Special Event Food Defense Assignment (SEFDA) Report - March 2013

Executive Summary

The 2012 Special Event Food Safety and Defense Assignment (SEFSDA) is the latest food defense related Food and Drug Administration (FDA) field activity. The SEFSDA was designed as a proactive effort to prepare for the protection of food that would be served during the 2012 National Political Conventions, as well as to evaluate the existing assignment template to be used for future National Security Special Events (NSSEs). The Republican Convention was held August 27–30, 2012 in Tampa, FL. The Democratic Convention was held September 4–6, 2012 in Charlotte, NC. This assignment was planned and conducted jointly with our sister agency the United States Department of Agriculture/Food Safety Inspection Service (USDA-FSIS) and several FDA operational divisions (Center for Food Safety and Applied Nutrition (CFSAN), Office of Regulatory Affairs (ORA), as well as the Food Emergency Response Network (FERN) Laboratories, Office of Emergency Operations (OEO) and state and local regulatory agencies in North Carolina, South Carolina (due to the proximity to the host site) and Florida. Additionally, the RNC was occurring as Hurricane Isaac was making landfall, and some activities and timeframes were modified slightly in order to accommodate the public’s health and safety.

Phase I began the week of May 3, 2012 and concluded the week of June 3, 2012. During this pre-convention phase, federal, state and local inspectors collected samples, conducted inspections and performed traceback related activities. The assignment focused on the high-risk food manufacturing facilities, distributors, warehouses and retail food service establishments located nearby or in proximity to the convention site venues.

Phase II began the week of August 24, 2012 and concluded the week of September 6, 2012. During this pre-convention phase of the assignment, federal, state and local inspectors focused on high risk retail and food service establishments (included hotels and caterers), as well as food distribution centers whose products would likely be consumed by convention participants.

The over-arching goals of this assignment were to:

Exercise the planning and implementation of a coordinated approach for food protection during NSSEs events among federal, state and local agency partners.
Examine the traceability of ‘higher risk’ foods served at special events.
Evaluate the effectiveness of the existing special event assignment template used to coordinate food safety and food defense activities during NSSE/special events.

During the SEFSDA, regulatory participants were tasked with conducting records examinations and inspections as well as collecting and analyzing food samples. Throughout the duration of the assignment, 1028 inspections were made in the convention cities and nearby areas and 235 samples were analyzed. USDA-FSIS collected 584-lbs. of product and analyzed 76 samples. All samples analyzed were negative.

To the extent of our knowledge, there were no reports of food related illnesses associated and/or attributed to either the RNC or the DNC convention activities.

Background

In August and September of 2012, the Democratic and Republican National Conventions were hosted in Charlotte, North Carolina and Tampa, Florida respectively. In preparation for these high-profile political events, the Food and Drug Administration (FDA) took a proactive approach in planning and collaborating with its federal, state and local counterparts in the Southeast Region where these events were being hosted. The Southeast Region Field Office (SE–FO) had the lead in coordinating resources with the state and local regulatory officials for the Atlanta District Office (ATL-DO) and Florida District Office (FLA-DO). The Special Event Food Safety and Defense Assignment (SEFSDA) sought to achieve this effort while utilizing a previously created template (from the 2008 SEFSDA) for future food protection activities involving heightened security. Since 2008, the FDA has recognized tremendous partnership growth with our federal, state, local, tribal and territorial stakeholders, and some of these partnerships were leveraged in order to ensure the success of this assignment

Scope

This Special Event Food Safety and Food Defense Assignment (SEFSDA) allowed for multiple federal, state, and local partners to exercise the planning and implementation of a coordinated approach to food protection during high-profile special events. While no specific threat information had been received, the following commodities were selected for sampling and traceback: bottled water, milk, juices, peanuts and products containing peanut butter, lettuce, tomatoes, melons, coleslaw, frozen desserts and seafood. In addition, USDA-FSIS analyzed meat and poultry samples that were sampled by SCDHEC, Mecklenburg County and other surrounding NC counties.

The food commodities selected for this assignment were based on the region and geographical location of the convention sites and chosen in consultation with the state and local officials (including the NC Food Safety and Defense Taskforce).

During the assignment, participants were asked to:

Conduct routine food safety inspections of the firms
Disseminate and discuss food defense related information,
Complete and submit traceback information, and
Collect a sample and send to a Food Emergency Response Network (FERN) laboratory

The SEFSDA provided an opportunity to practice coordination, and communication among regulatory agencies that were involved in food safety and defense activities during the 2012 National Political Conventions Food Safety and Defense Assignment. It also helped to form the basis for future assignments related to National Security Special Events/special events for food protection.

The following outlines the specific goals set forth in the assignment along with specific outcomes of each of these goals.

Goal 1:

Enhance food safety practices and food defense preparedness in specific industry segments and among FDA, federal, state and local counterparts.

