Food Safety Emergency Response
Planning
1
TECHNICAL TRAINING ON RISK ANALYSIS FOR SAARC COUNTRIES
FAO RAP, Bangkok, Thailand
Quality Council of India
Delhi, India, June 17-21, 2013
Shashi Sareen
Senior Food Safety & Nutrition Officer
FAO Regional Office for Asia and the Pacific
Bangkok, Thailand
Food Safety Emergency?
Codex Alimentarius definition :
A food safety emergency is a situation whether
accidental or intentional, that is identified, by a CA as
constituting a serious and as yet uncontrolled
foodborne risk to public health that requires urgent
action.
Codex Alimentarius, document CACGL-19
Food and Agriculture
Organization of
the United Nations
Emergency, Incident and Event?
Definitions:
Food Standards
Agency of the UK
(2009): an incident
Any event there are concerns about actual or
suspected threats to the safety and quality of food,
require intervention to protect consumers
US FDA (2005):
an emergency
An unforeseen combination of circumstances that
calls for immediate actions
AUS – National Food
incident Response
control (2007):
a food incident
Any situation where is a risk, potential risk or
perceived risk of illness or confirmed illness
associated with the consumption of food
Public Health
Emergency of
International
Concern (PHEIC)
(under IHR, 2005)
An event which includes the following four criteria:
1) Seriousness of public health impact
2) Unusual or unexpected nature of the event
3) Potential for the event to spread internationally
4) The risk that travel or trade restrictions may
result from the event
Emergency, Incident and Event?
Definitions:
Bangladesh
a situation arising from intentional or unintentional
contamination of food with biological, chemical, radio-nuclear
or physical hazards that is identified, by a CA as constituting
an uncontrolled food borne risk to public health, economy
and trade that requires urgent action
Thailand
“any event of food safety, whether accidental or intentional,
caused by chemical, biological & physical hazards of food ,
that is serious & unable to be controlled in normal food
control system, risk & impact to life, public health, trade,
economic and politic, both national & international level,
that requires urgent action & multi-agency coordination
approach from involved food safety agencies”
Japan
A situation where there is/may be significant foodborne
risk to public health that requires urgent action to ensure the
food safety .
Specifically, the incident causes large-scale and/or wide
spread damage.
Definition will differ along
national contexts
We recognize that:
• a situation ranges from minor incident to
major crisis
• a situation evolves over time
• severity varies (ie mortality, morbidity)
• international and trade implications vary
Plan ensures the coordinated response to a
potential or confirmed risk to public health
through food
“Food Safety Events” ?
• No standard in international approach - must make sense for each country
• Situation evolves over time
•Response is scalable to meet the changing needs of the event (resources,
coordination, decision making)
•Factors that effect response – numbers effected; severity of illness; volume
of food effected; contaminant known/ unknown; structures in a country; etc
Minor
incident
Major
crisis
Nature of Emergencies
• Emergencies of any description are
characterised by:
– Unpredictability
– Confusion
– Lack of Information
– Lack of Time
– Pressure to Act
– Loss of Control
Food and Agriculture
Organization of
the United Nations
Publications from FAO/WHO
on Food Safety Emergencies
• FAO/WHO framework for developing
national food safety emergency
response plans (FAO/WHO, 2010)
• FAO/WHO guide for application of risk
analysis principles to food safety
emergencies
• Food safety risk analysis: a guide for
national food safety authorities”
(FAO/WHO, 2006
• FAO/WHO Guide for developing &
improving National Food Recall
Systems
Why Panning & Preparedness
• Reduces the number of decisions during an
emergency
• Enables timely & coordinated response
• Reduces confusion (and disagreement)
• Agreed structures, roles & responsibilities
• Legislative authority & limitations understood
