Overview of FDA's Food Defense Activities - Food and Drug Law ...

Overview of FDA’s FoodDefense ActivitiesJanuary 26, 2012LeeAnne Jackson, Ph.D.Center for Food Safety and Applied NutritionFood and Drug AdministrationDefinitions• Food defense – the protection of food productsfrom intentional adulteration by biological,chemical, physical or radiological agents• Food safety - the protection of food productsfrom unintentional contamination• Food security - having enough food of sufficientnutritional quality to sustain yourself1

International Food Defense Activities• APEC Food Defense Pilot Program– Thailand, Peru, Vietnam, Philippines– 3 phases• Assessment/Relationship Building• Train the Trainer/Awareness Workshops• Individual food defense plan development• Regional Awareness Workshops– Latin America– Caribbean– China– MexicoFuture International FoodDefense Activities• 2012-13 Food Defense Roadshows– India– Middle East and North Africa– Latin America2

Food Safety Modernization ActIntentional Adulteration Provisions• Section 103 - Hazard Analysis and Risk-Based Preventive Controls– “...hazards that occur naturally or may be intentionallyintroduced.”– “…identify and evaluate hazards that may beintentionally introduced, including by acts ofterrorism…”• Section 105 – Standards for Produce Safety– “…consider hazards …. that may be intentionallyintroduced, including by acts of terrorism…”Food Safety Modernization ActIntentional Adulteration Provisions• Section 106 – Protection Against IntentionalAdulteration– Determinations – vulnerability assessment, economic assessment,science-based mitigation strategies– Regulations• Assess individual implementation requirements for mitigation strategies• Specify appropriate science-based mitigation strategies– Regulation Applicability – foods with a high risk of intentionalcontamination (exception – farms, but does apply to milk)– Guidance Documents – model assessment, example of mitigationstrategies, examples of situations where mitigation strategies areappropriate3

Food Safety Modernization ActIntentional Adulteration Provisions• Section 208 – Decontamination andDisposal Standards and Plans– Development of Model Plans• Section 301 – Foreign SupplierVerification Program• Evaluate the potential risk for intentionaladulteration of the foodFood Defense Tools4

Tools• Guidance Documents• CARVER + Shock• Food Defense Mitigations Database• FDA’s Food Related EmergencyExercise Bundle (FREE-B)Food Defense GuidanceDocuments• Guidance documents– Food Producers, Processors andTransporters– Dairy Farms, Bulk Milk Transport,Processors– Retail Food Stores and Food Service– Importers and Filers– Cosmetics Processors and Transporters5

Appendix V: Food Defense SelfAssessment Tool• Downloadable PDF file format• Preventative measure captured as astatement• Same topics reflected in text document• Yes/No/Not Applicable/Don’t Know choices• Assessment Tool--No ScoreFood Defense Self Assessment Tool• Appendix to the guidance documents– Checklist mechanism by which a firm isguided through assessing the securityof a facility– Once complete the information can beused to develop a Food Defense Plan6

7CARVER + Shock Software• Breaks a food systeminto nodes in the farm totable continuum• Assesses each node toprioritize those mostvulnerable• Identifies mitigations toreduce vulnerabilityFood Defense MitigationStrategies Database• Released in March 2011• Contains a range of preventive measures for industry toconsider• Searchable• Focuses on manufacturers, processors, distributors, andretail/food service• Contains roughly 60 production steps (nodes)• Mitigations compiled from:– Guidance Documents– Open Literature– Industry Inputwww.fda.gov/fooddefense

8Food Related EmergencyExercise Bundle (FREE-B)• Released in August 2011.• Provide jurisdictions (Federal, State, and local) with avariety of options to test and improve their capabilities torespond to human or animal health emergencies.• 5 scenarios in the set are designed so that jurisdictionscan conduct them with a minimal amount of effort andediting.• Each scenario is stand-alone. Collaboration andpartnering between government and private sector iskey.Raising Food DefenseAwareness

