tion in large, monoculture farms; the concentration of commodity food-processing in large centralized facilities; and a tendency to adhere to rigidly defined patterns of quality control that may not detect unanticipated contaminants.

Food production and processing offer many potential avenues for terrorist attack. Protection of the U.S. food supply is generally the responsibility of the Food and Drug Administration (FDA), which is progressively replacing old quality control (QC) and quality assurance (QA) programs with a new methodology called hazard analysis and critical control point (HACCP).9 In earlier QA/QC methods, samples were drawn from food lots according to a statistical protocol. These lots were then held, pending the results of testing, and released only after each lot passed all tests. HACCP is a system designed to enhance food safety by identifying sources of possible contamination and specifying ways to control them—through changes in source, process, procedure, or structure. HACCP was designed to prevent unintentional contamination, however, and not to deal with intentional contamination. Extending the existing HACCP program so that it can be effective against deliberate tampering will require a multidisciplinary reassessment.

Recommendation 4.10: The FDA should act promptly to extend hazard analysis and critical control point (HACCP) methodology to enable it to deal effectively with deliberate contamination of the food supply.

Primary food-production facilities need to be secured from contamination with toxic or infectious agents, but only to an extent commensurate with the hazard—that is, the number of people that might be involved, their likely rate of consumption of the contaminated food, and the time delay from contamination to consumption should all be considered. The time delay is especially important, because contaminated foods consumed slowly over time (such as canned goods) would cause few illnesses or deaths per unit time. Thus, there would be an opportunity to determine the source of the contamination and the lots affected and to accomplish a recall—thereby reducing the consequences of such an attack. By contrast, foods consumed quickly (such as milk, bread, and fresh meats and vegetables) would be less effectively removed by recall, so their production facilities require more security.

Recommendation 4.11: The FDA should develop criteria for quantifying hazards in order to define the level of risk for various kinds of food-processing facilities. The results could then be used to determine the minimal level of protection required for making each type of facility secure.

9  

So far, HACCP regulations have been established only for juice (FDA, 2002a) and seafood products (FDA, 2001); those for dairy products are voluntary (FDA, 2002b). In addition, HACCP guidelines have been issued for retail food (FDA, 1998).



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