GUIDELINES FOR THE DISPOSAL OF 

INTENTIONALLY ADULTERATED FOOD PRODUCTS 

AND THE DECONTAMINATION OF FOOD 

PROCESSING FACILITIES

APRIL 14, 2006
Guidelines for the Disposal of Intentionally Adulterated Food Products and the Decontamination of Food Processing Facilities

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TABLE OF CONTENTS

Page

List of Acronyms........................................................................................................................................iii

1. INTRODUCTION...............................................................................................................................1

1.1 Overview of Existing Federal Authorities.............................................................................2

1.1.1 The Food Safety and Inspection Service .................................................................. 2

1.1.2 The Food and Drug Administration ......................................................................... 2

1.1.3 The Environmental Protection Agency .................................................................... 3

1.2 Coordination among State, Local, and Federal Agencies......................................................3

1.3 Relationship of these Guidelines to U.S. Government Interagency Concept of 

Operations for Decontamination and Disposal under Homeland Security Presidential 

Directive – 9 for Food and Agriculture .................................................................................4

2. METHODOLOGY AND SCENARIO DEVELOPMENT..............................................................6

2.1 The Food Disposal and Decontamination Interagency Workgroup ......................................6

2.2 Literature Searches................................................................................................................6

2.3 Federal Staff Interviews ........................................................................................................6

2.4 Scenario Development...........................................................................................................6

3. CURRENT PROCEDURES ..............................................................................................................8

3.1 Procedures for Product Disposal ...........................................................................................8

3.1.1 FSIS Procedures....................................................................................................... 8

3.1.2 FDA Procedures....................................................................................................... 9

3.2 Procedures for Decontamination ...........................................................................................9

3.2.1 FSIS Procedures....................................................................................................... 9

3.2.2 FDA Procedures....................................................................................................... 9

4. DISPOSAL AND DECONTAMINATION GUIDELINES...........................................................10

4.1 Characteristics of an Intentional Adulteration Incident.......................................................10

4.2 Procedures for Incidents Involving Intentional Adulteration ..............................................11

4.2.1 Discovery and Response Phase .............................................................................. 11

4.2.2 Disposal Phase........................................................................................................ 13

4.2.2 Decontamination Phase .......................................................................................... 15

4.2.3 Event Clearance and Termination .......................................................................... 17

4.3 Categorization of Threat Agents .........................................................................................17

5. RESEARCH AND RESPONSE NEEDS.........................................................................................19

APPENDIX A – POTENTIAL DISPOSAL OPTIONS AND TECHNIQUES FOR 

THREAT AGENTS .................................................................................................................... 21

A.1 Potential Disposal Techniques .........................................................................................................22

A.1.1 Rendering ............................................................................................................................22

A.1.1.1 Edible Rendering................................................................................................... 22

A.1.1.2 Inedible Rendering ................................................................................................ 22

A.1.1.2.1 Batch Rendering Process ................................................................ 23
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A.1.1.2.2 Continuous Rendering Process....................................................... 23

A.2 Non-Hazardous Waste Disposal.......................................................................................................23

A.2.1 Land Disposal Techniques ..................................................................................................24

A.2.2 Combustion Techniques......................................................................................................24

A.2.2.1 Large and Small Municipal Waste Incinerators..................................................... 24

A.2.2.2 Commercial and/or Industrial Incinerators............................................................. 24

A.3 Hazardous Waste Disposal...............................................................................................................25

A.3.1 Land Disposal Techniques ..................................................................................................25

A.3.2 Combustion Techniques......................................................................................................26

A.4 Special Handling Techniques - Medical Waste Incineration ........................................................26

A.5 Radioactive Waste Disposal .............................................................................................................27

A.6 References..........................................................................................................................................29

APPENDIX B – POTENTIAL DECONTAMINATION OPTIONS FOR INACTIVATING 

THREAT AGENTS .................................................................................................................... 31

APPENDIX C – EXAMPLE SCENARIOS AND ACTIONS FOR DISPOSAL AND 

DECONTAMINATION ............................................................................................................. 35

APPENDIX D – CONTACT INFORMATION ....................................................................... 43

APPENDIX E – WORKING GROUP MEMBERS ................................................................ 71
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LIST OF ACRONYMS

AA Assistant Administrator 

ARS Agricultural Research Service

CCP Critical Control Point

CDC Centers for Disease Control and Prevention

CE Crisis Exemption

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

CONOPS Concept of Operations

DHS Department of Homeland Security 

DM District Manager

DOD Department of Defense

DOT Department of Transportation 

EIAO Enforcement Investigation and Analysis Officers

EMC Emergency Management Committee 

EPA Environmental Protection Agency

EPIA Egg Products Inspection Act

FBI Federal Bureau of Investigation

FDA Food and Drug Administration

FFDCA Federal Food, Drug, and Cosmetics Act

FLS Front Line Supervisor

FMIA Federal Meat Inspection Act

FSIS Food Safety and Inspection Service

HACCP Hazard Analysis and Critical Control Point

HMTA Hazardous Materials Transportation Act

HMTUSA Hazardous Materials Transportation Uniform Safety Act

HSPD-9 Homeland Security Presidential Directive 9

ICS Incident Command System

IPP Inspection Program Personnel

MSWLF Municipal Solid Waste Landfill

NORTHCOM Northern Command-Department of Defense

NRC Nuclear Regulatory Commission

NRI Non-Routine Incident Report

OFO Office of Field Operations

OFDER Office of Food Defense and Emergency Response

OIG Office of Inspector General

OPEER Office of Program Evaluation, Enforcement and Review

OSWER Office of Solid Waste and Emergency Response

PPIA Poultry Products Inspection Act

RCRA Resource Conservation and Recovery Act

SEDO Senior Executive Duty Officer
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SPHV Supervisory Public Health Veterinarian 

SSOP Sanitation Standard Operating Procedure

TC Toxicity Characteristic 

TSA Transportation Security Administration 

USDA United States Department of Agriculture

UV Ultraviolet
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1. INTRODUCTION

This document is intended to serve as a resource guide for the U.S. Department of Agriculture’s 

(USDA) Food Safety and Inspection Service (FSIS or the Agency) and the Department of Health 

and Human Services’ Food and Drug Administration (FDA) field personnel located in District 

Offices and at food processing facilities. It addresses the need to plan for response actions in the 

event that the food supply is intentionally adulterated somewhere in the supply chain. The 

document describes the current procedures used by each agency to respond to unintentional 

contamination events and how those procedures can provide a framework for planning response 

actions in the case of an intentional contamination emergency.

There are a large number of potential variables associated with any given contamination incident,

including the nature of the commodity, the different types of threat agents that might be used as 

adulterants and their concentration. Because of this variation, effective disposal and 

decontamination response actions must be collaboratively developed by government and industry 

stakeholders on a case-by-case basis. This document provides general guidelines to help FSIS 

and FDA field personnel provide advice and, when appropriate, make decisions regarding 

disposal and decontamination actions in the event of an intentional contamination incident. This 

document does not address response actions for incidents involving live animals. 

This report is organized into five sections and four appendices, as follows:

Section 1 presents an overview of Federal authorities and discusses their relationship to 

other coordination efforts at the Federal and state levels.

Section 2 presents the methods used to develop these guidelines.

Section 3 presents the current procedures for disposal and decontamination following an 

unintentional contamination incident.

Section 4 contains the guidelines for disposal and decontamination response actions for an 

intentional contamination incident. 

Section 5 discusses research and response needs.

Appendix A categorizes potential threat agents and possible disposal options, along with 

details of those options.

Appendix B provides a table containing options and details for decontamination of 

contaminated facilities and equipment.

Appendix C contains examples of responses for three different intentional adulteration 

scenarios.

Appendix D provides contact numbers for local, state, and other Federal offices that might 

need to be notified in the event of an incident.
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1.1 Overview of Existing Federal Authorities

During an incident in which food products have been intentionally contaminated three Federal 

agencies - FSIS, FDA, and the Environmental Protection Agency (EPA) - have authority to 

provide assistance and guidance.

1.1.1 The Food Safety and Inspection Service 

FSIS is the public health agency within USDA responsible for ensuring that the nation's 

commercial supply of meat, poultry, and egg products is safe, wholesome, and correctly labeled 

and packaged.

U.S. Code 21 gives the Secretary of Agriculture (the Secretary) broad authority to inspect, 

detain, seize, and condemn meat, poultry, and egg products. That authority is carried out by 

FSIS. The Agency has the authority to:

Inspect, detain, seize, and condemn meat products that are deemed adulterated or 

unhealthy for human consumption [Title 21, Chapter 12, the Federal Meat Inspection Act 

(FMIA), Sections 671, 672, and 673].

Inspect, detain, seize, and condemn poultry products that are deemed unwholesome, 

adulterated or unbranded [Title 21, Chapter 10, the Poultry Products Inspection Act 

(PPIA), Section 467]. 

Inspect, detain, seize, and condemn egg products that are deemed unwholesome, or 

adulterated [Title 21, Chapter 15, the Egg Products Inspection Act (EPIA), Sections 1047, 

1048, 1049].

1.1.2 The Food and Drug Administration 

FDA is responsible for protecting public health by assuring the safety, efficacy, and security of 

human and veterinary drugs, biological products, medical devices, the nation’s food supply, 

cosmetics, and products that emit radiation. The FDA is also responsible for advancing public 

health by helping to speed innovations that make medicines and foods more effective, safer, and 

more affordable, and helping the public get the accurate, science-based information they need to 

use medicines and foods to improve their health.

The Federal Food, Drug, and Cosmetic Act (FFDCA) provides the FDA with broad regulatory 

authority over food that is introduced or delivered into interstate commerce. Under the FFDCA, 

manufacturers are responsible for producing safe, wholesome and truthfully labeled food 

products. It is a violation of the law to introduce into interstate commerce adulterated or 

misbranded products that violate the various provisions of the FFDCA. 

The Public Health Security and Bioterrorism Preparedness and Response Act of 2002 

(PL107-188) was signed into law on June 12, 2002, by President Bush. Title III of PL107-188 

deals primarily with the protection of the safety and security of the food and drug supply. 

Subtitle A Section 303 allows for the detention by an officer or qualified FDA employee of food 
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if there is credible evidence or information that the food presents a threat of serious adverse 

health consequences or death to humans or animals.

1.1.3 The Environmental Protection Agency

EPA works to protect human health and the environment as well as to develop and enforce 

regulations that implement environmental laws enacted by Congress. EPA is responsible for 

researching and setting national standards for a variety of environmental programs, and delegates 

to states and tribes the responsibility for issuing permits and for monitoring and enforcing 

compliance. Where national standards are not met, EPA can issue sanctions and take other steps 

to assist the states and tribes in reaching the desired levels of environmental quality. Where 

authorized, EPA can delegate programs to federally recognized tribes. In addition, EPA works 

with tribes to build capacity and environmental programs. 

