PNS - BAFPS 134-2013 - Food Defense Guidance For Industry
PNS - BAFPS 134-2013 - Food Defense Guidance For Industry
Foreword
Food
defense
is
a
collective
term
used
to
describe
efforts
to
prevent
intentional
contamination
of
food
products
by
biological,
chemical,
physical
or
radiological
agents
that
are
not
reasonably
likely
to
occur
in
the
food
supply.
It
is
different
from
the
concept
of
food
safety,
which
involves
efforts
to
protect
food
products
from
unintentional
and
naturally
occurring
contamination
by
agents
reasonably
likely
to
occur
in
the
food
supply.
More
often,
food
defense
is
confused
with
food
safety.
This
Food
Defense
Guidance
for
Industry
was
developed
in
order
to
provide
a
general
overview
of
the
food
defense
concepts,
principles,
elements
and
procedures.
This
document
will
eventually
assist
the
food
industry
in
complying
with
future
regulatory
requirements
of
importing
countries
such
as
the
United
States
and
national
regulatory
requirements
such
as
that
of
the
National
Meat
Inspection
Service.
In
2013,
Republic
Act
(RA)
10536
ammended
the
Meat
Inspection
Code
of
the
Philippines
(RA
9296),
to
include
a
division
at
the
National
Meat
Inspection
Service
(NMIS)
on
“Enforcement
and
Food
Defense.”
This
division
shall
be
responsible
for
the
enforcement
of
policies
against
hot
meat
and
adulterated
or
misbranded
meat
products,
and
the
protection
of
meat
products
from
hazardous
contaminants.
A
Technical
Working
Group
(TWG)
was
created
through
Special
Order
Nos.
106
and
201
Series
of
2013
to
develop
the
draft
Food
Defense
Guidance
for
Industry.
The
TWG
represented
the
relevant
agencies
of
the
Department
of
Agriculture
(DA),
Department
of
Health
(DOH),
University
of
the
Philippines
(UP),
and
the
private
sector.
Public
consultations
were
conducted
in
Davao,
Cebu,
and
the
National
Capital
Region
(NCR),
which
represented
the
major
exporting
regions
in
the
Philippines.
Comments
and
recommendations
were
solicited
from
the
relevant
government
agencies,
academe,
private
sector
and
non-‐government
organizations.
Therefore,
this
Guidance
Document
is
the
final
output
of
the
public-‐private
sector
collaboration
between
and
among
the
TWG
and
the
relevant
stakeholders
who
participated
in
the
public
consultations.
1
PHILIPPINE
NATIONAL
STANDARD
PNS/BAFPS
134:2013
Food
Defense
Guidance
for
Industry
1. Introduction
Food
defense
is
a
collective
term
used
to
describe
efforts
to
prevent
intentional
contamination
of
food
products
by
biological,
chemical,
physical
or
radiological
agents
that
are
not
reasonably
likely
to
occur
in
the
food
supply.
It
is
different
from
the
concept
of
food
safety,
which
involves
efforts
to
protect
food
products
from
unintentional
and
naturally
occurring
contamination
by
agents
reasonably
likely
to
occur
in
the
food
supply.
After
the
September
11
attack
in
2001,
the
United
States
(US)
signed
into
law
the
Bioterrorism
Act
of
2002
which
aimed
to
improve
the
capacity
of
the
United
States
to
prevent,
detect
and
respond
to
terrorist
acts.
Concern
for
the
food
safety
of
the
food
supply,
which
can
be
a
target
of
terrorist
attacks,
also
came
into
the
fore.
With
it
came
a
basic
understanding
to
better
secure
the
food
supply.
In
2002,
the
Homeland
Security
Act
provided
the
basis
for
the
Department
of
Homeland
Security
to
be
responsible
for
protecting
critical
infrastructure,
including
food
and
agriculture.
In
2003,
Homeland
Security
Presidential
Directive
9
established
the
policy
of
improving
intelligence,
emergency
response,
mitigation
strategies
and
vulnerability
assessments
to
defend
food
and
agriculture
against
terrorism,
major
disasters
and
other
emergencies.
Food
terrorism,
as
defined
by
the
World
Health
Organization
(WHO),
is
an
act
or
threat
of
deliberate
contamination
of
food
for
human
consumption
with
chemical,
biological,
radionuclear
agents
for
the
purpose
of
causing
injury
or
death
to
civilian
populations
and/or
disrupting
social,
economic
and
political
instability.
Physical
hazards
may
similarly
be
intentionally
introduced
to
a
food
system
by
a
perpetrator.
Since
then,
the
term
food
terrorism
has
evolved
and
was
replaced
by
food
defense.
Food
defense
has
now
become
a
part
of
an
even
larger
concept
of
food
protection,
which
also
encompasses
food
safety
and
food
quality.
Currently,
the
US
Food
Safety
Modernization
Act
(FSMA)
requires
the
US
Food
and
Drug
Administration
(USFDA)
to
issue
regulations
to
protect
against
the
intentional
adulteration
of
food.
The
following
sections
of
FSMA
relate
to
intentional
adulteration
or
food
defense:
• Section
103:
Hazard
Analysis
and
Risk-‐Based
Preventive
Controls
–“identify
and
evaluate
hazards
that
may
be
intentionally
introduced,
including
by
acts
of
terrorism”
• Section
105:
Standards
for
Produce
Safety
–
“consider
hazards
that
occur
naturally,
may
be
unintentionally
introduced,
or
may
be
intentionally
introduced,
including
by
acts
of
terrorism”
• Section
106:
Protection
Against
Intentional
Adulteration
–
“issue
regulations
and
guidance
to
protect
against
intentional
adulteration
of
food”
• Section
108:
National
Agriculture
and
Food
Defense
Strategy
–
“a
strategic
planning
document
that
is
in
the
process
of
development”
The
Asia-‐Pacific
Economic
Cooperation
(APEC)
likewise
identified
food
defense
as
having
potential
impact
on
trade
and
measures
were
recognized
as
integral
to
protecting
the
food
supply.
APEC
endorsed
a
set
of
nine
(9)
Food
Defense
Principles
in
2007
and
created
an
APEC
Food
Defense
Pilot
Program
in
2008
in
an
effort
to
put
the
principles
into
practice.
The
Philippines
was
one
of
the
four
(4)
pilot
economies
of
the
APEC
Food
Defense
Pilot
Program
conducted
in
2011.
2
PHILIPPINE
NATIONAL
STANDARD
PNS/BAFPS
134:2013
Food
Defense
Guidance
for
Industry
In
2012,
the
Department
of
Agriculture,
with
the
Bureau
of
Agriculture
and
Fisheries
Product
Standards
(BAFPS)
as
Technical
Secretariat,
created
a
private-‐public
sector
Food
Defense
Technical
Working
Group
(TWG)
and
conducted
a
food
defense
awareness
seminar-‐workshop
series
to
continue
the
information
dissemination
initiatives
started
by
APEC.
The
Food
Defense
TWG
will
also
provide
recommendations
on
sustainable
national
initiatives
related
to
food
defense.
In
2013,
Republic
Act
(RA)
10536
amended
the
Meat
Inspection
Code
of
the
Philippines
(RA
9296),
to
include
a
division
at
the
National
Meat
Inspection
Service
(NMIS)
on
“Enforcement
and
Food
Defense.”
This
division
shall
be
responsible
for
the
enforcement
of
policies
against
hot
meat
and
adulterated
or
misbranded
meat
products,
and
the
protection
of
meat
products
from
hazardous
contaminants.
In
view
of
the
national
and
international
concerns
on
food
defense,
this
guidance
document
and
its
annex
was
drafted
for
the
Philippine
food
industry,
with
the
purpose
of
providing
a
general
overview
of
the
food
defense
concepts,
principles,
elements
and
procedures.
