United States Department of Agriculture Food Defense Preparedness

United States Department of Agriculture Food Defense Preparedness and Recall Exercise Package (FD-PREP) START July 2017 Food Safety and Inspection Service 1

Welcome • Thank you for meeting to conduct this Food Defense and Recall Preparedness Scenario-Based Exercise! • Your participation is critical to the success of the exercise and the safety of our food supply. 2

Overview • This exercise tool contains four scenarios. • Each scenario starts with a brief introduction describing the situation. • Additional information is provided as the events unfold (called “injects”). • After each inject, the facilitator will lead group discussions about what is happening in the scenario. • Tip: Keep your discussions as realistic to the scenarios as you can! 3

Objectives The intended purpose of this Scenario-Based Exercise Tool is to: Increase awareness of the importance of protecting the food supply from intentional adulteration Ensure that food defense and recall preparedness practices and mitigation strategies are effective, documented, and understood Test and maintain effective written recall procedures 4

Participant Responsibilities As a participant in this exercise, you should: • Have working knowledge of your establishment’s standard operating procedures, plans, policies, and practices. • Discuss the events as they unfold during the exercise. • Share your relevant experiences based on the discussion questions. 5

Exercise Structure • In order to complete the exercise in the time allowed, you will need to accept several assumptions. • You should assume that the scenario could really happen and that the events occur as presented (i. e. , play along). • Note: • Timelines may be shortened or unrealistic. • Textboxes will appear to capture answers to the questions posed. • The exercise should reflect the current FSIS rules, regulations, policies, and procedures. Don’t fight the scenario! 6

Welcome to Scenario 1 Settling the Score 7

Settling the Score Let’s Begin! 8

Settling the Score Day 1 - Contamination • • • You receive a call from your largest customer, a grocery chain with five stores. Your customer tells you that, upon visual inspection, one of the butchers found a problem with the product received from your company this morning. The customer provides the lot number and, as a precaution, has taken your product off the shelf. 9

Settling the Score Day 1 - Contamination • Your largest customer found a problem with the product received from your company this morning. • The customer has taken your product off the shelf. Whom do you inform? Would you discuss this with FSIS? 10

Settling the Score Day 1 - Contamination • Your largest customer found a problem with the product received from your company this morning. • The customer has taken your product off the shelf. Do you have a standard operating procedure or protocol for this situation? 11

Settling the Score Day 1 - Contamination • Your largest customer found a problem with the product received from your company this morning. • The customer has taken your product off the shelf. What actions will you take for other customers who may have received the same product? 12

Settling the Score Day 2 - Escalation • Media is reporting that an unusually high number of patients with gastrointestinal illnesses were admitted to area hospitals overnight. • A number of your employees are among those admitted. 13

Settling the Score Day 2 - Escalation • Media is reporting that an unusually high number of patients with gastrointestinal illnesses were admitted to area hospitals overnight. • A number of your employees are among those admitted. What actions do you take? 14

Settling the Score Day 5 - Inject An epidemiological study (looks at patterns of disease) indicates that a product you produce may be linked to the recent illnesses reported. 15

Settling the Score Day 5 - Inject An epidemiological study (looks at patterns of disease) indicates that a product you produce may be linked to the recent illnesses reported. What actions do you take? If your product is involved, would you know which of your customers received that product during the past 5 days? 16

Settling the Score Day 5 - Investigation • Public health officials and FSIS representatives have started investigating if your product is involved in the outbreak. • Local media is requesting an interview with your plant management about the ongoing public health investigation. 17

Settling the Score Day 5 - Investigation • Public health officials and FSIS representatives have started investigating if your product is involved in the outbreak. • Local media is requesting interviews on the situation. How will you manage and communicate about this incident? Who is authorized to talk to media or law enforcement? 18

Settling the Score Day 5 - Investigation • Public health officials and FSIS representatives have started investigating if your product is involved in the outbreak. • Local media is requesting interviews on the situation. Would you be able to recall product if it is determined to be the source of these illnesses? 19

Settling the Score Day 12 - Inject THE LAB RESULTS ARE IN! • A known pesticide is present in retained samples from your finished product and processing equipment. • The pesticide is used in the management of rodents and is highly toxic and unaffected by cooking. • The pesticide is not used in your facility. • FSIS officials have suspended processing operations and product 20