The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)

authorizes the President to respond to releases, or substantial threats of releases, of substances 

hazardous to the environment, and to respond to releases or substantial threats of releases of 

pollutants or contaminants that may present an imminent and substantial danger to the public 

health or welfare. CERCLA also authorizes investigations and studies. The President delegated 

his CERCLA authorities to the EPA Administrator in Executive Order 12580.

The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) provides Federal control of 

pesticide distribution, sale, and use. All pesticides must be registered (licensed) by EPA before 

they can be sold or distributed in the United States. Registration assures that pesticides will be 

properly labeled and if used in accordance with label safety precautions and use directions, will 

not cause unreasonable adverse effects to humans or the environment. 

The Resource Conservation and Recovery Act (RCRA) authorizes the EPA Administrator to 

regulate management of hazardous waste and disposal of non-hazardous solid waste. This 

authority has been delegated to the states, which must meet minimum Federal regulatory 

requirements, but implement their own programs at the state and local level. 

EPA has broad authority under Subtitle C of RCRA to regulate treatment, storage and disposal of 

hazardous waste as ―necessary to protect human health and the environment.‖ Subtitle D 

prohibits open dumps and requires EPA to establish criteria for sanitary landfills. An example of 

how this authority might be used would be to allow contaminated product to be disposed of only 

in municipal landfills that meet specific criteria, that is, municipal landfills that are in compliance 

with the Federal Criteria for municipal landfills contained in 40 CFR Part 258. 

1.2 Coordination among State, Local, and Federal Agencies

FSIS and FDA are employing the Incident Command System (ICS) management principles to 

coordinate the response to intentional contamination incidents involving the processing and

distribution of food products. FSIS also has established the Emergency Management Committee 

(EMC), which directs FSIS’ response to major food incidents and the Agency’s involvement in 

interagency responses to emergencies.
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FSIS recently entered into an agreement with FDA, the Department of Homeland Security 

(DHS), and the National Association of State Departments of Agriculture to facilitate 

development of coordinated emergency response procedures between frontline field locations 

and their associated state and local emergency response organizations. These partners are all 

committed to employing the principles of the ICS. In the event of an intentional contamination

incident, a response team would work with an incident commander, most likely someone from 

the state or local level, or a unified command. The response team would identify subject matter 

experts to assist the incident manager as well as provide a management process that overlaps the 

emergency response process.

1.3 Relationship of these Guidelines to Federal Food and Agriculture Decontamination 

and Disposal Roles and Responsibilities under Homeland Security Presidential 

Directive – 9 for Food and Agriculture

Homeland Security Presidential Directive – 9 for Food and Agriculture (HSPD-9) was signed by 

the President on January 30, 2004. The Directive established a national policy to defend the 

agriculture and food system against terrorist attacks, major disasters, and other emergencies. 

HSPD-9 directed four Federal agencies; FDA, USDA, EPA and DHS to develop coordinated 

response plans that include decontamination and disposal operations for handling adulterated 

food products or contaminated/infected plants and animals. 

The White House Homeland Security Council asked the EPA to coordinate the development of a 

document that lays out roles and responsibilities for decontamination and disposal response 

actions under HSPD-9. The document, Federal Food and Agriculture Decontamination and 

Disposal Roles and Responsibilities, formerly referred to as the ―CONOPS‖, focuses on 

chemical and biological incidents where the primary target is the U.S. food and agriculture 

infrastructure. The roles and responsibilities are consistent with the National Response Plan and 

are presented for the four primary Federal agencies tasked with response coordination under 

HSPD-9. The required adjustments in response activities to changes in incident magnitude and 

involvement of different impacted sectors are also detailed. For example, many response actions 

are handled solely at the local level using available local and private sector resources. However, 

as incidents require larger or more complex response actions, local resources may be exhausted 

and state or Federal resources may be needed to manage the incident. The Federal Roles and 

Responsibilities document presents a framework for the coordination of multiple Federal 

resources in a unified command structure to conduct decontamination and disposal activities. 

Whether the incident involves contamination of animals, crops or food, there are key process 

steps involved in decontamination and disposal operations. The document clarifies these steps, 

identifies who is in charge of the ICS and primary and supporting Federal agencies, and outlines 

the means by which states or Federal agencies can request technical and resource support.
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Both this guidance document and the Federal Roles and Responsibilities coordinated by the EPA 

(in conjunction with DHS, USDA/FSIS, USDA/APHIS, and HHS/FDA) address the issue of 

responses to adulteration of the food supply. However, the documents differ in the two 

following respects:

1. Goal – The objective of the Federal Roles and Responsibilities document is to describe the 

roles, responsibilities, and coordination of Federal and state decontamination and 

disposal resources in response to incidents where the primary target is the 

U.S. agricultural and/or food infrastructure. By contrast, the objective of these 

guidelines is to provide guidance to field personnel charged with implementing 

response actions.

2. Content – The Federal Roles and Responsibilities document addresses disposal and 

decontamination issues for food products, live animals, and crop materials potentially 

contaminated with biological and chemical agents. In contrast, these guidelines deal 

solely with food products that may be adulterated with biological, chemical, or 

radiological threat agents. 
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2. METHODOLOGY AND SCENARIO DEVELOPMENT

This section describes the methods used to collect information for the development of the 

guidelines in this document.

2.1 The Food Disposal and Decontamination Interagency Workgroup

An interagency team, the Food Disposal and Decontamination Interagency Workgroup, was 

established to facilitate coordinated discussions about the technical recommendations provided in 

these guidelines. The team consisted of members from FSIS, FDA, and EPA. The workgroup 

provided input at several meetings that were held from August through November 2004. 

2.2 Literature Searches

The open literature was examined for information regarding regulatory authorities and 

responsibilities, as well as disposal and decontamination techniques for food products. The 

literature was also reviewed for case study information involving unintentional adulteration of 

food products that could provide useful data for the development of these guidelines.

2.3 Federal Staff Interviews

Staff in FSIS Program Offices (Office of Food Defense and Emergency Response, Office of 

Field Operations, and Office of Program Evaluation, Enforcement and Review) and FDA (Center 

for Food Safety and Applied Nutrition, and Office of Regulatory Affairs) were interviewed to 

obtain information about the procedures used for responding to incidents involving the 

unintentional adulteration of food products. Information was also requested about case studies 

and points of contact at the state government level. 

2.4 Scenario Development

These guidelines focus on responses to the intentional adulteration of food products during 

processing or distribution. In order to facilitate discussion of such responses, several scenarios 

were constructed to serve as a framework for guideline development. These scenarios, 

developed through discussions with staff from FSIS and FDA, attempt to address potential 

adulteration incidents at several points in the supply chain. 

Scenario Number 1 addresses the intentional adulteration of products at a large food processing 

facility; for example, a major ground beef processing facility that produces a large volume of 

product that is distributed over a region of the country.

Scenario Number 2 addresses the intentional adulteration of food products during transportation. 

In this case, a tanker truck shipment of fluid milk is contaminated.
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Scenario Number 3 addresses the intentional adulteration of food products during storage in a 

warehouse/distribution facility. For example, this could involve the local/regional storage of 

frozen poultry products with a relatively smaller volume of product than the processing facility, 

and distribution over a more localized area.
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3. CURRENT PROCEDURES

This section provides information about the current FSIS and FDA procedures for disposal and 

decontamination response actions for incidents involving the unintentional contamination of food 

products. 

3.1 Procedures for Product Disposal

3.1.1 FSIS Procedures

In the event of unintentional contamination of meat, poultry, or egg products, FSIS has the 

authority under the Federal Meat Inspection Act, the Poultry Products Inspection Act, and the 

Egg Products Inspection Act to retain products in processing facilities and to detain products 

already distributed in commerce that might be adulterated for up to 20 days and petition a U.S. 

District court to seize products. Product seizure is initiated by the Department of Justice acting 

on FSIS’ behalf, following a request by FSIS’ Office of General Counsel, by filing a Libel of 

Information against the product in the appropriate district court, and the procedures to be 

followed for detention and seizure are outlined in FSIS Directive 8410.1 Revision 1. 

If, for example, contamination were found at a processing facility, the FSIS District Manager and 

Inspector-in-Charge would first alert the owners of the establishment of the need to retain the 

product in order to protect public health. The District Manager would prepare a non-routine 

incident report for the incident and send the report to the Assistant Administrator for the Office 

of Field Operations with a copy to the Office of Food Defense and Emergency Response. The 

District Manager would also notify the EPA Regional Office. FSIS would then work with the 

owners of the establishment and the representatives of the state departments of health, 

agriculture, and environmental quality to determine the appropriate disposal options for the 

contaminated product. FSIS requires that the owners of the establishment conduct a separate 

hazard analysis for the incident (i.e., as an unforeseen hazard), and develop a plan for the 

proposed disposition action and sanitation standard operating procedures (SSOPs). These 

requirements are specified in 9 CFR Part 314, 9 CFR Part 417.3, 9 CFR Part 416.5. FSIS staff 

actions are described in several agency directives (e.g., Directives 5000.1 and 8410.1). The 

establishment owner’s plans would be presented to the FSIS District Manager, who would 

determine whether the plans are sufficient to ensure that contaminated food does not enter the 

food supply and if the proposed actions can be implemented. FSIS Inspectors would witness the 

execution of the planned actions.

As outlined in FSIS Directive 5730.1 and a 1998 Memorandum of Understanding between FSIS 

and FDA regarding the sharing of information in dual jurisdictional establishments, when 

warranted (e.g., for plants processing products subject to regulation by both FSIS and FDA), 

FSIS would also contact FDA District Office staff as well as EPA Regional Office staff to 

coordinate responses on food product disposal actions. 
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3.1.2 FDA Procedures

For FDA-regulated food products, unless the product is seized by a U.S. Marshall, the owner of 

the establishment is responsible for the development of product disposal plans. The FDA District 

Office reviews the plans and contacts the relevant state agency and the EPA Regional Office, if 

needed, about the acceptability of the plans. FDA can offer advice and observe implementation 

of the proposed actions. FDA Field Investigators follow the guidance specified in Section 947 of 

the Office of Regulatory Affairs Investigations Operations Manual with regard to product 

disposition. Disposal decisions are usually made between the owner of the product, the 

appropriate state agency and local authorities.

As outlined in a 1998 Memorandum of Understanding between FSIS and FDA regarding the 

sharing of information in dual jurisdictional establishments, when warranted (e.g., for plants 

processing products subject to regulation by both FDA and FSIS), FDA would also contact FSIS 

District Office staff as well as EPA Regional Office staff to coordinate responses on food 

product disposal actions. 

