The contact information is reviewed and updated regularly. There are procedures for notifying appropriate law enforcement and public health officials when our school receives a threat about food contamination, as well as when a member of the school community observes or suspects 39

Step 1 Assess School Food Defense Measures (con t) c) Foodservice Operations: Foodservice Areas Foodservice Storage Food and Supplies Hazardous Materials/Chemicals Shipping/Receiving Security Personnel Security and Training 40

Four Steps to Creating Your School Food Defense Plan Step 1 Assess School Food Defense Measures Step 2 Assemble the Pieces Step 3 Complete Your Plan Step 4 Use and Maintain Your Plan 41

Wrap-Up (Hotwash) Each group will report on the following: What surprises did you learn today? What have you learned about your own district? 42

In conclusion To protect vulnerable populations: Add food defense to your professional tool box

Questions or to Discuss Conducting an Exercise in Your District National Food Service Management Institute The University of Mississippi 6 Jeanette Phillips Drive P.O. Drawer 188 University, MS 38677-0188 Telephone: (662) 915-7658 or toll free at (800) 321-3054 www.nfsmi.org or Marion Hinners, MS Food Safety Specialist Office of Food Safety, USDA Food and Nutrition Service Alexandria, VA (703) 305-2647 marion.hinners@fns.usda.gov 44

Thank you! Douglas Conwell Food Defense Instructor National Food Service Management Institute 45