ALERTHow do I ALERT the operators of theestablishments to make them more awareof Food Defense issues?17FDA’s ALERT Initiative• Intended to raise awareness of fooddefense• Applies to all aspects of the farm-totablecontinuum• Identifies 5 key food defense points:• Assure• Look• Employees• Report• Threat9

FDA’s ALERT InitiativeSee WWW.FDA.GOV/FOODDEFENSE for more informationFDA’s ALERT InitiativeALERT materials are available in PDF andmultiple languages• Wallet Card: English, Chinese, French,Korean, Portuguese, Spanish, Vietnamese• Brochure: English, Chinese, French, Korean,Portuguese, Spanish, Vietnamese• Poster: English, French, Portuguese,Spanish2010

11WEB-BASED TRAININGAVAILABLE IN ENGLISH & SPANISHEmployees FIRST22

Employees FIRST• Follow company fooddefense plan andprocedures.• Inspect your work areaand surroundingsareas.• Recognize anything outof the ordinary.• Secure all ingredients,supplies and finishedproduct.• Tell management if younotice anything unusualor suspicious.FIRST Employees Food DefenseAwareness Training• Training Kit for management toincorporate into company’s food defensetraining program for first-line employees• 10 - 15 minute video• Use images to re-enforce key message• Currently available in Chinese, English,French, Korean, Japanese, Portuguese,and Spanish.12

13Questions????LeeAnne.Jackson@fda.hhs.gov240-402-1593

Food Defense HistoryShaun KennedyDirector, National Center for Food Protection andDefenseAssistant Professor, Veterinary Population Medicine,University of MinnesotaThe Food and Drug Law InstituteFood Week26 January 2012©2011 National Center for Food Protection and Defense. All rightsreserved. Do not copy or distribute without permission of NCFPD.Food Continuum Paradigm• Food Security:Food System Protection• Supply sufficiency• Food Safety:• System reliability• Food Defense:• System resiliency• Food Quality:• Supply desirability• Food Protection:• Safety & Defense continuum©2011 National Center for Food Protection and Defense. All rightsreserved. Do not copy or distribute without permission of NCFPD.1

Food Security Reality©2011 National Center for Food Protection and Defense. All rightsreserved. Do not copy or distribute without permission of NCFPD.2010 U.S. Food Import Sources – USDA-ERS©2011 National Center for Food Protection and Defense. All rightsreserved. Do not copy or distribute without permission of NCFPD.2

Early Examples of Food Attacks• Athenian poisoning of Kirrha of the AmphictyonicLeague with the plant root of helleborous(Christmas rose) in 590 - 600 B.C• Contamination of wine left behind for Africanwarriors with mandagora by the CarthaginianGeneral Maharbal• Plague contamination of wells during the BlackDeath©2011 National Center for Food Protection and Defense. All rightsreserved. Do not copy or distribute without permission of NCFPD.Food as a Modern State Weapon• WW II Japanese use of food and water to attackthe population of at least 11 Chinese cities– Bacillus anthracis– Shigella spp– Vibrio cholerae– Salmonella paratyphi– Yersinia pestis©2011 National Center for Food Protection and Defense. All rightsreserved. Do not copy or distribute without permission of NCFPD.3

Disgruntled EmployeesGrocery store worker accused of poisoning beefThursday, February 13, 2003 Posted: 5:04 PM EST (2204 GMT)GRAND RAPIDS, Michigan -- A former supermarket employee was indicted on charges ofpoisoning about 200 pounds of ground beef with insecticide and sickening more than 40people.©2011 National Center for Food Protection and Defense. All rightsreserved. Do not copy or distribute without permission of NCFPD.Competitive Sabotage61 Students felled by rat poison in central ChinaMonday, September 29, 2003Dozens of elementary school students and teachers inHunan Province were hospitalized after ingesting ratpoison with their school breakfasts in an apparentdeliberate mass poisoning, state media said Sunday.©2011 National Center for Food Protection and Defense. All rightsreserved. Do not copy or distribute without permission of NCFPD.4