3.2 Procedures for Decontamination

3.2.1 FSIS Procedures

If the contamination incident occurs in a federally inspected meat, poultry or egg processing 

facility, the owner of the establishment is required to remediate the facility and demonstrate to 

FSIS that safe production of the product can resume.

As described in Section 3.1.1, the owner of the establishment prepares a hazard analysis, a 

remediation plan, and SSOPs. The plans should also address the protection of plant staff and 

FSIS inspection and compliance personnel during the remedial actions, and the disposal of any 

secondary waste streams resulting from decontamination actions. These plans are presented to 

the FSIS District or Regional Manager, who determines whether the plans are sufficient and the 

proposed actions can be implemented. FSIS field personnel witness the execution of the planned 

actions. Prior to the restart of operations, testing is conducted to document that the remediation 

action was successful.

Where warranted, FSIS may also contact FDA District Office staff and EPA Regional Office 

staff to coordinate responses on facility decontamination actions.

3.2.2 FDA Procedures

For FDA-regulated food products, as with disposal, decontamination plans are the responsibility 

of the establishment owner working with the appropriate state or local agency. The FDA District 

Office may offer advice and observe implementation of the proposed actions. 

Where warranted, FDA may also contact FSIS District Office staff and EPA Regional Office 

staff to coordinate responses on facility decontamination actions.
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4. DISPOSAL AND DECONTAMINATION GUIDELINES

Although response to any intentional contamination incident must be considered on a case-bycase basis, this document provides some guidance on disposal options for the contaminated 

product and decontamination actions for the facility. The phases of an incident of intentional 

contamination are described and the elements of a disposal and decontamination plan are 

presented. The previous section described the procedures currently used to dispose of 

unintentionally contaminated food products and decontaminate the facilities. This section 

describes how those procedures might change when the incident involves the intentional 

adulteration of food products. Finally, this section contains information on the categorization of 

agents that FSIS and FDA have identified as having potential for use in intentional 

contamination. Appendix A contains a table outlining those specific agents. 

Depending on the nature of the incident, a great deal of interaction among regulatory agencies 

(Federal, state, and local) might be required. Appendix D provides a list of important phone 

numbers for agencies that may possibly be involved in responding to an incident of intentional 

adulteration. Users of these guidelines are strongly encouraged to consult Appendix D to 

identify appropriate emergency contacts in their states and regions in preparation for responding 

to an incident of intentional adulteration. It is important to remember that FSIS and/or FDA 

headquarters (depending on the food product) should be kept informed at all times.

4.1 Characteristics of an Intentional Adulteration Incident

FSIS or FDA are likely to become aware of an intentional adulteration incident by:

Receipt of a tip by a government agency (e.g., local law enforcement, FBI, USDA- Office 

of Inspector General) or the owner of the establishment; or

Surveillance or monitoring system results (e.g., Consumer Complaint Monitoring System, 

laboratory analytical results) indicating unusual patterns of foodborne disease incidence or 

product contamination.

Incidents involving the intentional adulteration of food products may differ from unintentional 

contamination incidents in a number of ways, including:

1. Type of agent – threat agents may include biological, chemical, or radiological materials 

not typically found in food. Disposition of these unusual agents may require specific 

actions that provide special protection for personnel and to limit contamination of other 

environmental media.

2. Scale of the incident – although an intentional adulteration incident may be limited to a 

single facility, it could also involve a coordinated attack on a number of large facilities 

within a region or throughout the country. Larger scale incidents may require 

coordination among local, state and Federal government agencies within a region as 

well as across regions, and quickly saturate available resources.
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3. Coordination with local law enforcement and FBI – the law enforcement community will 

become involved upon the suspicion or confirmation of intentional contamination. 

FSIS and FDA staff in the field will need to work with state and local law enforcement 

and the FBI to rapidly retain or detain suspect products and take samples for laboratory 

testing while preserving the integrity of the crime scene. The ability of both of these 

types of actions to proceed unimpeded requires advanced planning among the different 

agencies involved.

4. Public concern – media and the public, including government leaders, will have great 

interest and concern over an intentional contamination of the food supply. Incidents of 

panic and confusion regarding which food products have been contaminated may occur. 

Effective stakeholder risk communications will be critical under these circumstances. 

4.2 Procedures for Incidents Involving Intentional Adulteration

Sections 3.1 and 3.2 describe the procedures currently used to dispose of contaminated product 

and decontaminate facilities and equipment, respectively, following incidents of unintentional 

contamination of food products. This section describes how those procedures may change when 

the incident involves the intentional adulteration of food products. 

An intentional adulteration incident can be divided into several phases:

Discovery and response phase – the event is identified and confirmed, a response team is 

created, the team conducts an investigation, and detains, retains, and recalls contaminated 

products;

Disposal phase – a specific plan for the disposal of the waste is developed and 

implemented; 

Decontamination phase – affected equipment and structures are decontaminated based on 

a specific decontamination plan; and

Event clearance and termination.

4.2.1 Discovery and Response Phase

During the discovery and response phase, the determination of whether or not an incident is 

intentional or unintentional is made. Figure 4-1 illustrates the steps taken in this first phase. 

Once the intentional adulteration is detected or even suspected, the appropriate authorities (FSIS, 

FDA, FBI, local law enforcement, state health authorities, etc.) should be notified. In some 

cases, these authorities should be part of a response team specifically developed to deal with the 

incident. As dictated by the principles of ICS, depending on the incident, the incident command 

might be from a state or local authority (e.g., a local law enforcement or public health agency 

representative). The response team will conduct the investigation and detain, retain or recall the 

product as necessary. Disposal and decontamination cannot occur until an investigation is 

completed and the incident command has cleared the product for disposal. The development of 

disposal and decontamination plans can be initiated during the discovery and response phase.
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Threat received by FBI, local law enforcement, other 

government agency, or facility owner

Surveillance/monitoring systems suggest cluster 

of foodborne disease or product contamination

Establish response team and identify command

Conduct investigation

Detain/retain product

Recall products, as needed

Clearance for disposal of contaminated food products and decontamination of 

equipment and facility obtained from incident command

As appropriate:

Notify local law enforcement and the FBI

Notify FSIS District or Regional Manager or FDA District Director, who will notify respective 

headquarters

Headquarters will determine whether to activate the Emergency Management Committee

Notify establishment owner

Notify other government agencies who need to be informed (e.g., APHIS, FNS, AMS)

Notify State Department of Health

Potential Intentional Adulteration Event Detected 

Figure 4–1. Discovery and Response Phase
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4.2.2 Disposal Phase

A key element of the disposal phase is the development and completion of a disposal plan. As 

illustrated in Figure 4–2, an approved disposal plan for the contaminated products is required to 

show how the waste will be properly dispositioned. 

Disposal clearance obtained from incident command

Facility owner works with FSIS field personnel, 

FDA District Office, and other state and local 

authorities to develop a plan to dispose of the 

contaminated products

The disposal plan should include: 

- presentation of different disposal options 

available for the agent (see Appendix A) 

and the proposed option(s) selected for the 

disposal actions

- identification of disposal facility willing to 

accept waste

- contingency plan in case disposal capacity 

is saturated – additional disposal sites, 

different disposal method, means of 

transportation for any required product 

transferring, etc. 

Submit the plan to the response team for review 

and approval

Plan approved 

by response 

team?

Facility owner obtains the necessary permits 

or permit modifications for disposal process, 

working with Federal, State and/or local solid 

waste contact and waste facility. FSIS and/or 

FDA field personnel provide oversight.

Facility owner procures the necessary 

transportation means and permits for transferring 

contaminated products from the site to the final 

disposal facility

Facility packages the 

contaminated waste for 

the transfer

Transfer waste to disposal site

Dispose of waste according to the plan

NO

NO

FSIS and/or FDA field personnel oversee the 

disposal process and ensure that the 

contaminated product cannot get back into the 

food supply

State and local EPA officials oversee the 

disposal process to ensure that the 

contamination does not spread to other media

Does disposal meet 

acceptance criteria?

Incident command declares 

disposal action complete YES

YES

Figure 4–2. Disposal Phase
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Federal oversight of the development of the disposal plan depends on the type of food product:

If the food product is under FSIS regulatory authority, the establishment owner will work 

with FSIS headquarters, field personnel, and the District or Regional Manager to develop 

the disposal plan, with consultation from state and local agencies. 

If the contaminated product is under FDA regulatory authority, the facility owner will 

work with the state and local agencies to develop the disposal plan. The FDA District 

Office will provide support in the plan development if requested.

Key elements of the disposal plan should address the following questions:

What is (are) the contaminant(s) or threat agent(s)?

How is the contaminated food matrix categorized (e.g. hazardous waste, municipal waste, 

radiological waste, non-hazardous waste requiring special handling, or unknown – see 

Appendix A)?

What is the quantity of the contaminated product for disposal?

What is the preferred disposal method (land disposal, incineration, rendering)?

Is the selected disposal technique acceptable according to state, local, and Federal 

regulations?

Where is the final disposal facility?

What are the logistics for moving the contaminated products from the site to the disposal 

facility?

Is transportation required for the transfer of waste to the final disposal site? 

What are the required permits associated with the disposal process and how are they 

procured? Is assistance from state, local, and Federal government agencies required? 

Is there a health and safety protection plan for the workers who will be involved in the 

disposal process? If so, what is the plan?

Who and what organizations will be involved in overseeing the disposal process?

What are the acceptance criteria for the disposal process?

The development of the disposal plan may include a template for waste profiling and preselections of facilities. The plan may also address potential training and inoculation 

recommendations for disposal facility workers. For disposal by landfill or rendering in 

particular, there may be a limited quantity of available disposal capacity. It may be prudent to 

negotiate blanket purchase agreements with disposal companies before a crisis. The disposal 

facilities need to be contacted prior to the completion of the disposal plan. Packaging and 

transportation will be partially driven by the disposal facility chosen. Potential disposal 
Guidelines for the Disposal of Intentionally Adulterated Food Products and the Decontamination of Food Processing Facilities

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techniques need to be evaluated early on in the process, and a disposal facility representative 

brought in at that time. In some cases it may be necessary to address the disposal of 

decontamination residuals.

Once the plan is completed by facility management, it will be submitted to the incident manager 

and the appropriate state level solid waste agency for review and acceptance. If the plan is 

accepted, the facility will proceed with disposal according to the plan. Any deviations from the 

plan should be communicated immediately to the incident manager and the agencies overseeing 

the disposal action; authorization from the incident manager is required prior to proceeding to the 

next step. 

FSIS and FDA observation and oversight of the disposal process helps to ensure that the disposal 

is successful and that contaminated product cannot be reintroduced into the food supply. 

Oversight by EPA or environmental quality authorities ensures that the contaminated products 

are disposed of properly and that there will be no further contamination of other media (i.e., air, 

groundwater, or soil).