This
document
will
eventually
assist
the
food
industry
in
complying
with
future
regulatory
requirements
of
importing
countries
such
as
the
United
States
and
national
regulatory
requirements
such
as
that
of
NMIS.
This
guidance
document
can
be
used
by
all
sectors
in
the
food
supply
chain,
including
farms
particularly
those
engaged
in
retailing
of
fresh
produce
or
minimally
processed
products,
aquaculture
facilities,
fishing
and
holding
vessels,
meat
establishments,
transportation
operations/facilities,
processing,
packing
and
warehousing
facilities.
It
is
not
intended
as
guidance
for
retail
food
stores
and
food
service
establishments.
3
PHILIPPINE
NATIONAL
STANDARD
PNS/BAFPS
134:2013
Food
Defense
Guidance
for
Industry
3. Definition
of
Terms
For the purpose of this document, the following terms are operationally defined:
Adulteration
–
refers
to
an
act
which
leads
to
the
production
of
food
which:
(a) bears
or
contains
any
poisonous
or
deleterious
substance
that
may
render
it
injurious
to
the
health
of
the
public;
(b) bears
or
contains
any
added
poisonous
or
deleterious
substance
in
amounts
exceeding
established
maximum
limits
or
standards
for
good
manufacturing
practice;
(c) contains
in
whole
or
in
part
filthy,
putrid
or
decomposed
substance
that
is
unfit
for
human
consumption;
(d) has
been
prepared,
packed
or
held
under
unsanitary
conditions;
(e) in
whole
or
in
part,
is
the
product
of
a
diseased
animal
which
has
died
through
ways
other
than
slaughter;
(f) is
in
a
container
having
in
whole
or
in
part
poisonous
or
deleterious
substance;
(g) has
been
intentionally
subjected
to
radiation
unless
the
use
of
radiation
is
in
conformity
with
an
existing
regulation
or
exemption;
(h) becomes
injurious
to
health
because
of
the
omission
or
abstraction
of
a
valuable
constituent;
or
if
any
substance
has
been
substituted
wholly
or
in
part,
or
if
damaged
or
made
inferior
which
has
been
concealed
in
any
manner;
or
if
any
substance
has
been
added
thereto
or
mixed
or
packed
therewith
so
as
to
increase
its
bulk
or
weight
or
reduce
its
strength
or
to
make
it
appear
better
or
greater
than
it
is;
(i) has
not
been
prepared
in
accordance
with
current
acceptable
manufacturing
practice
as
promulgated
by
way
of
regulation;
and
(j) uses
expired
ingredients.
Agent
–
a
biological,
chemical,
physical
or
radiological
poison,
which
may
be
used
for
intentional
or
terrorist
acts.
CARVER
+
Shock
-‐
a
vulnerability
assessment
tool
that
can
be
used
to
assess
and
prioritize
the
vulnerabilities
within
a
system
or
infrastructure
in
the
food
industry.
CARVER
+
Shock
is
an
acronym
for
six
attributes
used
to
evaluate
the
attractiveness
of
a
target
for
attack,
namely
criticality,
accessibility,
recognizability,
vulnerability,
effect,
recuperability
and
shock.
Critical
Node
–
specific
point
in
the
food
supply
chain
where
intentional
contamination
has
the
greatest
potential
to
cause
economic
and
public
health
harm.
Counterfeit
-‐
to
make
imitation
of
something
else
with
the
intent
to
defraud
or
deceive.
Diversion -‐ the act of turning something aside from its intended course or purpose.
4
PHILIPPINE
NATIONAL
STANDARD
PNS/BAFPS
134:2013
Food
Defense
Guidance
for
Industry
Economically
Motivated
Adulteration
-‐
an
economic
gain
or
increase
in
profit
resulting
from
malicious/
fraudulent,
intentional
addition/substitution
of
a
substance
in
a
product
to
increase
the
value
of
the
product
or
reduce
the
cost
of
production.
Food
–
refers
to
any
substance
or
product
whether
processed,
partially
processed
or
unprocessed
that
is
intended
for
human
consumption.
It
includes
drinks,
chewing
gum,
water
and
other
substances
which
are
intentionally
incorporated
into
the
food
during
its
manufacture,
preparation
and
treatment.
Food
Defense
-‐
effort
to
prevent
intentional
contamination
of
food
products
by
biological,
chemical,
physical,
or
radiological
agents
that
are
not
reasonably
likely
to
occur
in
the
food
supply.
Food
Defense
Plan
-‐
a
written
plan
used
to
record
practices
implemented
to
control/reduce
the
potential
for
an
intentional
contamination
event
and
thereby
reduce
the
overall
vulnerability
of
the
assessed
food
operation.
Food
Safety
–
refers
to
the
assurance
that
food
will
not
cause
harm
to
the
consumer
when
it
is
prepared
or
eaten
according
to
its
intended
use.
It
also
refers
to
efforts
to
protect
food
products
from
unintentional
and
naturally
occurring
contamination
by
agents
reasonably
likely
to
occur
in
the
food
supply.
Food
Supply
Chain
–
refers
to
all
stages
in
the
production
of
food
from
primary
production,
post
harvest
handling,
distribution,
processing
and
preparation
for
human
consumption.
Preparation
is
the
cooking
or
other
treatments
to
which
food
is
subjected
prior
to
its
consumption.
Food
Terrorism
-‐
an
act
or
threat
of
deliberate
contamination
of
food
for
human
consumption
with
chemical,
biological,
radionuclear
agents
for
the
purpose
of
causing
injury
or
death
to
civilian
populations
and/or
disrupting
social,
economic
and
political
instability.
Hazard
-‐
a
biological,
chemical,
radiological,
or
physical
agent,
in
or
condition
of,
food
with
the
potential
to
cause
an
adverse
health
effect.
Hot
Meat
–
the
carcass
or
parts
of
a
carcass
or
food
animals
which
were
slaughtered
from
unregistered/unaccredited
meat
establishments
and
have
not
undergone
the
required
inspection.
It
also
includes
undocumented,
illegally
shipped
and
unregistered
carcass
and
meat
products
coming
from
other
countries
and
those
that
are
classified
as
hot
meat
by
NMIS.
5
PHILIPPINE
NATIONAL
STANDARD
PNS/BAFPS
134:2013
Food
Defense
Guidance
for
Industry
Mitigation
Strategy
-‐
science-‐based
procedures,
practices,
or
processes
that
would
be
employed
to
significantly
minimize
or
prevent
the
vulnerabilities
identified
in
a
vulnerability
assessment.
Prevention
-‐
actions
taken
to
avoid
an
incident
or
to
intervene
to
stop
an
incident
from
occurring.
Prioritize
-‐
process
of
using
the
results
of
the
vulnerability
assessment
to
identify
where
the
reduction
of
risk
is
needed
and
has
to
be
reinforced.
Radiological
–
involving
radioactive
materials.
Radionuclear/radionuclide
-‐
a
chemical
substance
that
exhibits
radioactivity.
Recovery
-‐
return-‐to-‐service
activities
that
industry
and
government
must
undertake
to
assure
consumers
the
products
will
be
safe
and
secure
following
an
event.
The
development,
coordination
and
execution
of
service
and
site-‐restoration
plans
for
impacted
communities
and
the
reconstitution
of
government
operations
and
services
through
individual,
private
sector,
non-‐government
and
public
assistance
programs.
Response
-‐
activities
that
address
the
short-‐term,
direct
effects
of
an
incident
(e.g.
save
and
limit
loss
of
life
and
property,
meet
basic
human
needs,
execution
of
emergency
plans,
apply
intelligence
to
lessen
consequences,
immunizations,
law
enforcement
operations).
Risk
-‐
a
function
of
the
probability
of
an
adverse
health
effect
and
the
severity
of
that
effect,
consequential
to
a
hazard(s)
in
food.
Risk
Assessment
–
a
scientifically
based
process
consisting
of
the
following
steps:
(i)
hazard
identification,
(ii)
hazard
characterization,
(iii)
exposure
assessment,
and
(iv)
risk
characterization.
