15.4 Develop National Food and Agriculture Industry Protection Strategy
NASDA supports the development of an integrated national food and agriculture protection strategy that draws on the strengths of all stakeholders. Efforts to establish an integrated food safety system were begun almost decade ago, and the threats of an intentional attack on food and agriculture are placing increasing demands on states to develop strategies for protecting the food and agriculture industry in the absence of a uniform national policy.
In general, the strategy should assume that an intentional attack is more likely to involve the contamination of food or the introduction of plant and animal diseases, rather than the physical destruction of agricultural assets. Moreover, it must be flexible enough to address the diversity of sectors. Finally, components must be cost effective and based on a scientific risk assessment of their value. In addition, the development of a National Food and Agriculture Protection System should:
- Focus on safeguarding both the safety and security of food and agriculture. Existing surveillance and response systems should be used to form the basis for new measures to protect agriculture security.
- Be based on scientific principles that include an assessment of the risks and vulnerabilities of the food and agriculture system. The federal government through USDA and FDA need to develop uniform standards that can be readily implemented by state and local regulatory partners.
- Integrate the efforts of federal, state and local partners into a seamless system. Federal partners must lead collaborative efforts that establish standards, build on existing capabilities, provide training, foster assessments as needed, and provide appropriate funding to ensure the uniformity of the nationwide system. Federal partners must also take responsibility for ensuring the safety of all food products imported into the country through a uniform system based on establishing and monitoring the equivalency of foreign food safety programs. State and local partners must take primary responsibility for the inspection and sampling of local establishments.
- Coordinate appropriate security at all points in the production, processing and distribution, and retail sale of food to ensure the protection of food and food products.
NASDA strongly believes that the implementation of new policies and protocols by the food and agriculture industry under the new protection strategy must be accomplished in a way that is helpful to industry and will not create unnecessary financial or operational burdens. In addition to assuring that all measures are evaluated as to cost and effectiveness, and as circumstances warrant, new measures should be phased-in for adoption and federal funding made available to support the proposed measures.
Through a cooperative agreement with USDA APHIS, NASDA completed an assessment of the capabilities of the United States and state governments, foreign governments and the livestock industry to protect this nation’s livestock and human health from animal disease. The report considered the growing threat of terrorism and made more than 150 recommendations to strengthen domestic detection and surveillance, exclusion of disease, international information and response. The Animal Health Safeguarding Review was completed in 2001, and recommendations remain timely, in particular the need for a National Surveillance System and National Response Plan, improved and expanded research, and increased funding. NASDA believes that the recommendations of the Review must be prioritized and efforts redoubled to implement key actions within the context of developing a security strategy.
Furthermore, the existing NASDA policies with respect to Animal Health Protection and Disease Control, Food Regulation and Nutrition, and Plant Health should also be carefully considered and serve as a basis for additional action in this area. Actions should be considered on a priority basis to enhance the nation’s overall level of preparedness and response to food, plant protection and animal health threats.
Finally, NASDA fully supports the development of a national critical infrastructure protection plan that includes the food and agriculture sector and urges DHS to utilize the expertise of NASDA members to ensure national strategies adequately address food and agricultural considerations. NASDA urges DHS to call on state and local agriculture and food officials to participate in the development of national strategies.
Threat and Vulnerability Assessments
The assessment of terrorist threats to food and agriculture and evaluation of the industry’s vulnerabilities will form the basis for developing a preparedness and response strategy for the nation’s food and agriculture industry. The challenge is to determine the likelihood of various forms of attack and identify on a priority basis the gaps in the existing systems. With this information, we can develop cost-effective measures to enhance our ability to prevent an attack, detect an attack at the earliest possible time, respond to protect both the public health and industry and recover from an attack by restoring public confidence and the economic viability of affected sectors.
NASDA urges USDA, FDA, DHS, and other federal partners to complete assessments as rapidly as possible and share information relevant to the development of specific state preparedness strategies. Such information sharing is imperative as states develop and refine individual State Homeland Security Strategies (SHSS) and will be important for the seamless integration of state plans into the National Homeland Security Strategy.
To enhance state efforts to develop a well-coordinated integrated strategy for all stakeholders, uniform security standards should be developed. NASDA urges USDA, FDA and other federal partners to join with the state partners in developing standards:
- A voluntary Model Food Security Code based on the concept of the existing Model Food Code for food safety would help states close gaps identified through the risk assessments;
- Standards must afford the flexibility to recognize local, state and regional differences; for uniform agricultural and food protection with flexibility built in for regional, state, and local differences;
- National preparedness and security standards (e.g., response equipment, training, staff capabilities) are needed to guide decision-making and assess progress towards stated objectives;
- Development and implementation of standards should proceed only after careful assessment of cost and effectiveness;
- Support is needed for research to assess the standards, and NASDA urges its federal partners to coordinate development of the research agenda with local and state government, industry and university partners.
- Develop a national policy on the accessibility and availability of ammonium nitrate, urea and other products that can be converted from their intended use (fertilizer) to powerful explosives, in order to secure these products against easy transport across state lines and subsequent misuse by terrorists or other criminals. The Fertilizer Institute has demonstrated commitment to such protective measures, and those involved in agriculture will welcome actions to protect the country, while enabling them access to materials necessary for their success.
Exclude Foreign Animal and Plant Diseases and Contaminated Food Products
Increased trade in food and animal and plant stocks likewise adds challenges to ensure that imports do not include pests or diseases harmful to US agriculture. The increasing ease of global trade and travel raises concerns for the introduction—intentional or accidental—of pathogens, disease or pests.