Once all of the contaminated products are disposed of properly, the results will be reported to the 

incident manager and the appropriate state agency as part of the event clearance and termination 

process. However, the event is not considered closed and complete until decontamination and 

clearance have occurred. 

4.2.2 Decontamination Phase

Figure 4–3 illustrates the necessary steps preceding decontamination and closure of the event. 

Like the disposal phase, a plan must be developed by the facility owner with input from the FSIS 

field personnel and headquarters as well as state and local authorities. Options for 

decontamination techniques can be found in Appendix B. Decontamination of facilities or 

equipment will likely occur after the contaminated products have been removed or collected and 

disposal response actions have been completed.

In most cases, the owner of the establishment has an interest to conduct a cost-effective and 

timely remedial action in order to get the facility back on line as quickly as possible. However, 

the response team, including FSIS, FDA, and EPA, may need time to determine the most 

appropriate decontamination techniques for the incident, depending upon the threat agent. 

Intentional adulteration incidents may involve the use of threat agents not typically found as 

contaminants in food sector industrial facilities. Alternatively, the owner of the establishment 

may determine that the remedial actions required to restart the plant will not be cost-effective 

because the ability to sell product from the facility upon restart has been complicated by public 

opinion about the incident.
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Is full 

decontamination 

economically 

feasible?

Select method(s) 

of dismantling, 

decontamination, 

and disposal

Contaminated facility owner works 

with FSIS field personnel , FDA 

District Office, and state and local 

authorities to develop a 

decontamination plan (see Appendix 

B for decontamination options)

Submit decontamination plan to 

response team for review and 

approval

Plan approved 

by response 

team

Facility owner obtains the 

necessary permits for the 

decontamination process including 

permit for use of decontamination 

agents under EPA Crisis Exemption 

if necessary

Is/are selected 

method(s) 

acceptable?

FSIS and/or FDA field personnel 

oversee the decontamination process to 

ensure that the facility and equipment 

can be reintegrated into the food 

services 

State and local EPA officials oversee 

the decontamination process to ensure 

that the contamination is completely 

removed and secondary wastes are 

disposed of properly

Facility owner:

procures decontamination 

services

decontaminates equipment and 

facilities as planned

NO YES

YES NO

NO

Adulterated product removed from contaminated area(s). Potentially contaminated 

equipment and facilities are cleared for decontamination by incident command

NO YES

Incident command 

declares 

decontamination action 

complete

Does 

decontamination 

meet acceptance 

criteria?

YES

Post decontamination 

sampling and analyses 

conducted to confirm that the 

decontamination is 

successful

Figure 4–3. Decontamination Phase
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In some cases it may be necessary to perform environmental sampling outside of the 

contaminated facility to determine whether contamination has spread beyond its boundaries. If 

contamination has spread to roads, other facilities, or private residences for example, additional 

decontamination and disposal may be necessary. Roles and responsibilities of the various 

agencies for environmental sampling and decontamination and disposal outside the facility 

would be determined and assigned within the ICS.

As discussed earlier, Appendix B provides general guidance about types of decontamination 

techniques that may be useful for threat agents of concern for food products. However, the 

specific techniques required to effectively remediate facilities or equipment for a given incident 

should be decided on a case-by-case basis after careful consideration of the incident operational 

parameters. Worker protection or facility personnel concerns about safety and the generation and 

disposition of secondary waste streams resulting from the remedial actions should be discussed 

in the decontamination plan and factored into any recommendations. 

Data on the efficacy on decontamination technologies for terrorist agents are scarce. EPA has 

reviewed data related to the safety and effectiveness of some decontamination technologies such 

as anthrax decontamination, but in general it can be difficult to find specific recommendations. 

The efficacy of decontamination technologies is known to vary with site-specific conditions 

including surface roughness, contaminate concentration, surface pH, and contact time. Efficacy 

also varies with different decontamination situations such as building walls, hard surfaces, office 

equipment, furnishings, personal protective equipment, and other debris that may be generated. 

Since each site is different, each cleanup plan must be tailored to the unique situation at that site. 

Due to the hazards potentially associated with terrorist agents, it is essential for facility owners to 

work closely with EPA and other local, state, and Federal agencies with expertise in sampling, 

decontamination, and protection of workers. 

4.2.3 Event Clearance and Termination

Once the incident command, which would include or consult with all relevant agencies, declares 

the disposal and decontamination adequately completed, the incident is considered closed and 

terminated.

4.3 Categorization of Threat Agents

FSIS and FDA have considered the types of agents that might be used to intentionally adulterate 

food products. These agents include microbial pathogens, toxins, chemicals, and radionuclides. 

The addition of these agents to food products would produce waste materials that must be 

disposed in a manner that prevents the transfer of toxic constituents from one medium (i.e., food 

matrices) to another (e.g., groundwater, atmosphere). 

Although specific disposal decisions will vary on a case-by-case basis, depending on the 

particular aspects of each incident, Table A-1 in Appendix A generally categorizes or bins 

representative threat agents by potential waste management category (i.e., disposal as hazardous 

waste, municipal solid waste, special case waste, or radioactive waste). For example, the 

presence of certain agents will cause the contaminated food to be considered a hazardous waste. 

Disposition of such waste must comply with the requirements for hazardous waste management, 
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including the use of engineered landfills and approved incinerators. The addition of other agents 

will cause the contaminated food to be considered a municipal waste, which can be managed by 

a wider range of potential options. Wastes contaminated with characteristic wastes should go to 

hazardous waste facilities. Non-hazardous wastes should go to non-hazardous waste facilities. 

Wastes that are not hazardous but have some risks may potentially be disposed of/treated as 

hazardous wastes. The purpose of binning the agents is to provide some guidance for the disposal 

of contaminated food products using representative threat agents by illustrating a range of 

considerations and options. Additional details regarding available disposal options are also 

presented in Appendix A. Appendix B presents information on potential decontamination 

options for representative threat agents. Actual remediation decisions will be made at the state 

and local level on a case-by-case basis in consultation with the company and may differ from 

these suggestions.
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5. RESEARCH AND RESPONSE NEEDS

Table 5–1 provides a summary of the data and response needs and potential solutions identified 

during development of these guidelines. Other considerations for research are also listed below.

Table 5–1. Summary 

Response Needs Potential Solutions

Coordination among FSIS, FDA, FBI and local law 

enforcement during incident response needs 

improvement.

FSIS is currently developing protocols for communication and 

coordination of response efforts.

FSIS is testing protocols using Table Top Exercises.

Case studies and lessons learned information is poorly 

documented.

Develop procedures for documenting case histories of all 

contamination events (unintentional and intentional), including 

lessons learned.

Revise procedures, based on documented information, to 

improve response capabilities.

Contaminated products may require temporary storage 

pending decisions about disposal options. Plans for 

possible storage options are not in place.

At the District Office level, develop contingency plans for the 

interim housing of contaminated products, pending disposal, to 

improve response preparedness for adulteration incidents.

Local and regional disposal resources (e.g., landfills, 

incinerators) may be overwhelmed during a large incident 

or multiple incidents within a region.

Develop a network of potential disposal resources at the District 

Office level to improve the capability to respond to surge 

capacity demands.

Private sector decontamination capabilities may be 

exceeded during a large local or multiple regional 

incidents.

Identify a network of companies with specialized expertise to 

assist in addressing the need for remedial action support under 

surge conditions.

Coordinate access to other specialized Federal resources [e.g., 

Department of Defense Northern Command, (DOD 

NORTHCOM); National Guard] that might be needed under 

certain conditions.

Analytical laboratory capacity may be exceeded during a 

large local or multiple regional incidents.

Using the FERN model, develop local networks of laboratories, 

including state, academia, and private sector labs that may be 

quickly activated to accommodate surge requirements.

There is a lack of analytical methods for some threat 

agents in food matrices and disposal of threat agents.

1) Catalog:

Threat agent/food matrix pairs for which methods are 

currently available

List of test methods under development

List of priority testing needs 

2) Coordinate laboratory methods research and development 

efforts with the FDA, CDC, ARS, and universities. 

Food products contaminated with threat agents that have 

already been purchased by consumers might require 

special handling. For example, the contaminated product 

might be too dangerous or perceived as being too 

dangerous to be handled by consumers.

FSIS and FDA should explore developing agreements with state 

and local HAZMAT teams and the National Guard or 

NORTHCOM for support in collecting food products and other 

associated contaminated materials from consumer homes for 

incidents involving certain threat agents.

Effective decontamination techniques might not be 

readily available for all threat agents of concern.

Coordinated research and development programs should be 

undertaken by EPA, FSIS, ARS, FDA, CDC, DOD, DHS, and 

the academic community.

Contractors might not start removal procedures without 

first receiving indemnification against liability that could 

result from release of harmful substances.

EPA should determine if some form of contractor 

indemnification is needed for food adulteration events and if 

agreements could be pre-negotiated. 
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Other research and response needs that merit consideration include:

a) The purchase and stockpiling of transportable decontamination and disposal equipment 

that could be brought to the contaminated site; 

b) The impact of facility decontamination techniques on disposal of residues, both from a 

cost and an environmental perspective.
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APPENDIX A – POTENTIAL DISPOSAL OPTIONS AND TECHNIQUES 

FOR THREAT AGENTS

This appendix provides information on disposal techniques for dealing with threat agents. In 

Table A–1, potential threat agents and their characteristics and the disposal category that food 

contaminated with the agent belong to is identified. Disposal options for wastes belonging to the 

different categories are then discussed. Adulterated food products might be categorized as 

hazardous waste, non-hazardous waste that may require special handling, non-hazardous waste 

that can be treated as municipal waste, or radiological waste, depending on the adulterant and its 

concentration. Once it has been determined which category is most appropriate for the 

contaminated product, the corresponding technique should be presented in the disposal plan.

Table A–1. Disposal Considerations by Agent Category

Agents

Heat 

Resistant Special Considerations

Disposal 

Categorya

Bacteria b, c, d No Some have inhalation concerns – potential exposure pathway II & III

Spores e, f Both Some have inhalation concerns – potential exposure pathway II & III

Toxins c, f Both Some have inhalation concerns – potential exposure pathway II & III

Chemical Agents g, h Both Potential chronic health effects – Groundwater contamination I & II

Radionuclide Agents No IV

Unknown Agents II

a Definition of Disposal Categories:

Disposal Category I – Waste contaminated with chemicals identified as ―Toxicity Characteristic‖ (TC) Hazardous Waste 

constituents at concentrations exceeding those listed in Table 1 of 40 CFR Part 261 should be disposed of in accordance with 

RCRA hazardous waste requirement in 40 CFR Part 264. However, if the waste constituent concentration does not meet the 

TC level listed in Table 1, the waste is then considered as a non-hazardous waste and can be disposed of as municipal waste 

(see Disposal Category III). 

