Preparing for threats takes practice for governments, too

By Eric Greenberg, Attorney-at-Law on January 31, 2006

As it turns out, there has been more disaster preparation underway by the government than we knew. As far back as late 2004, government officials from state and federal agencies have been working together to anticipate terror attacks on the food supply and practice their reactions. The effort appears to have been a valuable preparation tool.

Of the many tragedies wrought by last year's Hurricane Katrina, several were of a political nature. We discovered, disastrously, that our state, local and especially federal officials were not sufficiently prepared to respond to this disaster, nor were they able to respond quickly or effectively enough once it arrived. This led many to believe that they also might not be prepared to address terror attacks.

Ideally, one would hope that these government bodies are prepared to act quickly to communicate with one another, coordinate their efforts, have the right people and equipment available and put these tools to work immediately to identify the nature of the problem and prevent as much damage as possible. Because terror might strike the food supply at any time, government agencies and companies have been focusing attention on preventing and minimizing the damage, especially since 9/11.

In September, we described the Strategic Partnership Program Agroterrorism Initiative announced last July (and we criticized the fact that it took four years since the 9/11 attacks to put it together—see PD, Sept. '05, p. 26). That initiative combined the U.S. Food & Drug Administration, the U.S. Dept. of Agriculture, the Department of Homeland Security, the Federal Bureau of Investigation and states and private industry to "protect the nation's food supply from terrorist threats."

Now comes word of a Food Security Surveillance Assignment that was led by FDA back in October and November of 2004. The report on it appeared in December 2005 (no idea why it took so long, but the concern may have been security; some details of the action are still not being made public). The assignment helped assure that relevant government bodies were ready for trouble.

For six weeks in late 2004, FDA's local district offices combined efforts with officials from 44 states and Puerto Rico to examine five food commodities considered at high risk for intentional contamination. The report on the project does not name the foods.

The effort built on information gathered under the 2002 Bioterror Act's new requirements for food-facility registration and prior notice of food imports. For example, inspections of food facilities were undertaken as part of the effort, and these included some facilities that were new to the Official Establishment Inventory. Also, more than 9,000 notices of importation were examined. Those notices had been filed under the Bioterror Act's requirement of prior notice of imports, and many of them were for the five commodities of interest. When this review resulted in what was considered a "high-risk" entry, specific follow-up inspections were assigned to FDA districts. More than 270 samples were collected and tested for a range of microbiological and chemical agents. All were negative, by the way.

This exercise, FDA is convinced, helped in a variety of ways. The agency noted, "While it is difficult to measure the level of deterrence that this assignment afforded, there was clearly a significant increase in food defense coverage, awareness and preparedness achieved by the preventive activities of state inspectors at multiple and targeted points in the food distribution system and through the communication with industry."

It is extremely encouraging to hear that all the relevant governments had thought through what might happen and practiced responding to such disasters. A crisis calls for swift action to be taken by multiple levels of government and industry as well. Don't underestimate the value of the kinds of exercises you sometimes see on the evening news when emergency responders simulate chemical spills or airport disasters. "Table-top" crisis management simulations force regulators and others to think about how they would respond to such an event, how they'd communicate with the industry and the public and with each other, how they would gather information, and what they would do from moment to moment.

These simulations are often the most relevant experiences government officials have to draw on when a real crisis strikes. They provide not only dry-run practice in gathering information and taking remedial action, but they also strengthen the bonds between and among the different levels of government—federal, state and local—as well as affected industry, which inevitably have to work together to combat a crisis.

One reassuring feature of this assignment is its apparent success at using information gathered from industry, such as the food establishment registration information and prior notice of food import, as tools to achieve the goal of protection. It's good to see this information used as an effective tool, rather than as a wasteful and burdensome bureaucratic irrelevance.

Another important byproduct of these thoughtfully designed preparatory efforts is mutual trust and familiarity among those government officials. Exercises like these help build that trust and familiarity, and those bonds, in turn, could make the difference between effective disaster response and a confused mess.

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