Misguided CompetitionChina dairy boss pleads guilty in melamine caseWed Dec 31, 2008 8:24am ESBEIJING (Reuters) - The chairwoman of aChinese dairy company went on trial onWednesday over a tainted milk scandal. . . Atleast six children have died and more than290,000 made ill from the contaminated milk,battering already dented faith in China-madeproducts and prompting massive recalls aroundthe world.©2011 National Center for Food Protection and Defense. All rightsreserved. Do not copy or distribute without permission of NCFPD.Criminals and DeviantsMan jailed over store food safety plotItaly on alert for water poisonerItalian police have launched a searchto track down a mystery poisoner whohas been injecting a soapy liquid intoplastic bottles of mineral water.Salesman Shane Ward, 53, left a jiffy bag in the fresh vegetable department ofMorrisons' King's Lynn branch marked for the attention of the store manager. Itcontained a jar of baby food - which he claimed he had contaminated - along with anote saying he had struck at nine other Morrisons stores,.©2011 National Center for Food Protection and Defense. All rightsreserved. Do not copy or distribute without permission of NCFPD.5

Domestic Extremists & Cults• Rajneeshee cult contamination of salad barswith S. typhimurium (1984, 751 ill).©2011 National Center for Food Protection and Defense. All rightsreserved. Do not copy or distribute without permission of NCFPD.Targeted Political Attacks350 Iraqi Policeman Suffer Food PoisoningOctober 11, 2006BAGHDAD, Iraq -- Authorities arrested the head ofthe mess hall where at least 350 Iraqi policemensuffered food poisoning, and a military spokesmansaid Monday that it was likely the poisoning wasintentional.©2011 National Center for Food Protection and Defense. All rightsreserved. Do not copy or distribute without permission of NCFPD.6

Terrorists“Terrorist groups have a lesser interest in biologicalmaterials and are most interested in chemicals such ascyanide salts to contaminate food and water supplies”CIA Testimony to Congress 2002Documents Seized inAfghanistan (Tarnak Farms)Indicate Interest©2011 National Center for Food Protection and Defense. All rightsreserved. Do not copy or distribute without permission of NCFPD.NCFPD VisionDefending the safety of the foodsystem through research andeducationShaun KennedyKenne108@umn.edu612-624-2247http://www.ncfpd.umn.edu©2011 National Center for Food Protection and Defense. All rightsreserved. Do not copy or distribute without permission of NCFPD.7

1Intentional Food Adulteration:Global Incidents / Private Sector ResponseMitchell Weinberg, Esq.Founder, President & CEOINSCATECHInternational Supply Chain Technologies CorporationIntentional Food AdulterationThe introduction of the FOOD SAFETY MODERNIZATION ACTrepresents an increased focus by both regulators and the foodindustry on FOOD DEFENSE (Intentional Food Adulteration):‣ Enhancing Global & National Security + Protecting OurBorders & Marketplace from adulterated products / ingredientsoriginating in high risk countries.SOURCES OF ADULTERATION:‣ Economically Motivated Actions‣ Disgruntled Employees‣ Politically Motivated GroupsINSCATECH Copyright 2012

2Economically MotivatedAdulterationDilutionWatered DownDairy ProductsMislabelingSunflower Oil Sold as Olive OilMethods of Intentional(Economically Motivated)Food AdulterationUnapprovedEnhancementsMelamine additionsto enhance proteinvalue / Use ofGrowth Hormones inMeatConcealmentSalmonella PeanutContamination / PoultryDiseases ConcealedSubstitutionHoney with Beet SugarCounterfeitingGrey Market Imitation CPG,example: repackagedyoghurtINSCATECH Copyright 2012Economically MotivatedAdulterationChinese Protein Export Adulteration – Unapproved Enhancement‣ The adulteration and contamination of several food and feed ingredientswith inexpensive melamine and other compounds - used to inflate theapparent protein content of products, so that inexpensive ingredients canpass for more expensive, concentrated proteins. The combination ofmelamine and cyanuric acid has been implicated in kidney failure.‣ 2007 - FDA disclosed 2.5 – 3 Million people in US consumed chickens thatwere fed contaminated vegetable protein from China‣ Melamine had been purposely added as a binder to fish & livestock feed inthe US & traced to suppliers in Ohio & ColoradoINSCATECH Copyright 2012