Disposal Category II – These wastes are contaminated with agents that are not listed as hazardous wastes by EPA’s 

regulations. However, due to their potential toxicities, these contaminated wastes should receive special handling. In addition, 

wastes contaminated with unknown agents should also receive special handling.

Disposal Category III – These wastes are contaminated with agents that can be disposed of as municipal wastes.

Disposal Category IV – Disposal of wastes contaminated with radioactive materials should be in accordance with NRC/DOE 

regulations. 

b

In general, microbial pathogens do not survive long in the environment outside of a host. Therefore, it should be safe to dispose 

of wastes contaminated with these agents in municipal landfills or municipal incinerators, unless otherwise specified below. 

Spore forming microorganisms are an exception.

c

Some agents are harmful when inhaled in large doses; wastes contaminated with these agents should receive special handling.

d Mycobacterium spp. is highly infectious when inhaled; waste contaminated with this agent should receive special handling. 

e Anthrax and Coxiella spores are infectious when inhaled. In addition, as specifically required by 9 CFR 314.3(b), carcasses and 

parts condemned because of anthrax at official establishments that are not equipped with tanking facilities shall be disposed of 

by (1) complete incineration or (2) by thorough denaturing with appropriate disinfectant prior to disposal in accordance with 

state or municipal authorities. Wastes contaminated with these agents should receive special handling. 

f

Some of these agents are toxic when ingested but have not been shown to be harmful when inhaled. Furthermore, because it is 

unlikely that they will be released into the atmosphere or groundwater in sufficient quantities to cause adverse health effects, 

wastes contaminated with these agents may be disposed of as municipal waste. 

g

Some of these agents are listed by EPA as acutely hazardous commercial pesticides under 40 CFR 261 (RCRA ―P‖ list). Wastes 

contaminated with one of these agents are not required to be designated as hazardous waste per 40 CFR 261.33 but they should 

receive special handling. A contaminated product having the presence of a ―P waste‖ does not automatically make it a hazardous 

waste. However, if the total quantity of the contaminated waste exceeds 1 kg, it is strongly suggested that the contaminated 

product be handled as a hazardous waste. 

h These pesticides are not listed under 40 CFR 261. However, they are acutely toxic, can cause chronic health effects, and may

contaminate groundwater. Therefore, wastes contaminated with these agents should receive special handling.
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A.1 POTENTIAL DISPOSAL TECHNIQUES

It is important to dispose of contaminated food products in an environmentally responsible 

manner. Fortunately, there is a long history of safely disposing of food contaminated with 

biological contaminates. Many of the same technologies can be used to dispose of food 

intentionally contaminated with biological, chemical or radiological agents. This section 

provides an overview of techniques that may be applicable for disposal of contaminated food 

products. The most appropriate disposal approach must be decided on a case-by-case basis. It is 

important that the facility owner be in close interaction with local, state, and Federal regulatory 

authorities. 

A.1.1 Rendering

The most common technique used to dispose of contaminated meat and poultry products is 

rendering. Rendering is a process in which purified fat and protein products are recovered from 

inedible portions of animal and poultry by cooking at high temperatures following by a 

separation of the fat and proteins. The cooking is done to remove moisture and kill bacteria. 

Anthrax spores will also not survive the rendering process (1). In addition, the process provides 

an opportunity to reduce the quantity of waste requiring disposal. 

In general, there are two types of animal rendering processes, edible and inedible (2): 

Edible rendering plants process fatty animal tissue into edible fats and proteins. The plants 

are normally operated in conjunction with meat packing plants under FSIS inspection and 

processing standards. 

Inedible rendering plants produce inedible tallow and grease, which are used in livestock 

and poultry feed, pet food, soap, and the production of fatty-acids.

A.1.1.1 Edible Rendering

A typical edible rendering process consists of feeding ground fat trimmings (usually consisting 

of 14 to 16 percent fat, 60 to 64 percent moisture, and 22 to 24 percent protein) via a belt 

conveyor to a melt tank. The melt tank heats the materials to about 110oF, and the melted fatty 

tissue is pumped to a disintegrator, which ruptures the fat cells. The proteinaceous solids are 

separated from the melted fat and water by a centrifuge. The melted fat and water are then heated 

with steam to about 200oF by a shell and tube heat exchanger. A second-stage centrifuge then 

separates the edible fat from the water, which also contains any remaining protein fines. The 

water is discharged as sludge, and the "polished" fat is pumped to storage (2).

A.1.1.2 Inedible Rendering

There are two processes for inedible rendering: the wet process and the dry process. Presently, 

only the dry process is used in the United States, since the wet process is energy inefficient, 

generates too much liquid waste, and has a negative impact on the quality on the fat produced. 
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Dry rendering is a batch or continuous process that removes moisture from raw material in order 

to release fat. Following dehydration, the melted fat and protein solids are separated and 

stored (2).

A.1.1.2.1 Batch Rendering Process

In the batch process, the raw material from the receiving bin is conveyed to a crusher for size 

reduction to improve cooking efficiency. The raw material is then transferred to a batch cooker 

where it is heated to about 275oF. Following the cooking cycle of 1.5 to 2.5 hours, the contents 

are discharged to the percolator drain pan (equipped with a screen) to separate fat from protein 

solids. 

From the percolator drain pan, the separated protein solids are then conveyed to a screw press, 

where a complete separation of the fat from the solids is done. These solids, called cracklings, 

are then ground and screened to produce protein meal. The fat from both the screw press and the 

percolator drain pan is centrifuged or filtered and stored in the crude animal fat tank (2).

A.1.1.2.2 Continuous Rendering Process 

The continuous rendering system is similar to a batch system except that a single, continuous 

cooker is used rather than several parallel batch cookers. In the continuous system, the raw 

material is continuously charged into a cooker, which is typically a horizontal, steam-jacketed 

cylindrical vessel equipped with a mechanism that continuously moves the material horizontally 

through the cooker.

Continuous cookers cook the material faster than batch cookers, and typically produce a higher 

quality fat product. From the cooker, the material is discharged to the drainer, which performs 

the same function as the percolator drain pan in the batch process. The remaining operations are 

generally the same as the batch process operations (2).

It is important to note that the application of rendering is situation dependent. For example, 

waste contaminated with hazardous chemicals may not be appropriate for rendering since 

equipment and products generated from the process may be considered as contaminated, thus 

generating additional secondary wastes requiring disposal. If a food product is contaminated with 

a hazardous constituent (i.e., arsenic or mercury) and the contaminated food fails the toxicity 

characteristic (TC) then the waste is hazardous and should not be run through a rendering plant. 

The hazardous waste would need to be treated or disposed of in an acceptable hazardous waste 

unit or facility after meeting the Land Disposal Restrictions (40 CFR Part 268). The same might 

be true for waste requiring special handling. 

A.2 NON-HAZARDOUS WASTE DISPOSAL

Non-hazardous waste is disposed of as municipal wastes. Municipal wastes can be disposed of 

by land disposal or by combustion techniques. Brief descriptions of municipal waste disposal 

techniques are provided below.
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A.2.1 Land Disposal Techniques

A municipal solid waste landfill (MSWLF) is a discrete area of land or an excavation that 

receives household waste. An MSWLF is not a land treatment unit, surface impoundment, 

injection well, or waste pile, as those terms are defined in the law (3). Although MSWLFs are 

similar to hazardous waste landfills in design and operations, they are not subject to the stringent 

regulations that are imposed on the latter. 

An MSWLF unit may receive types of wastes other than municipal waste as defined under 

Subtitle D of RCRA, such as commercial solid waste, non-hazardous sludge, small quantity 

generator waste, and industrial solid waste. Such a landfill may be publicly or privately owned. 

Additional information on MSWLFs can be found in the Solid Waste Disposal Facility Criteria –

Technical Manual (3).

A.2.2 Combustion Techniques

There are three types of combustors that may be used to burn municipal waste: large municipal 

waste combustors; small municipal waste combustors; and commercial and industrial solid waste 

incineration units. These are discussed briefly below. For more information on municipal waste 

management techniques, please refer to the following link: http://www.epa.gov/ebtpages/ 

wastsolidmunicipalsolidwaste.html.

A.2.2.1 Large and Small Municipal Waste Incinerators

Large municipal waste combustors are incinerators that are capable of burning greater than 

250 tons of municipal waste per day and that burn household, commercial, and/or institutional 

waste. Burning waste reduces its volume before disposal into a landfill. Municipal waste 

combustors include the subcategory of waste-to-energy plants, which generate electricity or 

steam from burning waste.

Large municipal waste combustors are field constructed units ranging from 50 to 1,000 tons per 

day (tpd). A municipal waste combustion facility might be comprised of multiple combustors 

and some have capacities up to several thousand tpd. In these large combustors, the waste is 

gravity or ram-fed to a single combustion chamber. The waste is moved through the combustor 

via a grate system. Air is supplied in excess of stoichiometric conditions through the grates and 

into the combustion chamber above the grates. These units are designed with either waterwall or 

waste heat boilers for energy recovery (4). Small municipal waste combustors have a similar 

design but small capacity. They are normally prefabricated units capable of burning 5 to 

150 tpd. The incinerators are of two designs, starved-air or excess-air (4).

A.2.2.2 Commercial and/or Industrial Incinerators

EPA has separate regulations and guidelines for commercial and/or industrial type solid waste 

incineration units. The regulations and guidelines apply to incinerators used by commercial and 

industrial facilities to burn non-hazardous solid waste.
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A.3 HAZARDOUS WASTE DISPOSAL

There are several methods that can be used to dispose of hazardous wastes. The two major 

techniques approved by EPA are land disposal technologies and combustion. Discussions of 

these two techniques are provided below.

A.3.1 Land Disposal Techniques

EPA has promulgated regulations on the design and operation of land disposal units (LDUs) for 

managing hazardous wastes. EPA defines an LDU as landfill, salt dome or bed formation, 

surface impoundment, waste pile, underground mine, injection well, underground cave, or land 

treatment facility.1

For solid hazardous contaminated food products (e.g. powdered eggs) landfills and incineration 

will most likely be the selected methods of choice. For liquid hazardous contaminated food 

products or any secondary wastewater from the decontamination process, surface impoundments 

or land treatment facilities may be appropriate. 

Landfills are land disposal sites that are protected by an engineered cover to protect against 

surface infiltration, and lined with an almost impermeable liner to prevent migration of wastes to 

the surrounding environment. They are monitored from the inception to post-closure phases. 

They are regulated by EPA under 40 CFR 264, Subpart N.