Existing systems to exclude animal and plant diseases and contaminated food have been called into question in the wake of rising terrorist threats. Because it is virtually impossible to ensure the safety and security oversight at the port of entry for all imports arriving into the United States, NASDA urges USDA and FDA to consider a new model: certifying the equivalency of safety and security systems employed by our trading partners. While this is employed already by USDA in meat and poultry inspection, this concept needs to be greatly expanded to help reduce the risk of an intentional attack via imported food, plant or animal products.
The need for an ability to track crops, livestock and food products from farm to table cannot be overstated in terms of protecting public health and preserving the economic viability of the food and agriculture industry. Consumer and market demands have already begun driving trends to greater accountability and traceability. Increasing threats from a food safety and animal health perspective alone would be sufficient argument in favor of developing comprehensive product identification and tracking systems. Last summer Canada was, and now the United States is, under a global microscope as we struggle to trace the source of a cow infected with BSE as well as other animals associated with that cow. The specter of terrorist attacks makes the development and implementation of such systems even more imperative. If we require more than a few hours to locate all products associated with a terrorist incident, we risk a massive loss of consumer confidence in the nation’s food and agriculture system. That could have far costlier consequences than the immediate cost of the incident. NASDA strongly urges the immediate development and implementation of a uniform farm animal identification and tracking system. NASDA further urges the consideration of systems that make possible the identification and tracking of farm products from farm to table.
Risk Reduction Strategies
Industry should be encouraged in every possible way to adopt cost effective measures that address identified vulnerabilities and wherever possible reduce the risk of a broad range of possible hazards (i.e., “all hazards” prevention). NASDA urges the establishment of financial or other incentives to reduce the cost of capital or other investments by food and agriculture businesses. Particularly important are the immediate establishment of incentives to develop uniform identification and tracking systems to provide timely traceback of all livestock, consumer foods and food products.
Priority should be given to investments that will enhance prevention, such as good on-farm biosecurity, and to investments that address prevention or response to all hazards.
National Surveillance System
There also exists a very real possibility that we will face threats that will not be immediately apparent, and because of the lag in identifying and responding, will have more widespread and harmful impact on our food and agricultural industries. New systems that are capable of providing ongoing surveillance, early detection and effective response must be designed to maximize the limited resources available at all levels of government and to leverage private capacity that exists throughout the food and agriculture industry.
While the U.S. has historically enjoyed strong, well-functioning food safety, animal health and plant protection systems new threats have changed the nature of the surveillance and inspection that will be required in the future.
Existing systems should form the basis for actions now required to provide protection against intentional attacks against any of the sectors. However, resources are needed to enhance routine monitoring of the domestic food system at all points from farm to table, including the monitoring of plant and animal health. NASDA urges a comprehensive review of existing staffing levels of food, milk and horticulture inspectors and veterinarians and animal health technicians at the federal, state and local levels. Staffing increases should be prioritized based risk assessment. Systems for improved sharing of surveillance information must be developed and implemented.
The current capacity for rapidly and accurately diagnosing diseases used as weapons is limited and would certainly be overwhelmed by the volume of demand for testing services in the face of an outbreak. Just as the nationwide public health laboratory infrastructure was hard pressed to support investigations in the face of the recent Anthrax attacks, the intentional introduction of certain animal or plant diseases into the United States would result in massive needs for diagnostic testing, even in states without confirmed cases.
There are at the national level efforts to coordinate and enhance local efforts. One example of this kind of program is the proposed National Animal Health Laboratory Network (NAHLN). Similar efforts are being made to establish an integrated nationwide system of food laboratories through the formation of the Counter Terrorism Food Emergency Response Network (FERN) by the federal Food and Drug Administration. Adequate qualified laboratory testing capacity has proven time and again to be a critical component in dealing with disease outbreaks.
Despite progress in these areas, resources are needed immediately to support development of enhanced veterinary diagnostic laboratory capacity, food and milk safety testing, and plant inspection to support the development of an enhanced surveillance network.
The accidental introduction of disease or illness has historically resulted in incidents limited in scope, number of individuals affected and geographic area involved. The intentional introduction of disease has the potential to extend impacts over a wide area and involve a much larger population—either directly or indirectly through fear and other social disruption.
Systems designed to respond to incidents today need to be flexible and scalable—able to adjust to rapidly changing circumstances and expanding scope. NASDA urges all partners to join in the development of systems that seamlessly augment prevention and surveillance resources. Response will also require the coordinated communications systems in place to enhance overall preparedness. Response efforts for all agricultural emergencies are now addressed through the Incident Command System (ICS). It is imperative that standardized training and exercises be provided for all state and local officials that would be expected to participate in response activities.
Once a response has been initiated, NASDA further urges all partners to develop mechanisms for ensuring that placement and release of control measures are targeted as specifically as possible.. The ongoing viability of the food and agriculture industry will depend on its ability to restore operations to near normalcy as soon as possible. The release of quarantined product or animals for example should take place as soon as possible to aid in the recovery phase.
Rapid recovery will be critical to ensuring the ongoing viability of food and agriculture businesses affected by an incident. Recovery can be facilitated by:
- A Public Communications Plan. The Plan must address not only the details of the incident but also the attendant fear and potential social disruption. Maintaining consumer confidence will be an important factor in preserving the resiliency of our agriculture and food infrastructure.
- Disaster recovery funds provided to fairly compensate for the loss of livestock, crops, and other costs of the incident. NASDA recommends a comprehensive review of current emergency assistance authority and development of plans to mitigate shortcomings.
- Technical assistance and other support for farms and businesses.