3Economically MotivatedAdulterationChinese Protein Export Adulteration –Unapproved Enhancement2008‣ China – baby formula recall – 294,000babies became ill, at least 6 died.‣ Europe – melamine found in chocolatespread imported across Europe2010‣ Chinese authorities still reporting seizures ofmelamine contaminated dairy productsINSCATECH Copyright 2012Economically MotivatedAdulterationUS – Substitution / Mislabeling‣ Sun Up substituted an inexpensive liquid beet sugar for some of the moreexpensive orange juice concentrate, then labeled the product unsweetenedorange juice concentrate and sold it to manufacturers and dairies for makingjuice sold through retailers.‣ Sun Up had used approximately 20 million pounds ofsugar to "stretch" or adulterate its orange juice.‣ James V. Mays, former owner of Sun Up Foods Inc. ofBenton, Ky., was sentenced to serve eight years inprison, & fined $100,000.‣ Cheated consumers out of at least $12 million.INSCATECH Copyright 2012

4Economically MotivatedAdulterationEUROPE: The Tapiro CaseConcealment / Unapproved Enhancements‣ North & Central Italy: Discovery of crime ringconsisting of stockbreeders, sales agents, managersof zootechnical food factories and pharmaceuticalindustries, farmers and veterinarians.‣ Antibiotics, hormones & steroids sourced from Chinawere illegally dealt by criminal organizations tomanagers of zootechnical food factories &pharmaceutical industries across Europe.‣ Stockbreeders used these substances as growth promoters & to hide animaldisease. 44 persons arrested, 98 persons charged.INSCATECH Copyright 2012The Tapiro Case‣ ACIDO ACETILSALICILICO (ATS)‣ AMPICILLINA – AMPLISOL‣ AMOSSICILLINA - AMOXICILLINA‣ ERITROMICINA - ERITROMICINA TIOCIANATO (ERI)‣ BAYTRIL – ENROFLOXACINA – OFLOXACINA‣ CLORAMFENICOLO (CAF)‣ DIMETRIDAZOLO (DMZ)‣ AVIOCHINA‣ TETRACICLINA (TET)‣ FURALTADONE (FUR)‣ FURAZOLIDONE‣ GENTAMICINA (GEN)‣ MEBENDAZOLO (MBZ)‣ N-BUTANOLO‣ NEOMICINA (NEO)‣ OLAQUINDOX (OQ)‣ TRICHLORFON (TFC)‣ STREPTOMICINA (STP)‣ SULFADIMETOSSINA –SULFAMETAZINA (SFM)‣ OSSITETRACICLINA – OXYTETRACYCLINE‣ FLUMEQUINA – FLUMECHINA (FMQ)‣ TRIMETHOPRIM – TRIMETOPRIM (TRP)‣ TRIMETROSULFA‣ 17BETA–ESTRADIOLO‣ 17BETA-BOLDENONE O DEIDROTESTOSTERONE‣ CLORTETRACICLINA - CHLORTETRACYCLINE‣ COLISTINA SOLFATO – COLISTIN SULPHATE‣ DESAMETAZONE - DEXAMATHASONE‣ DIAVERIDINA – DENAVERINE‣ DOXYCYCLINA‣ POTASSIO‣ IVERMECTINA‣ IODIO‣ PIPERAZINA‣ SPIRAMICINA – SPIRAMYCIN‣ TIAMULINA‣ TILOSINA – TYLOSINA TARTRATA‣ ZINCO BACITRACIN‣ ECXNEL‣ GANADOL‣ LASOTA‣ NISTATINAINSCATECH Copyright 2012