Landfills are subject to minimum technological requirements; that is, they must be designed 

with:

a cover;

a double-liner;

a leachate collection and removal system;

a leak detection system;

a site-specific leachate flow rate, also known as an action leaching rate, to indicate when a 

unit is no longer functioning properly, and;

storm water run-on and runoff controls to prevent migration of hazardous constituents for 

at least a 25-year storm (3).

Under 40 CFR 264.314 placement of bulk or non-containerized liquid hazardous waste or 

hazardous waste containing free liquids in any landfill is prohibited. Placement of non-hazardous 

liquids in a landfill is also essentially prohibited. In the case of destroying food products, 

therefore, it may be necessary to turn liquids into solids before disposal in a landfill. There are 

 

1

Under Subtitle C of the Resource Conservation Recovery Act (RCRA), Section 3004(a), EPA has promulgated regulations on the design and 

operations of land disposal units (LDUs) for managing hazardous wastes which are codified in 40 CFR 264 (Ref. 1). 
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certain situations when containers holding free liquids can be placed in a landfill, such as small 

containers (i.e., ampules), containers that are products (i.e., batteries), or lab packs. If sorbents 

are used to treat hazardous wastes so that the waste no longer contains free liquids, the owner 

and operator must use non-biodegradable sorbents.

To prevent significant voids that could cause collapse of final covers when containers erode, and 

to maintain and extend available capacity in hazardous waste landfills, containers placed in a 

landfill must be either at least 90 percent full or crushed, shredded, or in some other way reduced 

in volume, unless the containers are very small, such as ampules (3).

A.3.2 Combustion Techniques

Combustion is also commonly used to manage hazardous wastes. Combustion can permanently 

destroy some toxic organic compounds contained in hazardous waste by breaking their chemical 

bonds and converting them to their constituent elements. This technique can also reduce the 

volume of waste to be disposed of on land by converting solids and liquids to ash. 

During burning, organic wastes are converted from solids and liquids into gases. These gases 

pass through the flame, are heated further, and eventually become so hot that their organic 

compounds break down into the constituent atoms. These atoms combine with oxygen and form 

stable gases that are released to the atmosphere after passing through air pollution control 

devices (5).

The stable gases produced by the combustion of organics are primarily carbon dioxide and water 

vapor. Depending on waste composition, however, small quantities of carbon monoxide, 

nitrogen oxides, hydrogen chloride, and other gases may form. Emissions of these pollutants are 

regulated under EPA’s RCRA combustion unit standards.

The management or disposal of metals, ash, and other byproducts of the combustion process is 

also regulated by EPA’s RCRA standards. Ash is an inert solid material composed primarily of 

carbon, salts, and metals. When ash is removed from the combustion chamber, it may be 

considered hazardous waste due to derived rules or its chemical composition. Also, small 

particles of ash carried up the stack with the exhaust gases (also called fly ash) may carry 

hazardous constituents out of the unit and into the environment. Since combustion will not 

destroy inorganic compounds present in hazardous waste, such as metals, it is possible that such 

compounds may also end up in ashes at harmful concentrations. Ash residue is subject to 

applicable RCRA standards and may need to be treated for metals or other inorganic constituents 

prior to land disposal (4).

A.4 SPECIAL HANDLING TECHNIQUES - MEDICAL WASTE 

INCINERATION

In most cases, it should be possible to determine (through sampling and analysis) whether a 

contaminated food product is hazardous or non-hazardous (municipal) waste. However, there 

are situations for which it may not be possible to determine what the contaminant or threat agent 

is, or circumstances when the contaminated food product is classified as a non-hazardous waste, 
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but due to special circumstances, it may not be advisable to dispose of it as municipal waste. In 

such cases, special handling techniques should be considered. The determination of when to use 

special handling techniques to dispose of contaminated food products should be made on a caseby-case basis.

Some hazardous waste can be characterized as medical waste and should be disposed as such. 

Medical waste is generally defined as any solid waste that is generated in the diagnosis, 

treatment, or immunization of human beings or animals, in research pertaining thereto, or in the 

production or testing of biological materials. In general, incineration is used most often for 

disposing of medical wastes. However, emerging alternative approaches to incineration, such as 

reclamation and size reduction are being studied and pursued by private industry. 

Hospital/medical/infectious waste incinerators (medical waste incinerators - MWIs) are 

incinerators used by hospitals, health care facilities, and commercial waste disposal companies to 

burn hospital, medical, and infectious wastes. Burning this waste reduces its volume and destroys 

pathogens in the waste material (6).

Although there are a variety of MWIs, the basic design of all MWIs consists of primary and 

secondary combustion, which are sequential operations that are typically carried out in two 

separate chambers. In the primary chamber, the waste is loaded and ignited, the volatile organic 

components driven off, and the nonvolatile materials combusted to ash. The volatile organic 

components released from the primary chamber are combusted in the secondary chamber.

For more information about medical waste incinerators, please refer to: http://www.epa.gov/ 

epaoswer/other/medical/.

A.5 RADIOACTIVE WASTE DISPOSAL

For incidents involving contamination of food products with radioactive materials, waste 

products would be considered radioactive low level waste or transuranic waste, depending on the 

radioisotope and amount of radioactive material used. If the contamination consists of a 

hazardous chemical and a radioactive component, then the resulting waste is termed as mixed 

waste (e.g., mixed low level radioactive waste). The discussion provided below only applies to 

low level waste. For more information on how to deal with mixed waste, please refer to the 

following link: http://www.epa.gov/radiation/mixed-waste/. 

Disposal of low-level waste is regulated by the U.S. Nuclear Regulatory Commission (NRC). 

Low level wastes are defined as items that have become contaminated with radioactive material 

or have become radioactive through exposure to neutron radiation. The radioactivity can range 

from just above natural background levels to very highly radioactive in certain cases, such as 

parts from inside a reactor vessel in a nuclear power plant. Low level radioactive wastes are 

usually disposed by shallow land burial in engineered landfills. As required by NRC, radioactive 

materials that need to be shipped out of the operating site must be packaged for shipment to 

protect the public from exposure in the event of an accident (7). 

Transportation of radioactive materials is regulated by the Department of Transportation (DOT) 

under the Hazardous Materials Transportation Act (HMTA) and the Hazardous Materials 
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Transportation Uniform Safety Act (HMTUSA). DOT regulations cover all aspects of 

transportation, including packaging, shipper and carrier responsibilities, and documentation for 

all levels of radioactive materials (8). The type of packaging required depends on the total 

quantity of radioactivity, the form of the materials, and the concentration of radioactivity. In 

most cases, the packaging used for transport is also used for disposal. Most low level waste 

contains low enough levels of radioactivity to be shipped in strong, tight containers or DOT 7A 

Type A containers. Type A containers must be able to withstand ordinary transportation 

conditions and conform to DOT requirements stated in 49 CFR 178.350. Wastes containing 

higher levels of radioactivity are shipped in Type B containers, which must be able to withstand 

accident-type conditions. 

There are currently two low level waste disposal facilities that accept a broad range of low level 

wastes. They are located in Barnwell, South Carolina, and Richland, Washington. In addition, 

Envirocare of Utah is licensed by the NRC to operate a facility in Utah. It primarily accepts low 

level waste with small concentrations of radioactive material that are generated after a facility 

shuts down permanently and needs to remove a large bulk of contaminated material—such as 

contaminated soil or debris from demolished buildings—in preparation for NRC license 

termination (8).

The low level wastes at the Barnwell and Richland facilities are buried under several feet of soil 

in near-surface shallow trenches, usually in the containers in which they were shipped. Low 

level waste may be stored to allow short-lived radioactive materials to decay and to provide safekeeping when disposal sites are not readily accessible. The NRC believes storage can be safe 

over the short term as an interim measure; however, disposal rather than storage is preferred over 

the long term. For more information, please refer to: http://www.nrc.gov/waste/llwdisposal.html.
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A.6 REFERENCES

1. Hansen PI, Olgaard K. Zentralbl Bakteriol Mikrobiol Hyg [B]. 1984 Dec; 180 (1):3-20. 

Some Microbiological Aspects of Inedible Rendering Processes.

2. U.S. EPA, 1995. Emission Factor Documentation for AP-42, Section 9.5.3 – Meat 

Rendering Plants. Final Report. EPA Contract No. 68-D2-0159, Work Assignment 

No. II-03. Research Triangle Park, NC, September 1995.

3. U.S. EPA, 1993. Solid Waste Disposal Facility Criteria – Technical Manual. 

EPA530-R-93-017, November 1993.

4. U.S. EPA, 2003. RCRA Orientation Manual, Section III, Chapter 7 – Hazardous Waste 

Combustion. EPA530-R-02-016, January 2003.

5. U.S. EPA, 1989. Municipal Waste Combustors – Background Information for Proposed 

Standards: 111(b) – Model Plant Description and Cost Report. OAR-2004-0273-0003, 

Research Triangle Park, NC. August 14, 1989

6. U.S. EPA, 1997. Standards of Performance for New Stationary Sources and Emission 

Guidelines for Existing Sources: Hospital/ Medical/ Infectious Waste Incinerators. 

40 CFR Part 60. Federal Register, Vol. 62, No. 178. September 15, 1997.

7. U.S. NRC, 2002. Radioactive Waste: Production, Storage, Disposal. NUREG/BR-0216, 

Rev. 2. U.S. Nuclear Regulatory Commission, Office of Public Affairs, May 2002.

8. National Safety Council, 2002. A Guide to the U.S. Department of Energy – Low-Level 

Radioactive Waste. Washington, DC. January 2002.
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APPENDIX B – POTENTIAL DECONTAMINATION OPTIONS FOR 

INACTIVATING THREAT AGENTS

This appendix provides information on the potential decontamination options that can be used in 

the clean up of facilities and equipment contaminated with biological, chemical or radiological 

threat agents. Table B–1 presents some decontamination treatments that might be used for the 

various categories of threat agents of concern for food products. The specific agents within the 

agent categories can be found in Table A–1. For any decontamination effort it is crucial to 

conduct pre- and post-decontamination environmental sampling to verify the success of the 

decontamination process. It should be noted that, as with disposal, selection of the appropriate 

decontamination options should be done on a case-by-case basis after a careful review of 

available valid, documented information concerning safety and efficacy of each option. The 

appropriate options will depend not only on the type of contaminant, but also the type of surface 

that is contaminated. In the case of bacteria, spores, viruses and parasites, it may be necessary to 

obtain EPA emergency approval for the use of unregistered chemical decontamination agents.

