Regardless of the influence the new administration has on the FDA, the agency, of its own accord, appears to be expanding its role in safeguarding the nation's food supply. Still, bakers concerned about the safety and integrity of their products would be well advised to heed their own security.

The focus on food defense has increased dramatically since Sept. 11, 2001. Although the risks to bakeries are varied, “intentional contamination of products from outside threats or internal threats” ranks high among the list of concerns, notes Lance Reeve, director of food defense, AIB International, Manhattan, Kan. Workplace violence, also an issue within the baking industry, must be considered as well.

“There have been workplace violence issues from some larger bakeries during the past couple of years,” Reeve adds.

Bakeries must comply with the Public Health Security and Bioterrorism Preparedness and Response Act of 2002 (the Bioterrorism Act) that Congress passed in response to 9/11. Included among the Act's provisions are preparedness and response to bioterrorism and other public health emergencies; control of dangerous biological agents and toxins; food safety and protection against adulteration; and the safety of drinking water. Regarding additional food defense guidelines, the FDA offers a guidance document for the food and baking industry, but does not require compliance at this point, Reeve notes.

The FDA would like to have the authority to mandate food defense in the future, according to The Food Protection Act, published by the agency in November 2007. “This will be something to follow with changes in the FDA and the new administration this year,” Reeve adds. “A large scale contamination event would most likely usher in requirements for the food and baking industry.”

Bakers can use tools provided by the FDA and organizations, such as AIB International, to assess their bakeries' risk level. After 9/11, the FDA promoted an Operational Risk Management (ORM) program as a vulnerability assessment tool, but the agency now promotes CARVER + Shock, another prioritization risk assessment tool adapted from the military. CARVER assesses the vulnerability of a system to an attack, and the term “shock” refers to the health, economic and psychological impacts of an attack.

“Overall, the industry seems to be using one or both types of assessments,” Reeve says. “These assessments can be done by facility trained personnel or outside services can assist with these assessments.”

Regardless of the analytical tool used, bakers should analyze their food security programs, including record keeping, traceability and product recall; the protection of their grounds, storage systems and facility; and the welfare of their employees.

“Food defense should not only be implemented at the bakery, but companies also should implement food defense into their supplier approval system to assure that all suppliers of ingredients and packaging materials also have a food defense system. Transportation companies should be included in this system as well,” Reeve says.

Whether or not the FDA expands its intervention into issues regarding food defense shouldn't preclude bakers' proactive attention to the matter, particularly in this post-9/11 age.