• Templates, decision trees, other tools increase
efficiency
• Minimizes adverse impact on health & disruptions
to trade
FAO/WHO Framework for Developing
FSER Plans
Steps for development of FSER Plan
• 3 preliminary steps
– Step 1: Obtain high-level support (& mandate)
– Step 2: Identify key partners (agencies with some
responsibility for food safety)
– Step 3: Establish a planning group
• 5 key elements :
– Step 4: Essential background information
– Step 5: Multi-Agency Coordination Group (MACG)
– Step 6: Incident identification & management
– Step 7: Post-incident review & evaluation
– Step 8: Communication
The Planning Group will:
• Lead the process of developing a Plan
• Determine scope of the plan
• Oversee preparation of the plan
• Ensure appropriate review & consultation with key
partners
• Collect legal texts, integrate with other national
response plans, etc
• Seek approval
• Evaluate the plan periodically & ensure that a
mechanism is in place to update the plan
Key Considerations
• General
Tiered response
Build on food control systems
Consideration to seriousness, geographical area
Persons familiar – simulation exercises
• Country Specific
Existing systems
Gaps & limitations
Food inspection, disease surveillance mechanisms, labs
Resources
Essential Background Information
• Introduction – purpose, objectives, reference to
regulations, terminology/ definitions (Emergency)
• Scope of the Plan - food inspection & foodborne
disease surveillance, testing capacities, treatments
available (region/country)
• Collection & review of all relevant regulations/
legislations – legal basis for implementation
• Any other national emergency plans – list these,
relationship with this protocol
• Roles & responsibilities of different agencies
MACG (Multi Agency Coordination Group)
• General structure & composition - agencies involved; r&r
of each partner; MACG for different areas (any existing
structure);
• Notifying agency, Central notification point, Food incident
contact officer, Lead agency, National/ Agency food
incident controller, Communications
controller
• TORs of MACG
• Communication strategy for
MACG members
• Operational & logistic
arrangements (contact list of
members, address, ph, e-mail)
Establishing a National MACG - Thailand
Representative Agency
Role and Responsibility
1. Food and Drug Administration
- Mandatory Food control, inspection and importing control
2. Department of Disease
Control
- National IHR focal point
- Food & water-borne disease, epidemiology data collection
& surveillance
3. Department of Health
- Food & water sanitation, monitor & educate food handler
4. Department of Medical
Sciences
- National reference laboratory, standardized accreditation
5. Food Safety Operation Center
- Nation INFOSAN emergency contact point
- Functional structure to coordinate food safety policy and
implementation
6. Ministry of Agriculture and
Cooperatives
- Monitor and investigate primary products
- Control exported food products
7. Ministry of Industry
- Industrial standardization and conformance
8. Ministry of Commerce
- Facilitation, promotion and direction for trading in domestic
and international
9. Ministry of Tourism
- Distribute information to tourists/guide, food safety warning
10.Ministry of Interior and
Provincial Offices
- Local authorities of food inspection
- Liaise with food sector, trade and academia in communities
Establishing a National MACG – Bangladesh
Draft
• National Food Safety Emergency Coordination Committee
(NFSECC)
• Structure: The NFSECC includes two Committees that are
separate but complementary operational entities and both
include representatives appointed by five core agencies
involved in food safety in Bangladesh namely:
MoHFW, MoF&L, MoA, MoFDM, MoI
• The two Committees are:
FSE Policy Group (SPG), top-level decision making entity of the
NFSECC; includes top senior administrative level officials
nominated by five core ministries/ departments.
FSE Technical Group (STG) is a separate but complementary entity
of the NFSECC; includes top senior technical officials nominated by
five core ministries or departments.