Accomplishments:

Federal, state, and local partners within the designated areas conducted inspections and collected samples at retail/food service establishments, food manufacturers and warehouses within a 100 mile radius of the venues hosting both the Democratic National Convention (DNC) and the Republican National Convention (RNC). The 100 mile radius was determined due to convention guests and/or delegates lodging and hosting events outside the hard zone of the host convention sites. The following entities performed inspections and collected samples of foods within their regulatory purview:

Democratic National Convention:

Mecklenburg County Health Department
North Carolina Department of Health and Human Services (NCDHHS)
North Carolina Department of Agriculture (NCDA)
South Carolina Department of Agriculture (SCDA)
South Carolina Department of Health & Environmental Control (SCDHEC)
Gaston County Health Department
Cleveland County Health Department
Lincoln County Health Department
Catawba County Health Department
Iredell County Health Department
Rowan County Health Department
Cabarrus County Health Department
Stanly County Health Department
Union County Health Department
FDA Atlanta District Office
FDA State Cooperative Programs, Regional Retail Food Specialists

Republican National Convention:

Florida Department of Business and Professional Regulations (DBPR)
Florida Department of Agriculture and Consumer Services (DACS)
FDA Florida District
FDA State Cooperative Programs, Regional Retail Food Specialists

All participating inspection personnel were tasked with discussing and disseminating FDA's food defense information and initiatives, including the ALERT program and”See Something Say Something” campaigns with their respective regulated industries. Inspectors from state and local regulatory agencies were asked to conduct a food safety inspection within their regulated industry and discuss food defense awareness and preparedness. Inspectors also collected samples of targeted food commodities and sent them to be analyzed by a participating FERN laboratory. Tracebacks were performed on these targeted samples also.

Phase I of the assignment served as a trial run for enhancing preparedness of food safety and food defense during the actual Democratic National Convention (DNC) and Republican National Conventions (RNC). Federal, state and local inspectors focused their activities on those food industry segments that would be servicing both the DNC and RNC.
Phase II of the assignment focused solely on inspections of retail food service establishments, food service vendors, distribution centers, caterers and hotels that serviced the convention venues and guests. During this phase, USDA/FSIS analyzed samples of meat and poultry products sampled by SCDHEC, Mecklenburg County and other surrounding countries

Goal 2:

Demonstrate a coordinated system for Federal, state, local, and territorial agencies’ response to events requiring special security procedures and demonstrate targeted preventive activities at various points in the food supply chain.

Accomplishments:

The activities performed during this assignment helped to evaluate the existing Special Event/assignment template that can be used for future National Security Special Events/special event activities, as well as guiding the development of future Standard Operating Procedures (SOPs). As part of this assignment, participants were able to display a coordinated effort in their food safety and food defense activities. The FDA Southeast Regional Emergency Response Coordinator functioned as the point of contact for all communication and coordination between the federal, state and local agencies during this assignment. This assignment assisted the state and local agencies by providing a better understanding of the proper procedures used when collecting traceback information, sampling and shipping food samples. Traceback information obtained from retail food service establishments was shared with FDA District investigators. Investigators then linked this information with distributors under FDA jurisdiction, allowing for a more detailed inspectional history of the food supply chain. Collection and shipping of food samples is not part of the normal routine for several local regulatory agencies.

FDA conducted training for the local and state inspectors on conducting risk based inspections, sampling and traceback. Appropriate sampling and shipping procedures are crucial for effective testing in the event of an intentional contamination, and this assignment provided the opportunity to learn and gain competency on these procedures.

The table below identifies the number of inspections and samples collected from each agency or department within the timeframe of the assignments:

Agency	Inspections	Samples
North Carolina Dept. of Agriculture & Consumer Service	4	29
Mecklenburg County (NC) Health Dept. and Surrounding Counties (Retail)	789	57
North Carolina Dept. of Health	6
South Carolina Dept. of Agriculture	10
SC Dept. of Health and Environmental Control (SCHDEC)	2	2
Atlanta District Office - FDA	29	25
Florida Dept. of Business and Professional Regulations (DBPR)	99	46
FL Dept. of Agriculture and Consumer Services (DCAS)	50	12
FLA District Office – (FDA)	39	45
USDA-FSIS Regulated Products – 584 lbs.		76

Goal 3:

Exercise the integration of food safety and food defense activities using existing infrastructureat the federal, state, local, and territorial levels.

Accomplishments:

The assignment tasked inspectors with jointly conducting both routine inspections and SEFSDA related activities at each food facility. By incorporating food defense related messages into routine regulatory activities participants were able to reduce resource expenditures, and increase the integration of food safety issues, related to food defense principles. Additionally, the use of the Incident Command Structure/Incident Management Team (ICS/IMT) and the Florida Rapid Response Team (RRT) were novel approaches to this process and helped to identify other agency components to be included in the planning process.