Sabotage
-‐
destruction
of
the
employers
property
or
the
hindering
of
manufacturing
by
discontented
workers/perpetrators.
Tainted
-‐
to
affect
with
decay
or
putrefaction;
spoiled;
contaminated.
Tampering
-‐
to
interfere
with
the
food
in
a
harmful
way
by
adding
or
influencing
it
with
something
else.
Vulnerability
-‐
a
weakness
in
the
design,
implementation
or
operation
of
an
asset
or
system
that
can
be
exploited
by
an
adversary.
Vulnerability
Assessment-‐
process
of
identifying
and
prioritizing
the
weaknesses
(vulnerabilities)
in
a
food
operation.
The
process
is
used
to
identify
specific
points
in
the
food
supply
chain
where
intentional
contamination
has
the
greatest
potential
to
cause
economic
and
public
health
harm.
6
PHILIPPINE
NATIONAL
STANDARD
PNS/BAFPS
134:2013
Food
Defense
Guidance
for
Industry
4. Food
Defense
Principles
and
Concepts
There
are
generally
two
(2)
types
of
food
contamination:
(1)
unintentional/accidental
and
(2)
intentional
as
shown
in
Figure
1.
Food
defense
is
the
protection
of
food
products
from
intentional
contamination
by
biological,
chemical,
physical,
or
radiological
agents
that
are
not
reasonably
likely
to
occur
in
the
food
supply.
Human
intervention
is
the
source
of
intentional
contamination.
Food
defense
encompasses
intentional
contamination,
economic
adulteration,
disgruntled
employees/sabotage,
and
counterfeiting/diversion/tampering.
On
the
other
hand,
food
safety
is
the
protection
of
food
products
from
unintentional
contamination
by
agents
reasonably
likely
to
occur
in
the
food
supply.
Nature
and
environment
are
the
main
sources
of
unintentional
contamination.
7
PHILIPPINE
NATIONAL
STANDARD
PNS/BAFPS
134:2013
Food
Defense
Guidance
for
Industry
Table1.
Differences
Between
Food
Safety
and
Food
Defense
(adopted
from
Maczka,
2008)
Outcomes
May
involve
many
illnesses
but
Has
potential
to
result
in
many
few
deaths
deaths
Contaminants/Agents
Prevention
and
Control
Good
Agricultural
Practices
Measures
or
actions
taken
to
Strategies
(GAP),
Good
Animal
Husbandry
reduce
the
impact
of
Practices
(GAHP),
Good
intentional
food
contamination
Aquaculture
Practices
(GaqP),
at
vulnerable
points
in
a
facility
Good
Hygienic
Practices
(GHP),
(e.g.
personnel
and
physical
Good
Manufacturing
Practice
security)
as
well
as
(GMP),
Sanitation
Standard
government
or
industry-‐wide
Operating
Procedures
(SSOP),
measures
(e.g.
surveillance,
Hazard
Analysis
and
Critical
outreach
training)
Control
Points
(HACCP)
Decontamination
and
Can
be
cooked
or
sent
to
landfill.
Contaminated
food
may
be
Disposal
Sanitation
procedures
should
be
hazardous
waste.
Need
to
sufficient
for
cleaning
the
facility
identify
decontamination
before
resuming
food
production.
techniques
and
confirm
facility
is
free
of
residual
contaminant
before
resuming
food
production.
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Food
Defense
Guidance
for
Industry
Communication
Food
safety
education
needed
for
Much
public
concern,
therefore
general
public
and
good
risk
extra
consideration
is
needed
communication
strategies
needed
when
developing
risk
by
industry
and
government.
communication
and
public
education
messages
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Food
Defense
Guidance
for
Industry
5. Developing
a
Food
Defense
Plan
A
Food
Defense
Plan
is
a
written
plan
to
reduce
the
risk
of
intentional
contamination
with
low-‐cost
or
no-‐cost
mitigation
measures.
It
assesses
the
risk
of
an
attack
and
identify
control
measures
to
minimize
the
risk.
A
Food
Defense
Plan
achieves
the
following:
A
functional
Food
Defense
Plan
may
be
developed
following
these
steps:
1. Development
of
a
Food
Defense
Plan
by
conducting
vulnerability
assessment;
2. Implementation
of
the
Food
Defense
Plan
by
using
the
defense
measures
identified;
3. Testing
the
Food
Defense
Plan
by
periodic
monitoring
of
the
effectiveness
of
the
defense
measures;
4. Periodic
assessment
of
the
Food
Defense
Plan
by
reviewing
the
plan
and
revising
as
necessary
especially
if
new
risks
are
discovered;
and
5. Maintaining
and
sustaining
the
implementation
of
the
Food
Defense
Plan
to
ensure
that
defense
measures
are
being
implemented
and
are
effective.
Prior
to
developing
a
Food
Defense
Plan,
a
self
assessment
may
be
conducted
using
the
sample
templates
provided
by
the
US
Department
of
Agriculture
Food
Safety
and
Inspection
Service
(USDA-‐
FSIS)
for
food
processing
plants
(http://www.fsis.usda.gov/wps/wcm/connect/63fb5993-‐97ac-‐4414-‐b5d6-‐
f9c329d13c74/Food_Defense_Plant_Brochure_Slaughter.pdf?MOD=AJPERES)
and
for
meat
and
poultry
slaughtering
and
processing
plants
(http://www.fsis.usda.gov/shared/PDF/Food_Defense_Plan.pdf).
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PHILIPPINE
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STANDARD
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Food
Defense
Guidance
for
Industry
5.1
The
Basic
Food
Defense
Plan
The
Basic
Food
Defense
Plan
has
four
(4)
base
components.
Each
base
component
has
sub-‐
components
as
may
be
applicable
to
your
company.
They
are
as
follows:
1.
Outside
Security
1.1
property
perimeter
1.2
building
perimeter
1.3
vehicles
2.
General
Inside
Security
2.1
facility/plant
2.2
utilities
2.3
laboratory
2.4
process
computer
systems
3.
Logistics,
Production
and
Storage
Security
3.1
suppliers
and
vendors
3.2
shipping
and
receiving
3.3
incoming
shipments
3.4
processing
and
production
3.5
live
animals
3.6
outgoing
shipments
3.7
returned
products/goods
3.8
ice/water/processing
aids
3.9
storage
and
warehouse
3.10
hazardous
materials/chemicals
4.
Management
4.1
personnel
security
4.2
food
defense
plan
A
gap
assessment
should
be
done
to
evaluate
the
facility’s
existing
food
defense
measures
in
the
components/areas
listed
above.
Designated
personnel
who
are
competent,
understand
the
principles
of
food
defense
and
have
considerable
knowledge
about
the
company
should
conduct
the
gap
assessment.
Weaknesses
in
processes,
infrastructures
and
security
measures
which
provide
risks
for
intentional
food
contamination
are
identified.
These
gaps
may
allow
possible
access
of
persons
with
ill
motives
and
introduce
agents
that
are
hazards
to
food
safety.
The
Food
Defense
Plan
Builder
is
a
user-‐friendly
software
program
developed
by
the
USFDA
designed
to
assist
food
facilities
in
the
development
of
their
individual
Food
Defense
Plans.
The
tool
utilizes
the
existing
USFDA
tools,
guidance,
and
resources
on
food
defense.
The
Food
Defense
Plan
Builder
can
be
downloaded
using
this
link:
(http://www.fda.gov/Food/FoodDefense/ToolsEducationalMaterials/ucm349888.htm).
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Food
Defense
Guidance
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Industry
A
Basic
Food
Defense
Plan
should
detail
the
basic
information
about
the
company
and
the
basic
food
defense
mitigation
measures.
Records
of
implementation
of
these
controls
should
be
generated.
Monitoring
and
verification
of
implementation
should
likewise
be
done
through
reviews,
assessments
and
audits.
