Food Defense Vulnerability Assessment
Conducting a Food Defense Vulnerability AssessmentKAT versus Three Elements
Why Perform Vulnerability Assessments at All?
Preliminary Steps for Every Vulnerability Assessment
Step 1: Assemble a food defense team
Assembling a multi-disciplinary team of individuals with various backgrounds and experiences will help identify vulnerabilities within your facility. A team approach also helps with employee buy-in of the program.
Step 2: Describe the product under evaluation
Product descriptions can include things like product names, ingredients, intended use, intended consumers, serving sizes, storage and distribution, etc.
Step 3: Develop a flow diagram
These diagrams should include all steps in your facility that are part of the food manufacturing operation. Processes that are not part of food manufacturing, such as utilities, human resources, etc. need not be part of the flow diagram.
Step 4: Describe the process steps under evaluation
Process step description should contain details about what happens at each of the process steps being evaluated. Important details to include would be the number of employees involved at each step, amount of product (weight/volume) associated with the step, speed of equipment, nature of the product (liquid/powder), etc.
The Key Activity Type (KAT) MethodWhat are Key Activity Types?
Examples would be batter and breading of products, homogeneously mixing a powder, dough or liquid ingredient, grinding of food products into finer particles, and reworking previous batches of product into new or other batches.
Processing steps where ingredients are manipulated prior to or during addition by human contact. Automated/machine manipulated is not included. Examples might include staging of ingredients, measuring, weighing and other batching steps and physically adding ingredients directly into a product stream.
Processing steps where bulk liquids are being received or unloaded where transport vehicles are opened, vented and where pumping equipment may be attached.
Liquid Storage/Holding/Surge Tanks
Processing steps where liquid ingredients are stored in bulk, such as in silos and large tanks, including surge tanks.
The KAT food defense vulnerability assessment method
1. Identify Each Step
2. Evaluate Each Step
3. Identify Any Actionable Process Steps
If any steps are identified as key activity types, then you would consider each of those steps actionable process steps. These actionable process steps are considered significant vulnerabilities in your process.
For each actionable process step identified, the team will need to think about what type of mitigation strategy would significantly reduce the probability of a successful inside attack. We will talk more about mitigation strategies in Part 3 of our Food Defense Series.
The Three Element Method
Using the three element method is a little more complex than the KAT method. However, using this method will allow you to take a deeper dive into your risk assessment for each process under evaluation. This gives you more flexibility than the KAT method to decide whether or not the process step under evaluation truly has a significant vulnerability. Using this method can oftentimes result in less actionable process steps that your facility will need to monitor as part of your food defense plan.
The food defense team would still start by using the process flow diagram as a guide for the vulnerability assessment. But instead of needing to identify if any of the process steps are key activity types, the team will need to assess the vulnerability by evaluating the following three elements for each step:
1. The public health impact
A. Volume of food at risk
B. Representative contaminant
C. Contaminant-specific analysis
2. The degree of physical access to the product
This element focuses on determining if an inside attacker could actually access or touch the product at the step under evaluation. A different scoring chart is provided for this element. If a product is “easily accessible” for instance, that would provide the highest risk and be issued a score of 10. But if the product is considered “hardly accessible”, then a score of only a 3 would be issued.
This element also considers a new concept called “inherent characteristics.” Inherent characteristics are those activities, practices, conditions, etc. that are integral to the operation and make intentional adulteration difficult. For instance, if a step in the process was completely enclosed, this would be an inherent characteristic that would make the step low risk due to it being inaccessible during operations.
3. The ability of an attacker to successfully contaminate the product
This element focuses on determining if an inside attacker would be able to successfully contaminate the product if they had the opportunity. The food defense team would need to consider factors such as:
- Would the attacker have enough time to contaminate the food without being observed?
- Would the attacker have to engage in suspicious activity and likely be noticed by other employees in order to successfully contaminate the product?
- Would the attacker be able to add enough of a contaminate to have a sufficient quantity to cause acute illness or death if consumed.
- Would the contaminate, if added successfully, be homogeneously mixed throughout the food?
Like the previous two elements, this element also has its own scoring chart. A high score of 10 has the highest ease of successful contamination where there may be few workers in the area, a sufficient volume of contaminate could be added and that contaminate would be evenly distributed throughout the food.
Identification of Actionable Process Steps
The Hybrid Approach
Like performing a hazard analysis for a food safety plan, conducting a food defense vulnerability assessment for your food defense plan should be where you spend a large portion of your time as you develop your program. Understanding the potential vulnerabilities throughout your facility and being able to properly risk-assess those vulnerabilities using the methods we have discussed today are critical first steps in determining which areas are significantly vulnerable.
In our next installment of our 5 part series, we will be discussing how to effectively justify and explain decisions made in your vulnerability assessments. We will also discuss how to determine appropriate mitigation strategies for each actionable process step identified.
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