Settling the Score Day 12 - Inject • A known pesticide is present in retained samples from your finished product and processing equipment. What actions would you take? Do you have a written recall plan in place? • The pesticide is used in the management of rodents and is highly toxic and unaffected by cooking. • The pesticide is not used in your facility. • FSIS officials have suspended processing operations and product shipments from your facility. 21

Settling the Score Day 12 - Inject • A known pesticide is present in retained samples from your finished product and processing equipment. • The pesticide is used in the management of rodents and is highly toxic and unaffected by cooking. INJECT Your facility and your customer’s facility have been declared crime scenes by local and Federal authorities. What are the impacts to your company? Do you have established relationships with local or Federal law enforcement in your area? • The pesticide is not used in your facility. • FSIS officials have suspended processing operations and product shipments from your facility. 22

Settling the Score Day 13 – The Impact Your facility has received significant media attention as a result of the investigation. 23

Settling the Score Day 13 – The Impact Your facility has received significant media attention as a result of the investigation. What is the message to employees? To the media? 24

Settling the Score Day 17 – The Impact Customers have ceased doing business with your company and sales have dropped dramatically! 25

Settling the Score Day 17 – The Impact Customers have ceased doing business with your company and sales have dropped dramatically! Do your recall procedures include procedures to store or destroy large amounts of returned product? 26

Settling the Score Day 21 - Outcome The investigation reveals that a previously terminated employee gained access to your facility and adulterated the product on purpose. 27

Settling the Score Day 21 - Outcome The investigation reveals that a previously terminated employee gained access to your facility and adulterated the product on purpose. How could someone have gained unauthorized access to your facility? 28

Settling the Score Day 21 - Outcome The investigation reveals that a previously terminated employee gained access to your facility and adulterated the product on purpose. What security measures could you have taken to avoid this situation? Are there areas where access cannot be limited? 29

Settling the Score Day 21 - Outcome The investigation reveals that a previously terminated employee gained access to your facility and adulterated the product on purpose. Do you perform background checks or other forms of screening on potential employees? 30

Settling the Score Day 21 - Outcome The investigation reveals that a previously terminated employee gained access to your facility and adulterated the product on purpose. Do background check procedures also apply to temporary employees, contractors, and others who regularly enter your facility? 31

Settling the Score What Did We Learn Today? • • • Discuss the following issues in your group: Does our food defense plan prepare us to respond to an intentional adulteration incident? Are we prepared to implement a recall if necessary? What are the major issues involved in responding to such an incident? What are some new protocols we might consider adopting? How can we build on this exercise in the future? 32

Settling the Score Lessons Learned Implementing a food defense plan can help you think through and improve your hiring practices and monitor for suspicious behavior. Having written recall procedures can help you make good decisions quickly about which products to recall. Preparing key contact information and testing it in advance can help you in any food defense or recall incident. Testing your written recall procedures can give you confidence in recovering your product if the need arises. 33

Settling the Score After Action Report • Your facilitator and scribe will work on this following the exercise. – They may ask you for some thoughts now or in the days ahead. • This in an internal/confidential document only for the establishment’s own use. • Again, please keep this information confidential. 34

Settling the Score Additional Resources Food Defense Resources • FSIS General Food Defense Plan • Additional FSIS Web-Based Resources • Food and Drug Administration (FDA) Food Defense Tools & Educational Materials • The Food Protection and Defense Institute (FPDI) is a research consortium that looks at our Nation’s food system with respect to the vulnerabilities of attack through intentional adulteration with biological or chemical agents Recall Resources • FSIS Directive 8080. 1 Recall of Meat and Poultry Products • FSIS Final Rule for Written Recall Procedures. Federal Register, Vol. 77, No. 89, Tuesday May 8, 2012, pages 26929– 26937 • USDA “How to Develop a Meat and Poultry Product Recall Plan. ” Small Plant News Guidebook Series. Sep 2015 35

Settling the Score Thank you! For additional resources, and to provide feedback e-mail fooddefense@fsis. usda. gov or visit http: //www. fsis. usda. gov/fooddefense