Table B–1. Potential Decontamination Options

Decontamination 

Agents1 Applications

Agent Categories2

BacteriaSporesVirus

Special Considerations

es & 

ParasitesToxinsChemicalsRadiological Agents

Liquid Antimicrobials

Bleach4 Hard, nonporous surfaces

    To kill spores and other microorganisms, a bleach 

solution close to but not above pH 7 (neutral) and 

5,000 to 6,000 parts per million (ppm) should be 

prepared by mixing one part bleach (5.25%-

6.00%) to one part white vinegar (acetic acid) to 

eight parts water. Bleach and vinegar must not be 

combined together directly, rather some water 

must first be added to the bleach (e.g., two parts 

water to one cup of bleach), then vinegar (e.g., one 

cup), and then the rest of the water (e.g., six parts). 

The pH of the solution should be tested with a 

paper test strip. Surfaces should remain in contact 

with the bleach solution for 60 minutes (repeated 

applications will be necessary to keep the surfaces 

wet).

Liquid chlorine 

dioxide4

Hard surfaces     Liquid chlorine dioxide (500 mg/L) should be 

applied at room temperature (68oF, 20oC) and 

have a contact time of at least 30 minutes.

Liquid hydrogen 

peroxide –

peroxyacetic acid4

Hard surfaces     Peroxyacetic acid (5,000 parts per million (ppm)) 

should be applied at room temperature (68oF, 

20oC) and have a contact time of between 10 to 

20 minutes.

Physical Methods

Heat Hard surfaces     Heat and/or autoclaving can be used to inactivate 

biological agents. The effectiveness of the 

treatment depends upon time/ temperature.
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Decontamination 

Agents1 Applications

Agent Categories2

BacteriaSporesVirus

Special Considerations

es & 

ParasitesToxinsChemicalsRadiological Agents

Steam cleaning Hard surfaces     Steam cleaning physically extracts biological 

agents from equipment surfaces.

Facilities & 

structures 

High pressure heat Hard surfaces      Gas turbine jet engines are used to deliver hot 

exhaust gases, at high velocity, to decontaminate 

large items and equipment. Facilities & 3

structures 

Photochemical Hard surfaces  All microbes and many organophosphates can be 

inactivated by UV or X-ray irradiation, but spores 

Facilities & and biological toxins are more resistant

structures  

High pressure 

water/slurry jets

Hard surfaces Hot or cold high pressure (2000 psi) water/slurry 

jets can be used to remove surface contamination. 

Water should be collected and disposed of 

appropriately. 3

Quaternary ammonia 

compounds4

Hard surfaces    The application of sodium hypochlorite should be 

alternated with quaternary ammonia compounds 

(quats) in case the toxin is acid resistant.

Sodium hydroxide 

solution4

Hard surfaces     Decontamination of containers should be done 

using 5% sodium hydroxide solution, and rinsed 

with large quantities of water. Residues in 

contaminated containers should be emptied in a 

diluted form into a deep pit while avoiding 

potential contamination of ground waters.5

Gas or Vapor Antimicrobials

Gaseous chlorine 

dioxide4

Facilities & 

structures    

Chlorine dioxide gas (500-750 ppm) should be 

applied for a minimum of 12 hours, at a minimum 

temperature of 70oF, and at a minimum relative 

humidity of 65%.

Ethylene oxide4Facilities & 

structures    

Application concentration and duration not 

specified

Hydrogen peroxide

vapor4

Facilities & 

structures    

Application concentration and duration not 

specified

Methyl bromide gas4Facilities & 

structures   

Methyl bromide gas is registered for the 

fumigation of soil, buildings, and quarantine 

shipments, however, some uses are being phased 

out under the Montreal Protocol. 

Liquid Cleaners

Soap and water Hard surfaces 

and facilities & 

structures

 

In general, decontamination of metal surfaces in 

contact with radioactive materials can be achieved 

by scrubbing the surface with mild soap and water 

or bleach solution. 

Commercial products 

containing EDTA

Hard surfaces 

and facilities & 

structures



Commercial products containing EDTA and 

various solubilizers (e.g., ―Lift-Away‖) may 

enhance effectiveness. Spent solvents, rags and 

paper towels must be collected and disposed of as 

low level wastes.

Sand blasting Hard surfaces 

and facilities & 

High pressure sandblasting to is performed to 

remove surface contamination and is useful for 
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Decontamination 

Agents1 Applications

Agent Categories2

BacteriaSporesVirus

Special Considerations

es & 

ParasitesToxinsChemicalsRadiological Agents

structures porous surfaces like concrete.

Surface removal Hard surfaces 

and facilities & 

structures



Remove paint or surface layers containing 

contaminants.

Dismantling, 

removal, replacement

Hard surfaces 

and facilities & 

structures



Physical removal of selected components. 

Removed materials are shipped to disposal site as 

low level radioactive waste.

Demolition Facilities & 

structures 

Complete destruction and/or disposal of facility or 

equipment, but only after decontamination.

1

Sources used to develop the listed decontamination agents and techniques:

a. List of chemical agents that were authorized for use in past anthrax incidents for decontamination purposes by EPA Office of 

Solid Waste and Emergency Response (OSWER) Crisis Exemption (CE) statute under Section 18 of FIFRA. For more 

information, please refer to the following link: http://www.epa.gov/epahome/hi-anthrax.htm

b. Biological and chemical list compiled by the FDA and FSIS.

c. Office of the Deputy Prime Minister of UK, in ―Strategic National Guidance – The decontamination of buildings and 

infrastructures exposed to Chemical, Biological, Radiological or Nuclear (CBRN) Substances or Material‖, May 2004.

d. Inchem – Website that provides chemical safety information on several pesticides. For more information on recommended 

decontamination procedures for specific pesticides, refer to the following link: http://www.inchem.org

e. University radioactive material decontamination procedures – Tulane University, Iowa State University, etc.

2

See Table A-1 for a detailed list of agents within the different categories.

3 High pressure heat and high pressure water techniques are applicable for decontamination of organophosphate chemical agents, 

but not for other chemical agents.

4 The use of this option to inactivate B. Anthracis spores and other biological warfare agents is not registered and requires an 

exemption from EPA.

5

Sodium hydroxide solution is applicable for decontamination of all checked agents except for arsenic compounds, cyanide, 

mercury, and strychnine
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APPENDIX C – EXAMPLE SCENARIOS AND ACTIONS FOR DISPOSAL 

AND DECONTAMINATION

Example Scenario Number 1 – Processing Facility

Background

In this scenario, the adulteration incident occurs in a large ground beef processing facility. The 

incident is identified in a note received by the facility manager. Plant management immediately 

notifies the FBI, local law enforcement authorities and the FSIS Inspector of the note. The FBI 

and local police quickly set up a response team, with the local police chief as the incident 

manager. An investigation into the allegation begins. At the same time, the following actions 

are taken by FSIS staff:

The plant FSIS Inspection Program Personnel (IPP) notifies the Supervisory Public Health 

Veterinarian (SPHV) of the incident. 

The SPHV recommends the plant IPP take a regulatory control action (retention) on all 

suspected/affected product, facilities, and equipment, and verifies that all HACCP (Hazard 

Analysis and Critical Control Point) regulatory requirements (Monitoring, Verification, 

Recordkeeping, Corrective Action, Reassessment) are met.

The SPHV then notifies the Frontline Supervisor (FLS) of the incident.

Upon receiving the notification from the SPHV, the FLS immediately notifies the District 

Office and the Recall Management Staff of the incident.

The District Manager (or designee) completes a Non-Routine Incident Report (NRIR) and 

sends the report electronically to the Office of Field Operations (OFO) Senior Executive 

Duty Officer (SEDO) and the Office of Food Defense and Emergency Response 

(OFDER)

OFDER forwards a copy of the NRIR to the Office of Inspector General (OIG) through 

Office of Program Evaluation, Enforcement and Review (OPEER). 

The OFO SEDO reviews and validates the incident. The SEDO forwards the incident 

report to the OFO Assistant Administrator (AA) office for possible activation of the FSIS 

Emergency Management Committee (EMC).

Based on a thorough review of the incident report and all relevant information concerning 

the incident, the OFO AA in consultation with OFDER will determine if the EMC has to 

be convened. OFDER then activates the EMC and notifies applicable personnel per FSIS 

Directive 6500.1.

The FSIS EMC advises appropriate personnel to take control actions, such as sampling of 

the affected product, containers, equipment, and the environment.
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The plant management reassesses their HACCP Plan to ensure that the hazard is addressed 

in the hazard analysis. The HACCP Plan will be revised accordingly, per 9 CFR 417.3 

based on the results of the reassessment. 

Disposal

After a quick turnaround, results from the investigation indicate that adulteration has occurred 

and that the contaminated product was contained within the processing facility. Trace forward 

and trace back investigations are initiated to confirm that no contaminated products were moved 

out of the facility. The investigation also confirms that the agent used was anthrax spores. 

Although the incident investigation is still in progress, the incident manager recognizes the need 

to dispose of the contaminated products and potentially decontaminate the facility and equipment 

for continuity of operations. The incident manager clears the products for disposal and the 

facility for decontamination.

Upon receipt of the release order from the incident manager, the FSIS IPP works with the 

District Manager and the owner of the facility to develop plans for the disposal and 

decontamination actions. After consultations with the state and local health and environmental 

officials, the following determinations are made:

About 100,000 pounds of contaminated product require disposal.

The contaminated product is not considered to be a hazardous waste (per EPA’s 

regulations). The affected product is classified as a Category II waste (non-hazardous 

waste requiring special handling). Therefore, plant management must select a method for 

disposition judged to be appropriate by local authorities and FSIS.

The owner has several options for disposing of the contaminated product, including land 

burial, incineration, and rendering. Taking into account the requirements under 

9 CFR 314.3 on the disposal of carcasses and products contaminated with anthrax spores, 

the owner proposes incineration because the facility has no tanking capabilities. Given 

the concern about potential airborne release of anthrax spores, thermal destruction at a 

medical waste incinerator was selected as the disposal option. The FSIS IPP, the District 

Manager, and the state and local environmental authorities agree that the proposed 

medical waste incineration would be an acceptable disposal technique. 

The plant develops agreements with the multiple medical waste incineration facilities 

needed to handle the batch of contaminated product.

To provide containment during transfer to the medical waste incinerators, the adulterated 

product is placed into a disposable container with double polyvinyl or polyethylene liners 

and sealed. The containers satisfy DOT regulations. At the incinerators, the entire 

container is fed for combustion.

Plant management obtains the necessary permits for the disposal action from local 

authorities and from DOT for the waste transfer.
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The proposed disposal plan is submitted to the incident manager for review, and is accepted. 

The owner proceeds with the plan and the contaminated product is transferred to a medical waste 

incinerator for thermal destruction. The disposal is observed by the FSIS IPP and local heath 

and environmental agency officials and accepted as successfully completed. The results are 

reported to the incident manager for final closure of the incident. Due to the intentional nature of 

the contamination it may be necessary to preserve samples of the contaminated product for 

analysis by law enforcement and the FBI. 