Food
Defense
Plans
should
be
tested
for
effectiveness.
Where
plans
are
weak
in
preventing
intentional
food
contamination,
improvements
should
be
carried
out.
A
General
Food
Defense
Plan
developed
by
the
USDA
–FSIS
can
be
accessed
at:
http://www.fsis.usda.gov/wps/wcm/connect/99f95182-‐0c9e-‐
4214-‐9762-‐e98197f54ebf/General-‐Food-‐Defense-‐Plan-‐9-‐3-‐09+_2_.pdf?MOD=AJPERES.
5.2
Vulnerability
Assessment
Vulnerability
assessment
is
the
process
of
identifying
and
prioritizing
the
weaknesses
(vulnerabilities)
in
a
food
operation.
It
allows
evaluation
of
individual
unit
operations
in
the
process
to
identify
those
that
might
be
at
greatest
risk.
The
specific
point
in
the
food
supply
chain
where
intentional
contamination
has
the
greatest
potential
to
cause
economic
and
public
health
harm
is
called
a
critical
node.
In
conducting
a
vulnerability
assessment,
the
following
general
steps
are
followed:
1. Sketch
a
detailed
flowchart
of
the
operation,
validate
for
correctness
by
conducting
a
walk-‐through
in
the
facility;
2. Identify
major
process,
storage
and
distribution
steps;
3. Identify
vulnerabilities
based
on
a
number
of
criteria,
or
depending
on
the
vulnerability
assessment
tool
applicable;
4. Rank
the
unit
operation/s
based
on
vulnerability
scores
or
risks;
and
5. Establish
mitigation
measures
for
the
unit
operation/s
most
vulnerable
to
attack.
Vulnerability
assessment
requires
the
active
participation
of
all
members
of
the
Food
Defense
Team,
with
everyone
contributing
to
a
democratic
decision-‐making.
A
Food
Defense
Team
should
represent
all
the
departments
in
the
facility
and
should
be
multi-‐
functional.
The
size
of
the
Food
Defense
Team
depends
on
the
size
of
the
facility
and
availability
of
resources.
While
assessment
of
the
contributions
of
people
and
physical
structure
on
vulnerability
of
a
commodity
to
intentional
contaminations
may
be
easily
done
and
addressed
using
the
earlier
discussed
Food
Defense
Plan
Builder
tool
for
gaps
assessment,
vulnerability
assessment
of
the
food
processing
operation
entails
a
more
rigorous
process,
tracing
each
step
of
the
process
flow,
and
including
all
sub-‐processing
facilities
found
within
the
same
area.
For
example,
if
a
particular
ingredient
is
manufactured
in
the
same
facility
where
a
product
is
processed,
the
process
flow
for
that
particular
ingredient
should
similarly
be
subjected
to
vulnerability
assessment.
While
a
technology-‐intensive
and
fully-‐automated
process
may
have
few
or
no
vulnerability,
a
labor-‐intensive
and
highly
manual
process
exposed
to
human
contact
may
have
too
many.
Aside
from
identifying
the
vulnerabilities
of
the
process,
there
is
therefore
a
need
to
determine
the
relative
importance
of
the
identified
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Food
Defense
Guidance
for
Industry
weaknesses,
so
the
Food
Defense
Team
can
prioritize
the
more
significant
(or
more
vulnerable)
steps
that
need
immediate
mitigation.
Vulnerability
in
a
process
flow
is
a
weakness
in
any
of
the
unit
operations
where
intentional
contamination
can
take
place.
These
operations
include
handling
and
storage
of
raw
materials,
ingredient
mixing,
finished
product
packaging,
and
dispatch
and
distribution.
5.2.1.
Facilitators
of
Intentional
Contamination
Intentional
contamination
may
be
facilitated
by
agents
such
as
(1)
people,
(2)
process
and
procedure,
and
(3)
physical
structure
of
the
facility.
People
include
in-‐house
personnel
who
have
constant
direct
access
to
the
process
flow,
delivery
personnel
who
can
intentionally
introduce
hazards
to
raw
materials
or
finished
products
during
transport,
contract
cleaners
and
pest
control
service
providers
who
have
access
to
the
processing
facility
before,
during
and/or
after
food
processing;
and
visitors
who
may
have
limited
time
to
introduce
contaminants
but
may
successfully
do
the
job
if
there
are
weaknesses
in
the
security
in
the
processing
area.
The
nature
of
a
process
step
or
procedure
can
also
affect
the
ease
of
introducing
contaminations
to
the
food
product.
A
highly
manual
unit
operation
that
requires
long
contact
time
with
a
food
handler
is
significantly
more
vulnerable
to
intentional
contamination,
compared
to
a
unit
operation
that
is
fully
automated
and
with
minimal
human
intervention.
Furthermore,
a
unit
operation
that
is
thoroughly
and
uniformly
mixed,
and
involves
large
volumes
of
food
materials,
is
an
ideal
target
for
intentional
contamination,
as
successful
hazard
introduction
may
not
be
easily
detected,
and
may
result
to
more
consumer
exposure,
respectively.
Finally,
the
physical
structure
of
the
food
processing
area
may
contribute
to
vulnerability
of
the
product
towards
intentional
contamination.
Physical
barriers
preventing
entry
to
the
processing
area
include
doors
and
windows,
vents,
fences
and
gates.
Even
light
and
CCTV
installations
within
and
outside
the
processing
area
can
influence
product
vulnerability
to
attacks.
5.2.2.
Factors
Contributing
to
Unit
Operation
Vulnerability
In
general,
factors
that
contribute
to
high
vulnerability
and
accessibility
are
the
following:
1. Large
batch
size.
Successful
contamination
of
large
batch
size
may
similarly
result
in
a
large
number
of
population
that
will
consume
the
tainted
product.
2. Uniform
mixing.
A
unit
operation
that
involves
constant,
uniform
mixing
is
an
attractive
point
of
attack
since
the
contaminant
shall
be
homogenously
distributed
within
the
food
system,
ensuring
large
number
of
tainted
products.
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Defense
Guidance
for
Industry
3. Serving
size.
A
product
with
a
serving
size
small
enough
to
be
consumed
in
one
sitting,
containing
harmful
dose
of
an
agent,
is
ideal
for
an
attack
since
it
will
ensure
maximum
harm
to
consumers.
4. Short
shelf-‐life.
A
product
with
short
shelf-‐life
is
preferred
since
these
are
immediately
consumed
in
large
numbers
that
could
similarly
result
in
large
number
of
affected
consumers.
5. Ability
to
disguise
the
contaminant.
A
contaminant
not
easily
detectable
in
the
food
system
is
ideal
for
an
attacker.
6. High
impact
consumer
such
as
children
and
elderly.
Successful
attack
of
products
consumed
by
children
and
elderly
shall
result
in
greater
damage
to
public
morale.
7. Lack
of
processing/preparation
steps
to
inactivate
or
reduce
the
harmful
agent.
Some
biological
and
chemical
agents
may
easily
be
inactivated
by
heating
and
other
processing
steps.
USFDA
conducted
vulnerability
assessments
for
selected
food
products/categories.
Vulnerability
assessment
results
showed
that
common
vulnerabilities
exist
regardless
of
particular
food
product.
Common
vulnerabilities
can
be
organized
into
several
broad
activity
types:
1. Activity
Type
I
(coating,
mixing,
grinding
and
rework)
-‐
effect
of
these
steps
would
be
the
even
distribution
of
a
contaminant
2. Activity
Type
II
(ingredient
staging,
ingredient
preparation
and
ingredient
addition)
–
open
process
steps
with
access
to
product
stream
3. Activity
Type
III
(bulk
liquid
receiving
and
bulk
liquid
loading)
–
high
probability
of
uniform
mixing
4. Activity
Type
IV
(bulk
liquid
holding
and
non-‐liquid
holding
and
surge
tanks)
–
tanks
are
often
agitated
to
prevent
separation;
often
in
isolated
areas
of
facility
5.2.3.