Some areas to be considered for process improvement include the integration of the Rapid Response Teams (if present in the state where future assignments are planned). In addition, we must identify the key agency components to be included in preliminary decisions at least 24 months prior to the announcement of the National Political activities. FDA will continue to evaluate process improvements for the use of standard forms during Special Event assignments. Although we recognize that each participating agency procedures may differ, for the purpose of Special Event assignments coordinated through the FDA, every effort will be made to ensure use of consistent forms and reporting across the board.

Goal 4:

Exercise the FERN laboratory analytical surge capacity and capability, and network communication procedures, including expedited data entry and reporting procedures.

Accomplishments:

FERN and CFSAN have worked together in previous Democratic and Republican National Convention and Inauguration Assignments and the willingness and eagerness of the two programs to undertake this joint endeavor was evident. The staffs of the two programs were in close contact and the working relationship was symbiotic and collaborative.

FDA FERN Cooperative Agreement state laboratories were willing, participatory, communicative, competent and efficient. This assignment was proof of the vast scientific abilities of these labs, and their eagerness to work towards a food safety system that is swifter, more efficient and more effective. The FDA Cooperative agreement laboratories have been working for several years to harmonize methodologies, standardize data reporting, and communicate effectively with the federal regulatory agencies, and their diligence was demonstrated throughout the course of this assignment. Overall, the planning and logistics, assignment, coordination and instructions were well run. To ensure the best possible data generation, in the future it would be helpful if the specific matrices and analytes can be determined towards the beginning of the planning phase.

Goal 5:

Conduct food safety and food defense training activities to improve communication and collaboration with Federal, State, Local, Tribal and territorial participating agencies.

Accomplishments:

As part of the SEFDA, food inspectors from FL, NC and SC participated in FDA led training opportunities. This training allowed the FDA an opportunity to compare notes on how the FDA conducts their food inspections as well as an opportunity for sharing of ideas for future collaboration.

Some areas to be considered for process improvement include the development of a standard food safety and defense training presentation; training to improve communications, and to increase proficiency with the inspection/sample collection process.

Goal 6:

Identify gaps in the system for responding to events requiring special security evaluation procedures to:

Address the gaps to ensure seamless integration of food safety and food defense activities across federal, state, local, tribal and territorial agencies;
Enhance preparedness; and
Identify best practices and/or procedures to be further shared with federal, state, local, tribal and territorial partners.

Accomplishments:

Based on feedback received from the assignment workgroup and all participating agencies, it was evident that advance planning and coordination with stakeholders proved to be instrumental in the success of the assignments. It was a worthwhile exercise and it allowed each participating component to share information and lessons learned that will enable the workgroup to focus on better process improvements moving forward.

Some areas to be considered for process improvements include leveraging opportunities to extend fiscal resources to our State and local counterparts. A significant gap in the process of implementing and executing assignments are fiscal resources (e.g. training, equipment, sample collection and shipment).

In addition, since the last executed Special Event Food Safety and Defense Assignment, FDA has established and appointed Regional Emergency Response Coordinators. The Southeast Region Emergency Response Coordinator was the primary contact to ensure coordination with the FDA Retail Food Specialists, FDA Districts, and state and local jurisdictions during the planning efforts for the National Special Security Events (NSSEs).

An additional component included as part of this planning effort was the Incident Management Team (IMT).

The Future of National Security Special Events and Assignments

Our planning efforts for the National Political activities take place every four years. Moving forward, the FDA, in partnership with our federal state, local, territorial and tribal stakeholders, will seek to ensure that the Unified Incident Command System is considered as an integral component in our planning efforts to eliminate any information gaps and to minimize redundancy. Additionally, FDA is in the process of developing a Special Event/National Special Security Event Standard Operating Procedure which will allow for consistency and transparency. Additionally, the SOP will include steps for evaluating resource needs of state, local, territorial or tribal stakeholders, to better plan for and appropriate federal support.

FDA and USDA-FSIS collaboration and coordination in the early planning and subsequent execution of these events ensures the appropriate response from each agency relative to coverage of laboratory and regulatory agencies participation. These pre-convention inspectional and laboratory efforts clearly demonstrated a level of readiness for threat agent analysis and data reporting to Agency officials and/or Incident Command (as deemed appropriate), capable of supporting food safety and defense efforts of NSSEs.

Future NSSE activities involving Emergency Support Functions ESF-8 (Public Health & Medical Services) and ESF-11(Agriculture & Natural Resources), calls for the presence of each food regulatory agencies (FDA/USDA-FSIS) and the incorporation of both personnel into the Unified Command System. All future planning efforts will incorporate these components and engage all relevant staff.

The next planning phase for the National Political activities is anticipated for FY2014.