With Congress debating mandatory food-protection legislation, trade customers demanding safety assurances from processors and the FDA issuing security guidelines for food plants, processors are under the gun to demonstrate control over what comes in and goes out of their plants. “Since 9/11, we should have a new awareness of how vulnerable our facilities may be,” cautioned David Armstrong, assistant director of research in FDA’s Chicago office. “The intention is to raise the bar.”

To avoid raising it too high, food companies should consider performing an operational risk management (ORM) assessment. Risk management is a concept that originated in the banking industry and has been adapted for food by a U.S. military officer. ORM’s six-steps are:

• Identify hazards
• Assess severity of risks
• Assess their probability
• Make risk control decisions, based on risk rankings
• Implement risk controls
• Monitor effectiveness and review system approach.

Some experts liken ORM to HACCP plans: If there’s no way to control a risk, there’s no point devising a defense plan. “If you can’t implement it, monitor it and enforce it, it doesn’t do you any good” to devise a defense, points out Judy Fischer, senior packaging engineer at Sargento Foods, Plymouth, Wis.

Anthrax paranoia prompted the removal of Sargento’s cheese products from store shelves last fall, recalls Fischer. Cornstarch is used extensively by makers of flexible films to reduce clinging on rolls, and people in one supermarket feared the white powder was anthrax. Sargento subsequently directed film suppliers to lightly dust their rolls, and it is trying to eliminate cornstarch entirely in some applications.

“In the food industry, we’ve been very fortunate in that we had many safety measures in place long before 9/11 happened,” Fischer says. At Sargento, suppliers of the cheese that the company packages must follow specifications on “everything from how it should be wrapped on a pallet to how it should be delivered,” and those specs have not changed since September. Nonetheless, the company is more closely assessing the security and traceability protocols at those suppliers’ plants.

The security-conscious environment prompted 3M Co. to accelerate the rollout of TED, a tamper evident detection tape that is placed on master packs. And makers of induction seals are seeing renewed interest in their systems, initially devised to prevent leaks but now being added for their tamper evidence.

“Tamper evidence is an expected and a required feature,” says Fischer. “Everybody’s intent on being unique with their packaging to differentiate from the competition.” But secure packaging and raw-material controls that reduce risk are now must-have features.