The Food and Drug Administration (FDA) is requesting authority to require entities in the food supply chain to implement measures solely intended to protect against the intentional adulteration of food by terrorists or criminals and names tank trucks as one of its examples, according to an FDA Food Protection Plan announced in November.
If the authority is eventually approved by legislative action, the FDA would issue regulations requiring companies to implement practical food defense measures at specific points in the food supply chain where intentional contamination has the greatest potential to cause serious harm, "such as requiring locks on tanker trucks transporting food."
The specific points would be determined using vulnerability assessments such as CARVER Plus Shock, an offensive targeting prioritization tool adapted from the military version for use in the food industry. The tool can be used to assess the vulnerabilities within a system or infrastructure to an attack. It allows the user to think like an attacker to identify the most attractive targets.
FDA said that if the authority is granted, it would apply to food in bulk or batch form, prior to being packaged that have clearly demonstrated vulnerabilities, and where it would affect multiple servings and there is a high likelihood of serious adverse health consequences or death from intentional adulteration. The requirement would utilize industry best practices and would not apply to raw produce or food on farms, except for milk.
These regulations will be developed taking into account the best available understanding of the uncertainties, risks, costs, and benefits associated with alternative options. FDA also proposes that firms be extended an affirmative defense in civil litigation if they comply with these controls.
The Food Protection Plan can be viewed on the Food and Drug Administration Web site.