Food Defense and Recall Preparedness:

A Scenario-Based Exercise ToolProcessed Egg Products Scenario

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Welcome (3–5 Minutes)

• Thank you for meeting to conduct this Food Defense Scenario-Based Tool. Your participation is critical to the success of the exercise and the safety of egg products across the industry.

• There will be a brief introduction describing the situation at the beginning of a fictitious incident. Additional information will be provided as the incident unfolds (called “injects”). This will be followed by a discussion and interaction with participants.

• Please introduce yourselves and your normal operational role to one another (if you don’t already know everyone).

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Objectives (1–2 Minutes)

• The intended purpose of this Scenario-Based Tool is to – Increase awareness of the importance of

protecting the food supply from intentional contamination,

– Ensure the Food Defense Plan functions as designed and develop the plan as needed, and

– Understand Recall Procedures as needed.

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Participant Responsibilities (1–2 Minutes)

• Participants should have a working knowledge of their establishment’s standard operating procedures, policies, and practices.

• Participants should discuss the events as they unfold during the exercise, sharing relevant experiences based on the discussion questions.

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Exercise Structure (3–4 Minutes)

• Assumptions:– A number of assumptions and artificialities are

necessary to complete the discussion within the time allotted.

• During this exercise– Timelines may be compressed or artificial.– Participants should assume that the scenario is

plausible and events occur as presented (play along).– The exercise should reflect the current FSIS rules,

regulations, policies, and procedures.

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Let’s Begin

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The Threat (3–5 Minutes)

• A recently terminated employee of your establishment has initiated legal proceedings for unsubstantiated termination and received significant attention from local print and broadcast media.

• Questions: – Are there specific security actions that need to be

initiated? Can you limit access? Are there vulnerabilities where access cannot be limited (e.g., retail store)?

– Should communication activities—internal and external—be initiated in response to the media coverage?

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Day 1 (3–5 Minutes)

• Contamination:– Your largest customer, a bakery mix customer for processed egg

products, calls to inform your company that it has detected a contaminant in the product received from your company this morning.

– As a precaution, the customer has taken the product out of processing.

– Samples are being analyzed locally.

• Questions: – What actions do you take? Whom do you inform?– Do you have a Food Defense Plan or written Recall Procedures in

place? If so, have you activated either plan?– Could you determine which additional customers may have received

the same products from you?– Are there any ingredients/additives in the liquid eggs?

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Day 2 (3–5 Minutes)

• Media is reporting that an unusually high number of patients with bleeding disorders were admitted to area hospitals overnight.

• A number of your employees are among those admitted.

• Questions:– What actions do you take? – Does your Food Defense Plan or any other system such as a

customer complaint program prompt you to evaluate clusters of customer or employee illnesses?

– Is a media spokesperson identified in your Food Defense Plan and written Recall Procedures? If yes, is that person routinely briefed on the situation?

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Day 2 (3–5 Minutes)

• Your customer reports: – Their products have been linked to the outbreak reported in the

media.– Public health officials are on your customer’s site.– All of your customer’s production has been suspended.

• Your employees are questioning the safety of your facility. Several more have called in sick.

• Questions:– What actions would you initiate? Would you investigate? Would you

perform testing and analysis? If so, what tests might you consider?– How do you limit access/exposure to the suspect product and

processing facilities?– Would you consider initiating your Recall Procedures?

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Day 2 (3–5 Minutes)

• Public health officials (accompanied by FSIS and customer representatives) have arrived at your establishment as part of the investigation of your customer’s product.

• Local media is requesting an interview with your plant management about the ongoing public health investigation.

• Questions:– What plans are in place for dealing with and communication

about this incident?– Upon implementing your Recall Procedures, are you able to

recall all product if it is determined to be the source of these illnesses?

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Day 2 (3–5 Minutes)

• After a conclusive on-site investigation, FSIS officials have suspended your processing operations and product shipments from your facility.

• Questions: – What are the impacts to your operations, inventory,

cash flow, insurance, employees, brand image, etc.?– What is the estimated cost of a recall of all your

production of the last several days?

