I opened my last post in this series with the assertion
We’re in the middle of the first live, largescale test of the security of our food supply and, honestly, we’re not doing very well.
In this installment I plan to flesh that out a little and evaluate how we’ve done so far.
Wargaming an attack on the food supply
Since the attacks on September 11, 2001, an enormous amount of time, energy, and money has been devoted to studying various potential security threats to the United States. This concern was re-doubled after the less-than-stellar peformance of government at all levels in response to the Hurricanes Katrina and Rita in 2005.
Although we have an entire enormous expensive facility within DHS ostensibly devoted to the subject of biodefense including agro-terrorism, the National Biodefense Analysis and Countermeasures Center, to my eyes much of what’s available in open source form on this subject seems very rudimentary.
Much of it deals with something along the lines of an industrial sabotage model—risk assessment is done from the point of view of companies trying to prevent damage to their facilities. Useful as that may be I don’t think that it really corresponds to what we might actually experience, which presumably would conform more to a product tampering model.
Here’s how I think that a real attack against our food supply might be likely to unfold.
- a toxin or pathogen would be introduced into a basic food item either via a producer, distributor, or manufacturer
- the item would be packaged and distributed throughout the country
- the retail products would be purchased by consumers
- individual cases of injury or death would begin to appear
- complaints would be made to retailers and/or brand name vendors
- at some point relevant government agencies would become engaged
- there would be a scramble for causes and sources
- conflicts between agencies would emerge
- at some point the toxin or pathogen would be identified, its source might be identified, and a solution put into place
Some number of lives would have been lost, resources consumed in pursuing the problem, and the ultimate solution would bring that process under control but the objective of the attack would already have been accomplished: there would be a diminution of confidence in government, society, and other people.
A modern economy and modern society operates on trust.
Contaminated pet food as a live simulation
Does any of this sound familiar? Consider the timeline I established in my last post in this series. It conforms quite closely to such a product-tampering model.
At some point in the production process an as-yet unknown contaminant was introduced into the ingredients used to make pet food; the first warnings that something was wrong were observed in the form of visits to veterinarians and complaints of pet sickness and death. After a period of dithering the producer began tests of its own; the tests revealed almost immediately that something was seriously wrong. The producer notified the FDA, the FDA began testing of its own, the producer issued a recall which has been expanding ever since.
Now I don’t believe that what actually happened in the instance of the contaminated pet foods affair that’s continuing to unfold was a deliberate attack. I think it’s more likely that it was an error. But it provided an opportunity to treat it as a lve drill or wargaming activity that we are, unfortunately, squandering.
Performance to date
In a word the performance of government at all levels in this has been lousy. The wholesaler accepted wheat gluten that was seriously contaminated; the pet food producer accepted wheat gluten that was seriously contaminated; pet food companies distributed contaminated pet food in which the contamination was obvious (some reports say visible to the naked eye). Clearly, none of these companies believe that they have an affirmative responsibility to ensure the purity of their products. Indeed, I read one pet food executive quoted as wondering how they should have known to test for melamine.
The answer to this, as was pointed out in a comment to one of my posts on this subject, is that melamine, which, whether it’s the source of the deaths or not is indubitably a contaminant in the wheat gluten, is 67% nitrogen by weight. Commercial wheat gluten is something like 15% nitrogen by weight. A test for nitrogen would have revealed the problem; heck weighing the stuff probably would have revealed the problem.
The performance of government has been even worse. It’s been revealed that the FDA, too, clearly does not believe that it has an affirmative responsilbility to ensure the purity of foods. This is incredible. The Pure Food and Drug Act of 1906 created the Food and Drug Administration for exactly that purpose. As Illinois Senator Dick Durbin observed, its performance has been like that of a fire truck leaving the station after the building had burned down. If they don’t have the resources to do what they’re chartered to do, it’s not enough to do what they can with the resources they’ve got? Where is the whistle-blowing, where are the resignations?
Where is the Department of Homeland Security in this? They’ve been invisible and that is itself a problem. A real attack of this sort would have been an attack on public confidence—deaths would have been nearly incidental to the attack—and such an attack can’t be countered in secret. The assurances of the FDA that none of the contaminated wheat gluten made it into the food suppy ring hollow. If they don’t really know the sources or structure of the Chinese supplier of the wheat gluten, how the wheat gluten became contaminated, or even whether the contaminated wheat gluten is actually the cause of the pet deaths, I see no way they could know that.
I won’t let the Congress off the hook, either. This is clearly a problem of sufficient scale and scope that something should already have been done. In my view we need more engineers and businessmen in Congress and fewer lawyers and career bureaucrats. We need people who are solution-oriented rather than looking for an adversary to confront (and blame) or something to document or create a new department to oversee.
Tools for the future
The Menu Foods pet food recall, the largest recall of pet food in history, has revealed a number of defects in our inspection and regulatory regime. Somebody, somewhere needs to be responsible for ensuring the purity of food, even pet food.
Equally importantly somebody, somewhere needs to be responsible for re-building confidence. That’s analogous to re-building a bridge after a military attack. It’s not enough to document the loss of the bridge and assure us no bridges will be destroyed in the future.
However, the incident has revealed important information resources as well. These include veterinarians’ reports, chatter on veterinarians’ bulletin boards, activity on 800 number customer complaint lines, Google searches, blog traffic on relevant subjects (I’ve received thousands of visitors on this subject over the last several weeks), and comments left on blogs.
Whether we’ll be able to harness and mine these information sources remains to be seen.
There’s an excellent report on bio-terrorism written by Dr. Peter Chalk here.