5Economically MotivatedAdulterationIndia / Bangladesh – Unapproved Enhancements:‣ Formalin added to fish, fruit, meat, & milk forpreservation (linked to throat & blood cancer, asthma,skin diseases).‣ Toxic additives including auramine, rhodamine,malachite green, allura red, and Sudan red applied onfood items for colouring, brightness, and freshness(linked to liver and kidney damage, stomach cancer,asthma, and bladder cancer).‣ Urea added to rice to enhance whiteness (linked nervous system / kidneydamage and respiratory problems).INSCATECH Copyright 2012Economically MotivatedAdulteration‣ EXTORTION2010 – France - The owner La Romanée-Conti, (the legendaryvineyard of Burgundy, bottles sell for $10k+) received a threat thevineyard would be poisoned unless the owner paid one million euro.When the owner didn’t pay a map was delivered that identifiedseveral vines that had already been poisoned by drill and syringe.‣ COMPETITION2002 – China - 40 people died and 200 individuals were hospitalizedin Nanjing after the owner of a fast-food outlet poisoned acompetitor’s breakfast foods with rat poison.INSCATECH Copyright 2012

6Economically MotivatedIntentional Food AdulterationCOSTHEALTH IMPACTSource: A.T. Kearney, 2009, Drivers for EconomicAdulteration & Food Defense, Craig Henry, Ph.DDisgruntled Employees‣ 1997 – Texas – Lab Worker - Intentional contamination of muffins anddonuts with laboratory cultures of Shigella dysenteriae. The eventcaused gastroenteritis in 45 laboratory workers and 4 were hospitalized.‣ 2003 – Michigan - a supermarket employee intentionally contaminated200 pounds of ground beef with an insecticide containing nicotine.Although the tainted meat was sold in only one store, 111 people,including approximately 40 children, were sickened.‣ 2009 – North Carolina – Domino’s Pizza contamination by employees –video distributed via YouTube.INSCATECH Copyright 2012

7Politically Motivated Groups‣ 1978 - In an effort to damage Israel’s economy, citrus fruit exportedto several European countries was contaminated with mercury,which led to significant trade disruption.‣ 1984 - the Rajneeshee religious group contaminated salad bars inthe U.S. state of Oregon in hopes of affecting the outcome of a localelection. This incident caused 751 cases of salmonellosis andresulted in the hospitalization of 45 victims.INSCATECH Copyright 2012Politically Motivated GroupsINSCATECH Copyright 2012

8Insurance Industry Response‣ Historically - Most liability insurance policies did not coverthe expenses and lost income associated with intentional foodadulteration.‣ As a result Contaminated Products & Product Recall Insurancehave been created.INSCATECH Copyright 2012Insurance Industry Response‣ Specialty recall coverage is available to cover certain recallrelatedlosses that often are excluded from general liability andproperty policies. In general, specialty policies can be triggeredby some or all of the following insured events:‣ Malicious product tampering‣ Product extortion‣ Adverse publicity concerning contamination or tampering‣ Government recallINSCATECH Copyright 2012

9Insurance Industry ResponseMalicious Product TamperingTriggered by the actual or threatened intentional, malicious orillegal alteration or contamination of an insured product so as torender it unfit for the use for what it was intended or create suchan impression with the public.‣ SO, there is a deliberate desire to cause economic harmor inflict bodily injury. The harm is directed againstinsured and it is known to the public.‣ Examples: pins found in lettuce at a major mid Atlanticretailer; cyanide in Chilean grapes; glass in baby food jars,etc.17INSCATECH Copyright 2012Insurance Industry ResponseProduct Extortion - any threat or connected series of threats tocommit a malicious product tampering of the insured product, forthe purpose of demanding extortion monies communicated to theinsured.‣ Basically I threaten to contaminate your product if you don’tpay me!Example: Australia Mars candy received threat that candy barswould tampered post production unless $$ received. All candypulled from shelves; significant brand rehab expense. Cost of$8 MM US - sadly $$ was used to pay gambling debts.INSCATECH Copyright 2012