The
CARVER
+
Shock
Tool
for
Vulnerability
Assessment
One
of
several
tools
that
can
be
used
in
the
identification
and
prioritization
of
process-‐
related
vulnerabilities
is
the
CARVER
+
Shock
program.
In
this
document,
this
tool
shall
be
used
as
a
model
due
to
its
systematic
evaluation
of
potentially
vulnerable
unit
operations.
Poore
(2010)
described
that
the
CARVER
+
Shock
has
been
adapted
from
the
military-‐
based
CARVER
program,
which
was
originally
developed
as
a
targeting
tool
for
the
US
Special
Operations
Forces
to
thoroughly
analyze
enemy
infrastructure
and
identify
critical
nodes.
In
military
term,
a
critical
node
or
target
critical
damage
point
is
an
element,
position
or
command
and
control
entity,
which
when
disrupted
immediately
degrades
the
ability
of
the
enemy
to
conduct
combat
operations.
Hence
in
the
food
processing
14
PHILIPPINE
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Food
Defense
Guidance
for
Industry
environment,
a
critical
node
is
that
particular
unit
operation
that
when
successfully
attacked,
could
result
in
significant
public
health
and
economic
impact.
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Food
Defense
Guidance
for
Industry
• alarm
system
• CCTV
• perimeter
fence
7.
Training
Tools
and
Resources
Training
program
should
be
defined
to
ensure
that
personnel
are
aware
of
the
Food
Defense
System
and
understand
their
responsibilities
in
its
effective
implementation.
Several
training
tools
were
developed
by
the
USFDA
that
may
be
used
as
reference.
Employees
FIRST
is
a
USFDA
training
program
designed
to
educate
frontline
workers
on
the
first
line
of
defense
in
preventing
intentional
contamination
of
the
food
supply.
FIRST
is
the
acronym
for
five
(5)
rules
on
food
defense:
• Follow
company
food
defense
plans
• Inspect
your
work
area
and
surrounding
areas
• Recognize
anything
out
of
the
ordinary
• Secure
all
ingredients,
supplies
and
finished
product
• Tell
management
if
you
notice
anything
unusual
or
suspicious
ALERT
initiative
is
a
training
program
intended
to
raise
awareness
of
state
and
local
government
agencies
and
industry
representatives
on
food
defense
issues
and
preparedness.
It
applies
to
all
aspects
of
the
farm-‐to-‐table
continuum.
It
identifies
five
(5)
key
food
defense
points:
• A-‐
How
do
you
ASSURE
that
the
supplies
and
ingredients
you
use
are
from
safe
and
secure
sources?
• L-‐
How
do
you
LOOK
after
the
security
of
the
products
and
ingredients
in
your
facility?
• E-‐
What
do
you
know
about
your
EMPLOYEES
and
people
coming
in
and
out
of
your
facility?
• R-‐
Could
you
provide
REPORTS
about
the
security
of
your
products
while
under
your
control?
• T-‐
What
do
you
and
who
do
you
notify
if
you
have
a
THREAT
on
issue
at
a
facility,
including
suspicious
behavior?
USFDA
developed
Food
Defense
101
training,
a
vulnerability
assessment
software
tool
(CARVER+Shock),
a
mitigation
strategies
database,
the
Food
Related
Emergency
Exercise
Bundle
(FREE-‐B)
kit,
and
a
food
defense
plan
builder,
all
are
available
online,
and
can
be
downloaded
for
free.
The
following
Food
Defense
Industry
Guidance
documents
have
likewise
been
developed
by
USFDA
for
the
following
stakeholders
which
is
available
in
the
USFDA
website
(http://www.fda.gov/fooddefense):
• Food
Producers,
Processors
and
Transporters
• Importers
and
Filers
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NATIONAL
STANDARD
PNS/BAFPS
134:2013
Food
Defense
Guidance
for
Industry
• Retail
Food
Stores
and
Food
Service
Establishments
• Dairy
Farms,
Bulk
Milk
Transporters,
Bulk
Milk
Transfer
Stations
and
Fluid
Milk
Processors
Similarly,
FSIS
of
the
USDA,
developed
Food
Defense
Guidance
for
food
processors,
importers,
transporters,
and
distributors
that
can
be
accessed
at
http://www.fsis.usda.gov/wps/portal/fsis/topics/food-‐defense-‐defense-‐and-‐emergency-‐
response
• Food
Defense
Guidelines
for
Slaughtering
and
Processing
Establishments,
Warehouse
and
Distribution
Centers
• FSIS
Safety
and
Security
Guidelines
for
the
Transportation
and
Distribution
of
Meat,
Poultry
and
Egg
Products
• Guidelines
for
the
Disposal
of
Intentionally
Contaminated
Food
Products
and
the
Decontamination
of
Food
Processing
Facilities
8.
Assessment
of
Effectiveness,
Audits
and
Corrective
Actions
The
facility
should
establish
internal
quality
audit
to
verify
the
effectiveness
of
the
Food
Defense
Plan.
Internal
audit
will
help
give
objective
evidence/proof
that
the
Food
Defense
Plan
is
carried
out
effectively
in
the
facility.
Records
of
internal
audit
and
noted
non-‐
conformities
shall
be
given
attention
by
the
management
for
continuous
improvement,
assess
capability
of
facility
processes,
etc.
Audit
findings
will
serve
as
evidence
or
benchmark
data
for
the
effectiveness
of
the
policy,
procedure
or
requirement.
Verification
of
the
corrective
actions
should
be
made
to
ensure
conformity
to
the
requirements.
9.
Food
Defense
Documents
and
Records
Some
recommended
documents
and
records
to
effectively
carry
out
the
Food
Defense
Plan
include
the
following:
Documents
• Vicinity
Map
• Floor
Plan
• Emergency
Evacuation
Plan
• Crisis
Management/Contingency
Plan
• Human
Resource
(HR)
Training
Program
• Traceability
and
Recall
Program
• Personnel
Security
Measures
Records
17
PHILIPPINE
NATIONAL
STANDARD
PNS/BAFPS
134:2013
Food
Defense
Guidance
for
Industry
• Visitor/Suppliers
Entry
Slips
• Loading/Unloading
Inspection
Report
• Product
Recall
Exercise
Form
• Chemical/Hazardous
Material
Control
Log
• Food
Defense
Plan
Review
Form
• Record
of
Food
Defense
Plan
Testing
• CCTV
Recordings
10.
Annex
Annex
1
–Sample
Vulnerability
Assessment
Exercise
11.
References
http://medical-‐dictionary.thefreedictionary.com/radionuclide
http://www.accessdata.fda.gov/scripts/fooddefensemitigationstrategies/
http://www.fda.gov/Food/FoodDefense/ToolsEducationalMaterials/ucm349888.htm
http://www.foodsafety.gov/
http://www.fsis.usda.gov
http://www.fsis.usda.gov/shared/PDF/Food_Defense_Plan.pdf
http://www.fsis.usda.gov/wps/portal/fsis/topics/food-‐defense-‐defense-‐and-‐emergency-‐
response
http://www.fsis.usda.gov/wps/portal/fsis/topics/food-‐defense-‐defense-‐and-‐emergency-‐
response/preparation-‐and-‐prevention/guidance-‐documents/risk-‐mitigation-‐tool/ct_index
http://www.fsis.usda.gov/wps/wcm/connect/63fb5993-‐97ac-‐4414-‐b5d6-‐
f9c329d13c74/Food_Defense_Plant_Brochure_Slaughter.pdf?MOD=AJPERES
http://www.fsis.usda.gov/wps/wcm/connect/99f95182-‐0c9e-‐4214-‐9762-‐
e98197f54ebf/General-‐Food-‐Defense-‐Plan-‐9-‐3-‐09+_2_.pdf?MOD=AJPERES.
http://www.meathaccp.wisc.edu/additional_info/assets/Guide%20Food%20Processing.p
df
http://www.merriam-‐webster.com
http://www.merriam-‐webster.com/dictionary/diversion
18
PHILIPPINE
NATIONAL
STANDARD
PNS/BAFPS
134:2013
Food
Defense
Guidance
for
Industry
http://www.thefreedictionary.com/radiological
http://www.thefreedictionary.com/tainted
http://www.who.int/foodsafety/publications/general/en/terrorist.pdf
www.fda.gov/fooddefense
Mackza,
Carol
PhD.