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Day 2 (3–5 Minutes)

• Initial lab results report the presence of a known pesticide used in the management of rodents in retained samples of your finished product and your processing equipment. The pesticide is highly toxic and would survive cooking.– The pesticide is not used in your facility.

• Questions:– Does your Food Defense Plan or written Recall Procedures

reference an effective trace-back procedure to other related products?

– Insurance:• Does your liability insurance cover this incident? • Do you have business interruption insurance that will cover extended

closure? 13

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Day 3 (3–5 Minutes)

• Morning news is reporting two deaths attributed to the apparent contamination.

• Your facility and that of your customer have been declared a crime scene by local and Federal authorities.

• Questions: – Is a communications plan part of your Food Defense Plan and Recall

Procedures? – Does the communications plan cover internal as well as external

stakeholders?– What is the message to employees? To the media? Who delivers the

message?– Have you considered the impact of social networking as a means of

communications? Is this a vulnerability? 14

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Day 3 (3–5 Minutes)

• Customers are refusing delivery of your products already in commerce and are returning their inventory of your products.

• Questions: – Do your Recall Procedures include provisions to

store or destroy large volumes of returned product?

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Day 4 and Beyond (3–5 Minutes)

• The cause of the event was found to be malicious mischief by a disgruntled employee with access to processing equipment and product. After his arrest, he claims to be acting to expose alleged unsafe practices at your plant(s).

• Questions:– Does your Food Defense Plan talk about disgruntled

employees and looking for suspicious behavior?– What are your hiring practices? – Are temporary employees subject to the same

restrictions as permanent employees?16

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What did we learn today?

• Are we prepared to respond to a food defense incident?

• Are we prepared to implement our Food Recall Plan?

• Are our Food Defense and Recall Plans complete and available?

• As a result of this exercise, what are the major issues that need to be addressed?

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Benefits (1–2 Minutes)

• As you complete this exercise, consider these potential benefits:– Having 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 the confidence you could recover your product if the need arises.

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Post-exercise documents (4–8 minutes)

• Lessons Learned– This in an internal/confidential document solely for the

establishment’s own use.– It has three sections for key findings, action steps, and

additional discussion items.– Your facilitator and scribe will work on this following the

exercise, although they may ask you for some thoughts now or in the days ahead.

– Again, please keep this information confidential.

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Additional Resources AvailableRecall Resources Food Defense Resources

• FSIS General Food Defense Plan. http://www.fsis.usda.gov/PDF/General-Food-Defense-Plan-9-3-09%20_2_.pdf

• Additional FSIS web-based resources can be found at the following link: http://www.fsis.usda.gov/wps/portal/fsis/topics/food-defense-and-emergency-response/preparation-and-prevention/guidance-documents/guidance-documents

• Food and Drug Administration (FDA) Food Defense Tools & Educational Materials http://www.fda.gov/Food/FoodDefense/ToolsEducationalMaterials/default.htm

• The National Center for Food Protection and Defense (NCFPD) is a research consortium that looks at our Nation’s food system with respect to the vulnerabilities of attack through intentional contamination with biological or chemical agents. http://www.ncfpd.umn.edu/

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• FSIS Notice 67-12 Instructions Concerning Written Recall Procedures and Food Defense Plans http://www.fsis.usda.gov/OPPDE/rdad/FSISNotices/67-12.pdf

• FSIS Notice 34-13 Verifying Written Recall Procedures and Food Defense Plans at Small and Very Small Establishments. http://www.fsis.usda.gov/OPPDE/rdad/FSISNotices/34-13.pdf

• FSIS Directive 8080.1 Recall of Meat and Poultry http://www.fsis.usda.gov/OPPDE/rdad/FSISDirectives/8080.1.pdf

• FSIS Final Rule for Written Recall Procedures. Federal Register, Vol. 77, No. 89, Tuesday May 8, 2012, pages 26929–26937 http://www.fsis.usda.gov/OPPDE/rdad/FRPubs/2008-0025F.pdf

• USDA “How to Develop a Meat and Poultry Product Recall Plan.” Small Plant News Guidebook Series. May 2013. http://www.fsis.usda.gov/PDF/RecallPlanBooklet_0513.pdf

Thank you!

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