Incident identification
• Criteria for activating FSER; validation of criteria
• Identify possible information sources;
• Mechanisms for sharing information to be
documented;
• Identify monitoring mechanism in multiple
sectors – coordination mechanism; document
• Identify reference/ testing laboratories
• Identify documentation & evaluation mechanism
(documents and records – where kept);
Incident Management (1)
• Relies on establishing control, direction &
coordination to deal with incidents
• MACG is responsible for overall management –
state the same
• Identify who takes lead in food safety/ health related
investigations, define the process of coordination
• Describe the process of flow of information to
MACG and from MACG to others (daily information
reports – develop a format), identify population at
risk, duty roster may be made
Incident Management (2)
• Identify RM options (detention, seizure, recall,
closure of businesses, disposal of food products
removed from food chain) & reference their
procedures
• Procedure to decide when to scale down,
communication process
• Reference documents, GLs, tools, check lists,
templates
• A table of agencies with roles & responsibilities
• Process for maintaining central records
Post incident review & evaluation
• Outline the process to conduct review of how
incident was managed; strengths/ weaknesses
• Include reviewing process for
i. response activities,
ii. communication methodologies,
iii. regulatory procedures to prevent production/
distribution of implicated foods,
iv. capacity & reporting of lab & inspection service,
v. effectiveness of product withdrawal,
vi. identify gaps in lab testing/ regulatory procedures
• Review plan, if needed
• Sharing of corrective actions with policy makers
Communication
• Document strategies for communication & information
exchange (partners, media, public, international orgs)
• Document processes to address emergency alerts, intra
agency communication, public messaging
• List of all contact details
• Models & templates - press releases, incident notification
templates, recall/withdrawal notice templates
• Identify means of information dissemination (websites,
newspapers, English language, public notices, SMS
• What to communicate – the risk, what consumer should do if
consumed effected product
• Decide on spokesperson (from an agency) – single person
per event is preferable
Risk analysis in emergency
situations
FAO/WHO guide for application of
risk analysis principles to food safety
emergencies
Key Steps
•Preparedness
•Preliminary risk management (risk
evaluation)
•Risk assessment
•Risk management
•Risk communication
• Monitoring and Review
Risk Characterization
Preliminary RM Activities
Hazard Identification
Exposure
Assessmen
t
Hazard
Characterizati
on
Risk Management (RM)
Risk Assessment (RA)
Risk Communication
Food Safety Risk Analysis – Elements & Process
By Dr. Yukiko YAMADA
functional separation & interaction
24
• Implement RM decision
• Identify FS Problem
• Develop Risk Profile
• Establish RM goals
• Decide on need for RA
• Establishment of RA Policy
• Commissioning RA (if
needed)
• Consideration results of RA
• Rank risks (if necessary)
• Identify & select RM options
Preliminary Risk Management
Activities
• Preparedness for food safety emergencies
(criteria, decision trees, templates)
• Initial steps after identifying a food safety
event
• Activation of emergency response
• Formulating targeted questions for risk
assessors
Initial steps after identifying
a food safety event
• On receipt of report of food safety event
(widespread, difficult to control, serious health
consequence)
• Determine
– Likely magnitude of event
– If need to inform/ involve higher officials
– If emergency response plan needs to be activated
• Consider
– Initial source of information (media, food inspectors, lab
tests, partner alerts, consumer complaints)
– Verification/ validation of initial reports
Initial steps after identifying
a food safety event
• Initiate investigations (food safety & epidemiological)
to determine
– Whether food potentially contaminated with a food hazard
– Whether severe illness or death is involved
– Whether event localized or widespread
– Whether source of hazard has been identified
– The involvement of a particular food source
– Likely scope of distribution of product (e.g. local, regional,
national, international)
– If no action could it result in wide spread illness
Activating of Emergency Response
• FSE identified
• RA procedures followed –
more dynamic & intense
• RM actions before RA
completed
• FSER Plan activated
• MACG established (r&r
already defined)
• Risk communications
expert included
Activating of Emergency Response
• Risk managers should
– Set the objectives for the emergency response
– Identify data required
– Evaluate any other relevant factors
– Consider need to include other relevant agencies/
ministries in MACG
– Determine stakeholders to be notified (e.g. senior officers,
other agencies, affected private-sector establishments)
– Consider inclusion of decision tree to model initial steps &
resulting outcomes
Formulating Targeted Questions for Risk
Assessors
• Interaction between RA & RM rapid & frequent,
initiated early, all channels used
• For formulating Q on RA, need to
– Formally engage relevant partners to gather additional
information
– Begin to collect & focus information for RA
components eg hazard characterization
– For new/ unusual hazards emphasis on collecting field
data
– Standardize terminologies understood by industry, RAs
& RMs to reduce miscommunication
– Targeted questions to RA in standard format
Standard Templates Examples
Risk Assessment
Risk assessment
• Screen incoming/ other available data &
information rapidly
• Decide on appropriate methodology & scope
of RA
• Does a RA need to be conducted?
– Are food safety standards already in place?
– Is there sufficient data to conduct an RA?
– Could existing RAs be used to feed into the
current RA?