2008.
Food
Safety
vs.
Food
Defense:
Differences
and
Similarities:
Protecting
the
Middle
East
Supply
from
Intentional
Contamination.
Presented
in
Cairo,
Egypt
last
29-‐31
January
2008.
Poore,
D.
(2010).
Protecting
Your
Food
Supply:
A
Practical
Approach.
Food
Safety
Magazine,
February-‐March
2010.
(http://www.foodsafetymagazine.com/article.asp?id=3536&sub=sub1
)
Republic
Act
10536
-‐
An
Act
Amending
Republic
Act
9296,
Otherwise
Known
as
the
Meat
Inspection
Code
of
the
Philippines.
15
May
2013.
Republic
Act
10611
–
An
Act
to
Strengthen
the
Food
Safety
Regulatory
System
in
the
Country
to
Protect
Consumer
Health
and
Facilitate
Market
Access
of
Local
Foods
and
Food
Products,
and
for
Other
Purposes.
28
August
2013.
Republic
Act
9296
-‐
Meat
Inspection
Code
of
the
Philippines
and
Its
Implementing
Rules
and
Regulations.
October
2005.
19
PHILIPPINE
NATIONAL
STANDARD
PNS/BAFPS
134:2013
Food
Defense
Guidance
for
Industry
Annex
1:
Sample
Vulnerability
Exercise
Milk
in
Gable-‐Top
Cartons:
A
Sample
Vulnerability
Assessment
Exercise
The
following
is
an
example
of
a
vulnerability
assessment
(VA)
exercise
that
uses
the
CARVER
+
Shock
as
a
VA
tool.
As
previously
discussed
in
the
Food
Defense
Guidance
for
the
Industry
of
the
Bureau
of
Agriculture
and
Fisheries
Product
Standards,
VA
is
an
important
part
of
coming
up
with
a
Food
Defense
Plan
since
it
allows
the
processor
to
determine
which
particular
unit
operation/s
or
step/s
(or
node/s)
in
the
process
is/are
most
vulnerable
to
attack.
This
example
borrowed
from
Poore
(2010)
uses
one
of
the
many
VA
tools
available.
The
choice
for
CARVER
+
Shock
is
due
to
its
simplicity
and
the
systematic
method
with
which
each
of
the
unit
operations
in
a
particular
process
may
be
evaluated.
The
following
is
a
step-‐by-‐step
example
that
can
be
used
to
guide
the
readers
to
conduct
their
own
VA,
in
the
development
of
their
own
Food
Defense
Plans.
1. Determine
what
are
you
trying
to
protect,
and
from
what
or
whom.
2. What
is
the
food
you
are
trying
to
protect?
3. What
is
the
concern
–
foodborne
illness,
death,
or
economics?
4. Who
or
what
does
the
attacker
look
like?
A
politically
motivated
outside
person,
a
disgruntled
employee,
or
a
disgruntled
employee
with
ties
to
outside
person(s).
5. What
agent
will
be
used
in
the
scenario/attack?
This
is
perhaps
the
most
difficult
aspect
of
the
analysis.
Careful
consideration
should
be
given
to
the
whole
process
in
choosing
the
appropriate
agent.
Choose
the
worst
case;
assume
that
successful
attack
is
highly
possible.
1
Poore, D. (2010). Protecting Your Food Supply: A Practical Approach. Food Safety Magazine, February-March
2010. http://www.foodsafetymagazine.com/article.asp?id=3536&sub=sub1
20
PHILIPPINE
NATIONAL
STANDARD
PNS/BAFPS
134:2013
Food
Defense
Guidance
for
Industry
Once
these
questions
have
been
answered,
do
not
be
tempted
to
change
them
in
the
middle
of
the
VA.
If
the
team
decides
to
do
so,
they
should
start
from
the
beginning
of
the
analysis.
Aside
from
the
details
found
in
the
flowchart,
the
Food
Defense
Team
should
have
access
to
other
information
such
as
those
related
to
product
distribution
and
sales,
consumers,
market
share
in
the
areas
where
the
product
is
distributed,
even
Good
Manufacturing
Practices
(GMP)
implemented
in
the
processing
facility.
Figure 1. An example of a detailed flowchart/process diagram for pasteurized milk (Kennedy, 2011)
21
PHILIPPINE
NATIONAL
STANDARD
PNS/BAFPS
134:2013
Food
Defense
Guidance
for
Industry
i. Criticality.
A
unit
operation
or
node
is
critical
when
an
agent
can
be
introduced
and
cause
significant
health
or
economic
impact.
In
evaluating
Criticality,
always
consider
successful
introduction
of
the
agent.
The
Criticality
may
be
evaluated
by
first
filling
up
the
following
worksheet.
Worksheet
1.
Worksheet
for
the
determination
of
Criticality
value
of
a
particular
unit
operation/node
For
this
particular
example,
consider
the
following.
These
information
shall
be
used
in
the
entire
CARVER
+
Shock
analysis.
22
PHILIPPINE
NATIONAL
STANDARD
PNS/BAFPS
134:2013
Food
Defense
Guidance
for
Industry
ii. Ricin
as
the
agent
of
attack,
with
a
harmful
level
of
2.0
mg
per
serving
iii. 87%
of
all
the
units
(8
oz.
milk
in
carton)
were
sold
before
the
attack
was
discovered,
and
the
warning
came
out
iv. 50%
of
the
sold
units
were
consumed,
one
unit
was
consumed
by
one
person
v. The
mortality
rate
is
50%
vi. Product
distribution
is
through
retail
outlets
in
areas
near
colleges
or
universities
vii. The
market
share
for
this
company’s
milk
is
75%
in
the
area
viii. The
plant
that
was
attacked
is
one
of
five
in
the
corporation.
There
are
three
fluid
milk
plants,
one
ice
cream
plant,
and
one
cultured
products
plant
Worksheet
2.
Filled
worksheet
for
the
determination
of
Criticality
value
of
a
particular
unit
operation/node
23
PHILIPPINE
NATIONAL
STANDARD
PNS/BAFPS
134:2013
Food
Defense
Guidance
for
Industry
Table
1.
Criticality
score
scale
Loss of more than 10,000 lives OR loss of more than $100 B. 9-‐10
(*Note:
If
looking
on
a
company
level,
loss
of
>
90%
of
the
total
economic
value
for
which
you
are
concerned.)
Loss of life is between 1,000 and 10,000 OR loss of $10B to $100B. 7-‐8
(Note:
If
looking
on
a
company
level,
loss
of
between
61%
and
90%
of
the
total
economic
value
for
which
you
are
concerned.)
Loss of life is between 100 and 1,000 OR loss of $1B to $10B. 5-‐6
(Note:
If
looking
on
a
company
level,
loss
of
between
31%
and
61%
of
the
total
economic
value
for
which
you
are
concerned.)
Loss of fewer than 100 lives OR loss of $100M to $1B. 3-‐4
(Note:
If
looking
on
a
company
level,
loss
of
between
10%
and
30%
of
the
total
economic
value
for
which
you
are
concerned.)
No loss of life OR loss of less than $100M. 1-‐2
(Note:
If
looking
on
a
company
level,
loss
of
<10%
of
the
total
economic
value
for
which
you
are
concerned.)
*Note:
The
economic
loss
could
depend
upon
different
factors.
