While Canada has no legislation on “food defence,” a phrase coined by the U.S., many Canadian companies are affected by regulations south of the border and are making significant investments in physical security infrastructure.

Millions of tons of food are shipped around and through Canada every year, making it a potential target for tampering or terrorism. But Canada doesn’t have a plan for “food defence,” per se.

“Unless there’s a disease outbreak on a farm or we’re investigating an on-site feed-mill, which is subject to regulations, we don’t have any role in the day-to-day operation of a farm,” says Marc Richard, a spokesperson with the Canadian Food Inspection Agency (CFIA). Where it plays a role is in slaughter plants and with the importation of plants and animals.

“If you have someone who’s making candies, we’ll rarely visit them because candy is basically sugar, there’s not a lot of risk to it, and it’s heated to very high temperatures when you manufacture it and that would kill any pathogen or parasite,” he says. “So that’s the approach — we don’t have a role in certifying [physical security infrastructure].”

But the U.S. government is demanding it, and wants to see proof of a food security program on site that addresses any potential risks and hazards. Many Canadian companies, however, are a little naïve about food security, says Frank Schreurs, director of food safety and quality services with the Guelph Food Technology Centre (GFTC), which provides both consulting and auditing services. Addressing food security means formalizing a food security program that documents procedures and policies, and investing in infrastructure, which could include fencing, surveillance cameras and access control systems.

“Identifying your weaknesses and doing something about it is another thing,” says Schreurs. “Do I need 10-foot fencing and an armed security guard and all those things? That may or may not be needed — it depends on their location, the type of product they ship.”

 But for a company that ships bulk materials across the border that could easily be tampered with, a food security program is now a necessity.

“In some countries, companies like Kraft or Heinz don’t even put their name on the front of the building,” he says. “They don’t want people to know it’s a Kraft or Heinz plant because it’s like putting a big target on your forehead.”

But “food defence” costs money. This could include security guards, gates and fencing, for example, as well as surveillance cameras and access card systems for employees.

Companies should assess their requirements first, says Schreurs. If your facility is up against the street, for example, and you can’t put a fence there, what are your other options? Is it easy for someone to get on your roof and put something into your air system? Where are the best places to put surveillance cameras? And what is the cost versus the risk? There’s a lot to consider, from someone walking into a building with a machine gun to someone discretely slipping poison into a 10,000-pound batch of ground beef.

The industry’s biggest weakness is that there isn’t a formalized process of assessing what needs to be done. “There’s no allocation of responsibility, there’s no ownership,” says Schreurs. “How often are you archiving the film [from surveillance cameras] and how long do you keep it? If you’re rewriting over it every 24 hours, is that good?”

We need to look at the entire farm-to-table continuum to understand vulnerabilities and the potential for adverse actions that could impact the food supply, says John Brown, global operational risk manager with the H.J. Heinz Company. We also have to understand the goals of the individuals or groups who would want to cause those actions.

There are several characteristics of the food industry that make it a difficult target, he says. Agriculture is spread over vast areas, although there are concentrations in specific sectors. “Food processing subjects products to steps that inactivate or kill most biological contaminants,” he says. “Similarly, quantities of foods processed would require large amounts of chemical contaminants to achieve a particular effect.”

The maturity of the industry in dealing with food safety and the ability to quickly locate and recall products limit the amount of contaminated product that could get into consumers’ hands, he says. Product packaging has also matured relative to tamper-evidence features, limiting the potential for post-packaging contamination.

Leigh Booth, director of quality assurance with Honeyman’s Beef Purveyors — J.J. Derma Meats, sees it differently. “The food chain is so large and has so many access points, you can do a lot of damage,” he says, pointing to the recent E.coli outbreak in California spinach. In the case of a biological attack, it would be something much more contaminant than E.coli.

“That could be done relatively easily and that goes right across the food chain in North America,” he says. “Produce is probably one of the worst as a security threat.”

Unlike Brown, he believes Canada is a ticking time bomb. “The problem in Canada is the Canadian government isn’t looking at it as much as it should,” he says. “But it will happen here and they’ve really got to start looking at it. Why is it starting at our end?”

But all parties agree that Canadian companies have to be vigilant in identifying potential weaknesses and putting controls in place to strengthen them. “We like to view the issue of food defence within the realm of any intentional contamination,” says Heinz’s Brown. In reality, these threats most likely come from employees or people who have valid access to a processing facility, such as contract employees, suppliers and contractors.

Beyond employee awareness, there are physical and procedural measures that can be taken to increase protection of specific points in the farm-to-table continuum that have been identified as potential vulnerabilities, says Brown. Facilities should have the minimum possible number of access points, use turnstiles coupled with access control systems to ensure one person per access activation, and use access control to further limit access to more sensitive areas within processing facilities. These physical measures should be reinforced with human resource measures to include background checks and similar investigations on hiring.

Other measures that can and should be incorporated within the scope of processing plants, says Brown, include the use of seals on in-bound and out-bound trucks (or tamper-evident features at the case or pallet level), locks or seals on bulk delivery ports and storage tanks, tamper-evident sealing of partially-used ingredients, and good lighting systems to limit the ability for activity to go unnoticed.

“You have to identify not only what are the risks, but where are the risks,” says Honeyman’s Booth. “The outside is huge ”“ usually there’s no barrier, there’s no fencing, there’s nothing to stop somebody from getting at your building.”

The company uses surveillance cameras and electronic access at the front door; anyone who is not an employee must be accompanied inside the building, whether it’s a tour group or an auditor. The plant’s shipping and receiving facility has a secure door and drivers can’t get in unless they’re let in. Every employee has a security “fob” — and that’s the only way they can get into the building.

Some facilities are going so far as to build automation controls that monitor the temperature of food products, says Nick Migliore, president of Reilly Security Services. When a product is received, for example, a thermal temperature gun tests if that product is at a certain temperature. It either accepts or rejects it; if accepted, it can then be secured properly ”“ and this can be demonstrated through a trail of documentation.

There’s also increased screening and supervision of the human element and more controls on access, externally as well as internally ”“ from production to distribution. “We work for some firms that are more involved in the distribution and logistics side and they’ve invested heavily in technology to help them with their vehicles and type of refrigeration in the vehicles and the type of locks securing the product,” says Migliore.

But let’s be honest, says GFTC’s Schreurs, a lot of the push for this is coming out of the U.S. “For the most part they said that our audits were being too lenient, we weren’t being tough enough on the security side, and I would agree with that.”

This is serious stuff, he added, and if Canadian companies don’t take it seriously they’re going to get hammered. And the hammer, ultimately, is the consumer.