10Insurance Industry ResponseAdverse Publicity‣ Coverage for adverse publicity is sometimes provided inconnection with a contamination or tampering incident.‣ Such coverage typically requires that either the insuredproduct or the brand name has been specifically identified.‣ For example, an FDA enforcement report that identifies theproduct would trigger coverage, but an FDA advisory warningconsumers not to consume a specific food, regardless ofbrand or producer, might not.19INSCATECH Copyright 2012Insurance Industry ResponseGovernment Recall‣ In the past, coverage for government recalls had limitedapplication in the United States as FDA did not havemandatory recall authority over food items other than infantformula.‣ However, since the FSMA granted the FDA mandatory recallauthority on Jan. 4, 2011, future FDA recalls might triggersuch coverage.20INSCATECH Copyright 2012

11Insurance Industry ResponseCovered LossesPolicies may cover some or all of the following recall-relatedexpenses:‣ Transporting, storing and disposing of the recalled product‣ Hiring and paying temporary staff to manage the recall‣ Paying overtime‣ Pre-recall testing‣ Third-party recall expenses‣ Product rehabilitation costs‣ Loss of gross profits‣ Crisis management expenses21INSCATECH Copyright 2012Some Key ExclusionsMost carriers have “no coverage” for any loss arising out of, basedupon, attributable to or involving, directly or indirectly:‣ A carcinogenic contamination‣ Any accidental contamination that occurs after the insuredhas knowledge of a defect or deviation in the production,preparation or manufacture of an insured product(s), or anycircumstance(s) which have resulted in or are likely to resultin such deviation or defect, for which the insured fails to takecorrective action.22INSCATECH Copyright 2012

12Some Key ExclusionsMost carriers have “no coverage” for any loss arising out of,based upon, attributable to or involving, directly or indirectly:‣ Any accidental contamination or malicious product tampering of acompetitor’s product that is similar to an insured product‣ Changes in population, customer tastes, economic conditions,seasonal sales variations, or competitive environment‣ Any injury, damage, or claim made by a third party arising out of or inconnection with the use or consumption of the insured product,including any defense costs related to a third party lawsuit.‣ Any illegal act of the insured’s directors, officers, or trustees.23INSCATECH Copyright 2012Private Sector ReactionsEurope – Intentional Adulteration - Perceived RiskSOURCE: Secufood: Security of European Food Supply Chain Study, April 2010.24

13Private Sector Response2010 - Peter Hayes, Frito Lay, Senior Group Manager, Manufacturingoperations Support and Food Security:‣ “We recognize we can never make the system bulletproof, but our jobis to mitigate 90 percent of the risks and a lot of that is aboutperception,”‣ The key to improving food defense is to remain vigilant, said Hayes.“We understand a lot of this infrastructure was created in the shadowof 9/11 and there were a lot of knee-jerk reactions,” he said. “We haveto make sure [our systems] are relevant to the risks of today and thatwe use the information we have to identify new threats - that’s key forus.”25Source: Stelter Leischen,”Food Defense: How Frito LayProtects Its Supply Chain, Security Director News, May 2010INSCATECH Copyright 2012Private Sector Response2011 – Quotes Provided by Security Director of MajorGlobal CPG Company:‣ …as the substantial effects are connected more tothe spreading of the news rather than to thematerial damages that the event causes, thevictims usually tend to keep the tampering caseswrapped up in the greatest secrecy, whenever thisis possible. It is therefore generally acknowledgedby analysts that the news leaking out is just a sortof tip of the iceberg of a phenomenon which isquite more frequent than one might think.‣ …the main tool to fight against tampering forterrorist purposes is the intelligence andoperational activity carried out by secret services.26INSCATECH Copyright 2012