If
your
facility
is
part
of
a
large
multinational
organization,
the
financial
impact
may
not
be
as
severe
when
compared
to
a
regional
organization
that
has
a
couple
of
local
plants.
Note
that
the
Criticality
scale
should
not
imply
that
a
certain
loss
of
life
is
‘acceptable,’
but
should
be
used
to
determine
the
impact
of
an
attack
on
certain
nodes
within
the
process.
Therefore,
based
on
the
Criticality
worksheet
analysis
in
Worksheet
2,
the
attack
will
be
very
successful,
and
based
on
the
score
scale
in
Table
1,
the
Team
should
give
this
unit
operation/node
(pasteurized
silo)
a
score
of
10.
24
PHILIPPINE
NATIONAL
STANDARD
PNS/BAFPS
134:2013
Food
Defense
Guidance
for
Industry
ii. Accessibility.
To
evaluate
and
give
Accessibility
score
to
the
unit
operation/node
in
question,
the
Food
Defense
Team
should
have
information
on
the
location
of
that
particular
unit
operation,
as
well
as
the
environmental
conditions
to
which
the
operation
is
exposed.
For
example,
in
the
unit
operation
earlier
evaluated
for
Criticality,
the
following
information
is
needed
to
continue
with
the
VA.
i. The
pasteurized
silos
are
in
the
upper
level
of
the
plant
without
much
traffic,
but
workers
pass
through
this
area
to
access
the
pasteurizer.
ii. The
lighting
is
kept
dim
to
save
energy,
and
there
are
no
cameras
in
the
area.
iii. The
silos
are
filled
from
the
top
and
have
vents
to
the
side
of
the
fill
tubes
that
are
accessible.
iv. There
is
an
attached
ladder
on
the
front
of
the
tank,
which
allows
access
to
the
fill
tubes
and
vents.
v. The
tanks
are
only
required
to
be
washed
every
24
h
and
can
be
filled
multiple
times
between
washings.
Based
on
these
information,
assess
the
Accessibility
of
the
unit
operation/node;
and
give
a
score
based
on
the
scale
presented
in
Table
2.
Based
on
the
description,
the
tanks
would
be
fairly
accessible.
Proper
exclusion
practice
is
not
practiced,
hence
everyone
in
the
plant
could
have
access
to
it.
However,
attacking
the
silo
may
not
very
easy
since
the
tanks
are
elevated
and
an
attacker
climbing
the
ladder
on
the
silo
will
certainly
be
noticeable.
Based
on
the
scale
in
Table
2,
the
team
can
give
it
an
Accessibility
score
of
7.
iii. Recognizability.
The
following
additional
information
shall
help
the
team
assess
the
Recognizability
of
the
unit
operation/node
in
question.
i. The
tanks
are
made
of
stainless
steel,
located
close
to
the
pasteurization
system,
and
are
very
large.
ii. Even
untrained
person
shall
easily
identify
the
tanks.
iii. A
photograph
would
be
adequate
to
show
what
a
target
should
look
like.
Based
on
these
information,
assess
the
Recognizability
of
the
unit
operation/node;
and
give
a
score
based
on
the
scale
presented
in
Table
3.
The
Team
can
give
this
unit
operation
a
Recognizability
score
of
8.
iv. Vulnerability.
The
following
additional
information
shall
help
the
Team
assess
the
Vulnerability
of
the
unit
operation/node
in
question.
i. Each
of
the
tanks
has
a
ladder
in
front
of
it,
and
a
person
has
to
climb
the
ladder
to
introduce
the
agent.
ii. At
the
top
of
the
tank,
6
feet
from
the
floor
of
the
platform
is
a
2.5-‐inch
filling
port.
iii. The
tanks
are
not
labeled
to
indicate
that
they
contain
pasteurized
product,
but
‘everyone’
knows
the
tanks
are
for
pasteurized
milk.
Table
2.
Accessibility
score
scale
25
PHILIPPINE
NATIONAL
STANDARD
PNS/BAFPS
134:2013
Food
Defense
Guidance
for
Industry
Accessibility
Criteria
Score
Easily
Accessible
(e.g.
target
is
outside
building
and
there
is
no
perimeter
fence).
9-‐10
Limited
physical
or
human
barriers
or
observation.
Attacker
has
nearly
unlimited
access
to
the
target.
Attack
can
be
carried
out
using
moderate
to
large
volumes
of
contaminant
without
undue
concern
over
detection.
Multiple
sources
of
information
about
the
facility
and
the
target
are
readily
available.
Accessible
(e.g.
target
is
inside
building
but
in
an
unsecured
part
of
the
facility).
7-‐8
Human
observation
and
physical
barriers
limited.
Attacker
has
access
to
the
target
for
an
hour
or
less.
Attack
can
be
carried
out
with
moderate
to
large
volumes
of
contaminant,
but
requires
the
use
of
stealth.
Only
limited
specific
information
is
available
on
the
facility
and
the
target.
Partially
Accessible
(e.g.
inside
building
in
a
relatively
unsecured
but
busy
part
of
the
5-‐6
facility).
Under
constant
possible
human
observation.
Some
physical
barriers
may
be
present.
Contaminant
must
be
disguised,
and
time
limitations
are
significant.
Only
general,
non-‐specific
information
is
available
on
the
facility
and
the
target.
Hardly
Accessible
(e.g.
inside
building
in
a
secured
part
of
the
facility).
Human
3-‐4
observation
and
physical
barriers
with
an
established
means
of
detection.
Access
generally
restricted
to
operators
or
authorized
persons.
Contaminant
must
be
disguised
and
time
limitations
are
extreme.
Limited
general
information
available
on
the
facility
and
the
target.
Not
Accessible.
Physical
barriers,
alarms,
and
human
observation.
Defined
means
of
1-‐2
intervention
in
place.
Attacker
can
access
target
for
less
than
5
minutes
with
all
equipment
carried
in
pockets.
No
useful
publicly
available
information
concerning
the
target.
26
PHILIPPINE
NATIONAL
STANDARD
PNS/BAFPS
134:2013
Food
Defense
Guidance
for
Industry
Recognizability
Criteria
Score
The target is clearly recognizable and requires little or no training for recognition 9-‐10
The target is easily recognizable and requires only a small of training for recognition 7-‐8
The
target
is
difficult
to
recognize
or
might
be
confused
with
other
targets
or
target
5-‐6
components
and
requires
some
training
for
recognition
The
target
is
difficult
to
recognize.
It
is
easily
confused
with
other
targets
or
3-‐4
components
and
requires
extensive
training
for
recognition
Notice
that
it
may
not
be
easy
to
add
approximately
320
g
ricin
(Worksheet
1)
through
a
2.5-‐inch
port,
especially
considering
that
the
port
is
an
access
point
to
the
pasteurizer
for
other
employees
as
well.
If
an
attacker
is
detected,
an
employee
might
ask
why
the
individual
is
adding
something
to
the
port.
To
assess
the
Vulnerability
of
the
unit
operation/node
in
question,
refer
to
Table
4
for
score
scale.
The
Team
could
give
this
unit
operation
an
Vulnerability
score
of
6.
Target characteristics allow for easy introduction of sufficient agents to achieve aim. 9-‐10
Target
characteristics
almost
always
allow
for
introduction
of
sufficient
agents
to
7-‐8
achieve
aim.
Target
characteristics
allow
30%
to
60%
probability
that
sufficient
agents
can
be
5-‐6
added
to
achieve
aim.
Target
characteristics
allow
moderate
probability
(10%
to
30%)
that
sufficient
3-‐4
agents
can
be
added
to
achieve
aim.
27
PHILIPPINE
NATIONAL
STANDARD
PNS/BAFPS
134:2013
Food
Defense
Guidance
for
Industry
Target
characteristics
allow
low
probability
(<10%
)
that
sufficient
agents
can
be
1-‐2
added
to
achieve
aim.
v. Effect.