• Time constraints may not support full RA but
needs to be robust
Example of a Decision Tree for Initiating Risk Assessments
Risk assessment
• In an emergency situation, communication between
RM & RA more frequent
• Peer review of RA especially where data is limited
• Use of existing tools can help –national or
international consumption data sets, expert
networks, international reference values, advice
from international counterparts
• Specific Considerations - Absence of specific
experience i n country may contact CA/ experts
from other countries; use of pre-existing scientific
information or data specific to incident; information
from company/ industry experts; expert opinions
Risk assessment
• Hazard identification
– Where data is insufficient/ hazard not fully
identified/ insufficient time to generate new data
• Surrogate data may be useful (eg unknown serotype
non 0157 E. coli , 0157:H7 data could be used)
– Testing methodology
• Validated rapid test methods used to identify hazards if
possible
• Where no validated method available in-house, review
literature/ seek international advice/ develop a method.
Risk assessment
• Hazard Characterisation
– Existing data from toxicity studies, guideline
values, dose-response models, etc can be used
to expedite RA
– Where dose-response information is not
available, a conservative approach should be
taken and whole population should be
considered sensitive
Risk assessment
• Exposure assessment
– Existing national consumption data preferred
– Alternatives include
• Household food expenditure surveys
• Models
• Other national datasets
• International data (eg WHO GEMS)
– *It is important to identify & document
assumptions used in dietary exposure
assessment modelling
– Refined as new information available
Risk assessment
Risk characterisation
• During an emergency, initial information is
often qualitative or semi-quantitative
due to time and information constraints
• Decision trees can be very helpful in
quantifying and communicating levels of
risk
Risk assessment
• Expedite the RA
• Important to document and explain
limitations and uncertainties (data gaps)
• Need to revise risk assessment as new
data becomes available
• MACG to consider revised risk
assessment – and RM or RC implications
Risk Management
Risk management
• Although public health and safety is paramount,
social and economic impacts also to be considered
• Preparation will help with RM decisions in an
emergency – eg pre-agreed RM options, decision
triggers, documents, templates/decision trees etc
• Documenting RM decisions critical
• Risk categorization system useful – enables
rapid, consistent RM decisions
Risk management
• Factors to consider in selecting RM options
– Capacity issues, eg to implement RM or laboratory
capacity/ ability to obtain assistance from elsewhere
– Uncertainty about the nature of the risks
– Public expectations & perceptions
– Legal considerations
– Industry considerations (Industry support/ cooperation
– International considerations, eg actions taken by
other countries, trade implications
– Others
Risk management
• Implementation of RM decisions
– May need to involve agencies/ministries not
usually involved in food enforcement
– Legal authority for dealing with industry eg
recall actions else advice to public
– Consultation and coordination with industry
– Widely used ingredient - complex supply
chains and traceability
• Monitoring, evaluation of options/ results
Risk Communication
Risk communication
• May be very different from usual approach
– Demands for frequent updates from different
stakeholders
– Urgent demand for up-to-date reports
– Communicating complexity & uncertainty
– Messages developed in very short
timeframes
– Messages change as situation unfolds
– Public, media or political scrutiny & pressure
for action
Risk communication
• Communicating with industry
– faster response & possible an earlier return to
market of implicated products
– Contact points for use in emergency established
- industry/ government
– 2-way– industry a good source of information &
may assist in implementing RM
– Industry to be aware of investigation approaches,
RM options & legal basis, FSER GLs
– Consistent/ complementary messages by
government & industry
Risk communication
• Communicating with the general public
– Early communication critical even in uncertainty
– Two-way
– Public trust can be easily damaged
– Be as accurate as possible, timely, consistent,
demonstrate confidence, well targeted & address
public concerns
– Identified agency to take lead
– May need to counter inaccurate/ misleading
statements by others
Risk communication
• Communications to the public to cover
– Details of the food safety emergency
– The foods involved
– The risks & if known
– Levels of exposure that are harmful
– What public should do if affected products
consumed/ obtained
– How to access additional information
• Different ways to communicate with public
– traditional/social media, signs in shops,
advertising, health/ field officers
Risk communication
• Communicating with international/ regional
bodies
International counterparts
Importing countries
International bodies, eg INFOSAN
Conclusion
• Countries to define emergency in terms of own,
systems, resources &capacity
• Emergency response can differ in countries
• Application of RA to follow same principles as
in normal situations
• Differences are factors effecting decision
making – time pressure, increased uncertainty
• increased need for multi-agency coordination,
strong demand for timely communication
• Preparedness is the key – FSER Plan & team,
MACG, data & information, tools
THANK YOU
Any Questions?