14Private Sector ResponseUniversity of Minnesota Study – Retail Food, Food Service andWholesale Suppliers‣ Firms are better prepared for food defense against terrorism withintheir own firms than they are in collaboration with their suppliers.‣ Foodservice retailers and their wholesale partners are placing agreater emphasis on defense efforts then grocery retailers and theirwholesale partners.‣ There is much room for improvement in coordination between firmsalong the food supply chain.27Source: Kinsey, Jean, Kateryna Kaynts, KoelGhosh:”Defending the Food Supply Chain: Retail Food,Foodservice and Their Wholesale Suppliers”, The FoodIndustry Center, University of Minnesota, November 2007INSCATECH Copyright 2012Private Sector Response‣ Retail Food Sector - No focus on supply chain; little to no focus onprevention outside of scope of control – “it’s not my problem” mentality‣ Food Services Retail Sector - Focus on perception as opposed toproblem; no steps to prevent problems outside of area of control.‣ Foodservice companies have invested more in food defense practicesprobably because they have a stronger brand to protect. Theircompany is their brand unlike retail food companies who sell a varietyof brands and manufacturers who often sell many types of products.Also, foodservice retailers are large and global and more vulnerable toattack as an American icon.28Source: Kinsey, Jean, Kateryna Kaynts, KoelGhosh:”Defending the Food Supply Chain: Retail Food,Foodservice and Their Wholesale Suppliers”, The FoodIndustry Center, University of Minnesota, November 2007INSCATECH Copyright 2012

15Private Sector ResponseConclusions from the Operational Defense Competencies‣ Comparing the foodservice and retail food sectors based on thesecompetencies and their mean scores - found that the foodserviceindustry outperforms the retail food industry.‣ The foodservice retail sector ranks #1 followed by foodservicewholesalers, retail food wholesalers and retail food.‣ It was determined that the foodservice retail sector surpasses all theother three sectors in almost all the competencies except PhysicalSecurity where the retail food wholesalers rank higher, and SupplyChain Collaboration and Tracking/Monitoring where the foodservicewholesalers received higher mean scores.29Source: Kinsey, Jean, Kateryna Kaynts, KoelGhosh:”Defending the Food Supply Chain: Retail Food,Foodservice and Their Wholesale Suppliers”, The FoodIndustry Center, University of Minnesota, November 2007INSCATECH Copyright 2012Private Sector ResponseConclusions from the Operational Defense Competencies‣ By comparing the retail sectors, the firms and supply chain membersof the foodservice retail sectors perceive much larger improvements intheir performance as a result of defense initiatives than do foodretailers.‣ This observation is consistent with the benchmark results presentedwhere the foodservice retail sector often had the highest competencyscores.‣ They had invested more in food defense and recovery and alsoperceived more benefits to that investment than did others.30Source: Kinsey, Jean, Kateryna Kaynts, KoelGhosh:”Defending the Food Supply Chain: Retail Food,Foodservice and Their Wholesale Suppliers”, The FoodIndustry Center, University of Minnesota, November 2007INSCATECH Copyright 2012

16Private Sector ResponseUniversity of Minnesota Study – Retail Food, Food Service andWholesale Suppliers - Conclusion‣ In general, companies with larger revenue, cooperatives and thosewith a larger market scope are more engaged in food defensepractices.‣ Individual companies are doing better internally than they are doingwith their suppliers or than they perceive their suppliers to be doing.‣ Cross supply chain communication about practices & coordination willbe very important to continue to improve food defense practices andfurther strengthen the U.S. farm-to-fork supply chain continuum.31Source: Kinsey, Jean, Kateryna Kaynts, KoelGhosh:”Defending the Food Supply Chain: Retail Food,Foodservice and Their Wholesale Suppliers”, The FoodIndustry Center, University of Minnesota, November 2007INSCATECH Copyright 2012Supply Chain RisksA SUPPLY CHAIN ISAS STRONG AS ITSWEAKEST LINK…32INSCATECH Copyright 2012