The
following
additional
information
shall
help
the
Team
assess
the
Effect
to
the
company
of
the
successful
attack
of
the
unit
operation/node
in
question.
i. The
plant
is
a
well-‐known
entity
in
the
area,
producing
a
regional,
name-‐brand
product.
It
has
75%
market
share
for
the
product
that
it
sells
within
the
region.
ii. The
plant
would
be
shut
down,
and
the
milk
sales
would
drop
to
zero.
iii. Other
product
sales
will
also
suffer
greatly.
Assess
the
Effect
and
give
an
appropriate
score
by
referring
to
Table
5.
Based
on
these
information,
the
Team
could
easily
give
a
score
of
10.
vi. Recuperability.
As
described,
this
scenario
is
going
to
be
a
major
disaster
to
the
plant.
The
concern
is
to
estimate
how
long
it
will
take
for
the
plant
to
recover
the
publicity
associated
28
PHILIPPINE
NATIONAL
STANDARD
PNS/BAFPS
134:2013
Food
Defense
Guidance
for
Industry
with
the
contamination.
Also,
consider
how
long
it
will
take
to
clean
the
facility
(should
it
survive),
and
how
challenging
it
may
be
to
regain
consumer
confidence
and
market
share.
Based
on
the
fact
that
there
were
so
many
deaths,
it
is
highly
unlikely
that
the
plant
or
even
the
entire
organization
will
ever
recover.
Referring
to
Table
6
for
score
scale,
the
Team
can
give
this
unit
operation
a
score
of
10.
vii. Shock.
This
attribute
is
a
combined
evaluation
of
individual
emotions.
Shock
is
considered
on
a
national
level.
It
is
especially
dramatic
if
the
event
occurs
on
or
close
to
a
holiday,
or
affects
children,
and
the
elderly.
Consider
all
of
the
emotional
factors
when
evaluating
Shock.
In
evaluating
Shock,
ask,
“How
would
I
feel
if
this
were
to
happen?”
The
number
of
deaths
in
this
particular
unit
operation/node
being
evaluated
is
high,
and
could
easily
be
given
a
score
of
10
(Table
7).
Consider
that
it
would
affect
young
adults
going
to
a
college
or
a
university.
Furthermore,
because
the
product
is
sold
at
the
retail
level,
the
incident
would
affect
individuals
of
all
ages.
A
serving
size
of
8
oz.
could
also
be
targeted
because
smaller
children
also
consume
this
product,
as
well
as
elderly
who
do
not
drink
a
lot
of
milk.
29
PHILIPPINE
NATIONAL
STANDARD
PNS/BAFPS
134:2013
Food
Defense
Guidance
for
Industry
After
evaluating
all
seven
(7)
CARVER
+
Shock
parameters,
consolidate
all
the
scores
for
each
of
the
unit
operations/node
evaluated
(Worksheet
3).
One
can
expect
several
nodes
for
a
complex
processing
operation
with
multiple
sub-‐processes;
and
fewer
nodes
for
a
straightforward
process.
Compare
the
summed
scores
of
all
nodes
to
identify
the
critical
node/s,
which
can
be
prioritized
in
the
establishment
of
mitigation
measures.
CARVER
+
Shock
is
a
valuable
tool
that
may
be
used
to
help
protect
the
food
chain
‘from
farm
to
fork.’
When
completing
the
analysis
process,
do
not
forget
to
consider
people,
visitors,
contractors,
vendors,
haulers,
records,
equipment
and
supplies,
interior
and
exterior
factors,
and
all
processes
from
incoming
and
outgoing
products.
It
has
been
observed
–
wisely
–
that
‘food
at
rest
is
food
as
risk.’
Target
has
major
historical,
cultural,
religious,
or
other
symbolic
importance.
Loss
of
9-‐10
more
than
10,000
lives.
Major
impact
on
sensitive
subpopulations,
such
as
children
or
the
elderly.
National
economic
impact
more
than
$100
billion.
Target
has
high
historical,
cultural,
religious,
or
other
symbolic
importance.
Loss
of
7-‐8
between
1,000
and
10,000
lives.
Significant
impact
on
sensitive
subpopulations,
such
as
children
or
the
elderly.
National
economic
impact
between
$10
billion
and
$100
billion.
Target
has
moderate
historical,
cultural,
religious,
or
other
symbolic
importance.
Loss
5-‐6
of
between
100
and
1,000
lives.
Moderate
impact
on
sensitive
subpopulations,
such
as
children
or
the
elderly.
National
economic
impact
between
$1
billion
and
$10
billion.
Target
has
little
historical,
cultural,
religious,
or
other
symbolic
importance.
Loss
of
3-‐4
fewer
than
100
lives.
Small
impact
on
sensitive
subpopulations,
such
as
children
or
the
elderly.
National
economic
impact
between
$100
million
and
$1
billion.
Target
has
little
historical,
cultural,
religious,
or
other
symbolic
importance.
Loss
of
1-‐2
fewer
than
100
lives.
Small
impact
on
sensitive
subpopulations,
such
as
children
or
the
elderly.
National
economic
impact
between
$100
million
and
$1
billion.
30
PHILIPPINE
NATIONAL
STANDARD
PNS/BAFPS
134:2013
Food
Defense
Guidance
for
Industry
Worksheet
3.
Summary
sheet
for
scoring
unit
operations/nodes
across
CARVER
+
Shock
attributes
31
PHILIPPINE
NATIONAL
STANDARD
PNS/BAFPS
134:2013
Food
Defense
Guidance
for
Industry
Department
of
Agriculture
(DA)
1. Rubina
O.
Cresencio,
DVM
-‐
Bureau
of
Animal
Industry
(BAI)
2. Orlando
C.
Ongsotto,
DVM
-‐
National
Meat
Inspection
Service
(NMIS)
3. Clarita
M.
Sangcal,
DVM
-‐
NMIS
4. Marvin
B.
Vicente,
DVM
–
NMIS
5. Consuelo
C.
Baltazar/Timothy
Joseph
S.
Lazaro
-‐
Bureau
of
Fisheries
and
Aquatic
Resources
(BFAR)
6. Simeona
E.
Regidor
–BFAR
7. Dennis
E.
Tiotangco
-‐
BFAR
8. Sonia
T.
Hernandez
-‐
Bureau
of
Plant
Industry
(BPI)
9. Lucita
M.
Falcatan/Josephine
T.
Nieva
-‐
Philippine
Coconut
Authority
(PCA)
10. Dina
B.
Masa
–
PCA
11. Marcelino
M.
Guevarra
-‐
Sugar
Regulatory
Administration
(SRA)
12. Magdalena
D.
Palanca
–
SRA
13. Jean
Nanette
C.
Sumagaysay
-‐SRA
14. Alberto
R.
Cariso
Jr./Carmelita
V.
Alkuino
-‐
Food
Development
Center
(FDC)
15. Judith
A.
Platero
–
National
Dairy
Authority
Members
-‐
Department
of
Health
(DOH)
16. Ma.
Theresa
C.
Cerbolles
-‐
Food
and
Drug
Administration
(FDA)
17. Jesusa
Joyce
N.
Cirunay-‐
FDA
18. Minda
G.
Villa,
M.D./Josefina
P.
Giliberte
-‐
Bureau
of
Quarantine
(BOQ)
19. Richard
B.
Laroya
-‐
BOQ
20. Shirley
F.
Rillo/Jelene
N.
Jose
–
BOQ
32
PHILIPPINE
NATIONAL
STANDARD
PNS/BAFPS
134:2013
Food
Defense
Guidance
for
Industry
Secretariat
Chairperson
Karen
Kristine
A.
Roscom
Chief
Science
Research
Specialist
Standards
Development
Division
BAFPS-‐
DA
Member
Charlie
T.
Palilio
Research
Assistant
I
Standards
Development
Division
BAFPS-‐DA
33