Decontamination

The decontamination process begins when the owner of the facility receives clearance from the 

incident manager. In this instance, the facility owner has an interest in returning the plant to 

operations as soon as possible. Since anthrax can be an airborne as well as a foodborne toxin, the 

potential for anthrax contamination may include the whole production facility or a few 

immediate areas where the contamination was found. Depending on the nature and extent of the 

contamination, the following aspects may need to be addressed in the decontamination plan:

Pre- and post-treatment sampling to determine the effectiveness of the decontamination 

process.

Decontamination of hard surface (non-porous) equipment. 

Removal and replacement of hard-to-clean parts. 

Fumigation of areas potentially contaminated by the agent.

Obtaining concurrence from local, state and Federal environmental protection officials on 

the proposed decontamination techniques.

Obtaining the necessary authorization for use of decontamination agents from EPA under 

the Crisis Exemption (CE) statute (if needed).

Procurement of the necessary decontamination services from professional licensed and 

insured contractors if the specialized capabilities do not exist within the company. This 

also requires procurement of the needed decontamination agents.

In this case, the owner might propose to use liquid chorine dioxide at the concentration and 

application time suggested in Appendix B for remediation of all hard surface equipment and nonporous structures. For fumigation of contaminated areas, the owner might select vaporized 

hydrogen peroxide as the decontamination agent.

If approved by the incident manager, with review and concurrence from local, state and/or 

Federal environmental officials, the owner of the facility could proceed with the decontamination 

process. The effectiveness of the decontamination would be confirmed through post-treatment

sampling. The FSIS Inspector and the District Manager would observe the decontamination 

process and verify the effectiveness of the process prior to giving their acceptance to the incident 

manager.
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If all results indicate that the decontamination process was successful, and the disposal was 

complete, the incident manager might declare closure of the incident even if the criminal 

investigation continues. The FSIS IPP and District Manager would approve restart of facility 

operations.

Example Scenario Number 2 – Transportation

Background

In this scenario the adulteration incident involves a shipment of products. FSIS has regulatory 

authority over shipments of meat and poultry products, whereas, FDA has regulatory authority 

over shipments of egg products and other food products. The FBI has received a tip that a tanker 

truck carrying fluid milk from Farm Cooperative A to milk processing Plant B has been 

contaminated with mercury.

The FBI begins the incident investigation and asks the state law enforcement community to set 

up a response team with the regional State Police authority as the incident manager. The 

incident manager works with FDA field staff and the state police to isolate the shipment and 

begin trace back and trace forward investigations to determine the extent of the contamination. 

In addition, DOT and the Transportation Security Administration (TSA) are consulted. Early 

results of the investigation indicate that the contamination was contained within the tanker truck

and occurred somewhere between the farm and the processing plant. No product recalls are 

necessary, since the contaminated milk was isolated prior to distribution in commerce. The 

incident manager gives clearance for disposal of the contaminated product and decontamination 

of the tanker truck after receiving investigation closure from assigned law enforcement. 

Disposal

Upon receipt of the disposal and decontamination order from the incident manager, the owner of 

Farm Cooperative A begins to draft a plan for disposing of the adulterated milk. In this case, the 

food product is regulated at the Federal level by the FDA. One difference between this scenario 

and Scenario 1 is that the FDA is less directly involved in the preparation of the disposal plan 

than FSIS. FDA’s function is to provide consultation to the owner in the planning process.

The process of preparing the disposal plan is similar to that outlined in Scenario 1. Waste 

containing mercury, the threat agent, is considered hazardous waste at mercury concentrations 

greater than 0.2 mg/L (see Appendix A), the contaminated product should be treated as 

hazardous waste. Because test results indicate a mercury concentration level that is higher than 

0.2 mg/L, the disposal options available to the owner include:

a) Land burial in an established hazardous waste disposal facility. The contaminated fluid 

milk must be solidified to immobilize the mercury in a solid matrix since land burial will 

not accept liquid waste. Or,

b) Treatment of the contaminated milk to remove most of the mercury prior to disposal. 

Various techniques have been used to remove mercury from wastewater, including 

sulfide precipitation, coagulation, adsorption, and membrane separation. Or, 
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c) Incineration of mercury contaminated liquid. Incineration of the waste may not be 

acceptable since it may require secondary treatment of the media used to control air 

pollution from incinerators (i.e., air scrubbing liquid, etc.). 

The selection of the techniques to dispose of the contaminated milk must be submitted to the 

incident manager for review and approval prior to carrying out the disposal process. Once the 

disposal plan is approved by the incident manager, the remaining steps in the disposal process 

would be similar to those outlined in Scenario 1. As in Scenario 1, the incident manager works 

closely with law enforcement and the FBI to preserve any needed samples.

Decontamination

Decontamination of a transport vehicle or fleet of vehicles may require coordination with other 

Federal agencies, such as DOT and TSA, working through the response team. Since the tanker 

truck container was in contact with the threat agent, it could be cleaned using appropriate 

decontamination agent(s). However, it may be more cost-effective for the owner of the vehicles 

to remove them from service, at least with respect to food transport, rather than attempt to 

remediate them. 

If the owner decides to remediate the tanker truck, it still might not be adequately 

decontaminated for food transport despite being considered ―cleaned‖ by EPA’s standard; food 

safety assurance could require a higher standard. Thus, if this option is selected by the owner, the 

rehabilitated tanker truck could be reused for purposes other than food processing, such as 

transporting oil or wastewater. In any case, the decontamination plan would require addressing 

these issues prior to obtaining approval from the incident manager.

Example Scenario Number 3 – Warehouse/Distribution Facility

Background

In this scenario a tip to the FSIS District Office indicates an FSIS-regulated poultry product 

stored in a warehouse has been adulterated. As outlined in Scenario 1, the following actions are 

taken by FSIS staff:

The DM notifies, by telephone, the FLS and the IPP of the tip.

The DM also notifies, by telephone and via the NRIR, the OFO SEDO and OFDER of the 

incident.

The FLS notifies the Recall Management Staff of the incident.

The FLS instructs the FSIS IPP to conduct an ―02‖ procedure to verify compliance. The 

Pre-Shipment Review has been completed.

OFDER notifies OIG and OPEER of the incident.

Under the authority and directions of the FBI, OPEER conducts a thorough investigation 

of the incident with regard to transportation and warehouse issues.
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Also under the authority and directions of the FBI, OPEER assumes control of all of the 

activities regarding the criminal act, the product in transport and in storage at the 

warehouse. Therefore, the OPEER Program Investigator becomes the incident manager.

The FSIS Enforcement Investigation and Analysis Officers (EIAO) are deployed to 

investigate the incident as coordinated by the DM and under the guidance of the OFO 

EMC representative. The tasks include sampling and analysis of the affected products, 

equipment, containers, etc.

The warehouse management reassesses their HACCP Plan to ensure that this CCP is 

addressed. If not, the HACCP Plan will be revised accordingly, per 9 CFR 417.3.

Sampling results indicate that a batch of the product was contaminated with radiological 

materials. The FSIS IPP moves to detain the products from further distribution, per instructions 

from the FLS and the DM.

Disposal

Because the poultry product was contaminated with a radiological agent, the adulterated product 

is considered to be a low-level radioactive waste. The disposal of such a waste must satisfy NRC 

requirements.

The owner of the warehouse works with FSIS personnel and the DM to develop a disposal plan. 

In this case, the regional NRC office is also called upon for consultation. Disposal options 

include:

a) Disposal of the contaminated product as low-level waste in accordance with NRC 

regulations, or

b) On-site storage of the contaminated product to allow for radioactive decay to background 

level.

Since the radiological agent could have a long half-life, storage for decay may not be acceptable. 

If low-level waste disposal is selected, the owner may be required to package the contaminated 

product and seek disposal at an approved low-level waste disposal site. The owner may also 

need to obtain approval for interstate transportation, which may raise concerns about the transfer 

of radioactive materials across state lines. These details would need to be worked out in the 

disposal plan prior to getting approval from the incident manager.

Once the plan is approved by the incident manager, the remaining steps in the disposal process 

would be similar to those outlined in Scenario 1.

Decontamination

Decontamination of a warehouse may be less difficult than cleanup of a processing facility, 

given the limited amount of equipment involved. However, similar types of considerations apply 

with respect to determining the appropriate remediation method, protection of workers, 

generation and distribution of secondary waste streams, and cost-effectiveness given the 

potential future uses of the facility. If the facility does not have the training and/or capabilities to 
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41

clean up radiological contamination, the NRC Regional Office should be contacted for 

consultations including the proper decontamination process as well as organizations that provide 

professional cleanup and survey services.

Decontamination of a hard surface in contact with the contaminated product can be 

accomplished by using mild soap solution or any available commercial radiological 

decontamination solution. The used rags and wipe materials would be collected, packaged and 

disposed as low-level waste. Post-treatment area surveys would be required to confirm that the 

radioactivity in the contaminated areas has been reduced to natural background levels.

Results of post-treatment area surveys would form the basis for the declaration of incident 

closure by the incident manager.
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APPENDIX D – CONTACT INFORMATION 

This appendix contains contact information for state agencies, in alphabetical order by state, 

which might need to be contacted by district offices in the case of an intentional adulteration 

incident (e.g. State Departments of Agriculture, Health, and Environment). Regional offices of 

the EPA and NRC are provided. Contact information for regional Federal Bureau of 

Investigation (FBI) offices is also included; the Weapons of Mass Destruction Coordinator 

should be contacted.

Unless otherwise noted, these numbers are for in-state use only during regular business hours. If 

an incident involves health or environmental effects which require immediate action by 

local authorities, call 911 or other local emergency response access numbers. Incidents 

involving CERCLA/ EPCRA Hazardous Substance/ Environmental Response and Remediation

OR Releases Affecting ―Waters of the State‖/ Water Quality may also require notification of the 

National Response Center (1-800-424-8802).

Two other important emergency contacts are:

FDA’s 24-hour emergency number (866) 300-4374 or (301) 796-8240

USDA’s Food Safety and Inspection Service Office of Food Defense & Emergency 

Response 24-hour emergency number (866) 395-9701
Guidelines for the Disposal of Intentionally Adulterated Food Products and the Decontamination of Food Processing Facilities

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STATE AGENCY CONTACT INFORMATION

ALABAMA

Department of Agriculture & Industries

Food Safety & Consumer Division Deputy Commissioner: (334) 240-7238

Department of Environmental Management

Emergency Response: (800) 843-0699

Department of Public Health

Assistant State Health Officer for Disease Control & Prevention: (334) 206-5325

ALASKA

Department of Natural Resources

Division of Agriculture, Director’s Office: (907) 761-3851

Department of Environmental Conservation

Food Safety & Sanitation Program Manager: (907) 269-7501

Department of Public Health

Director’s Office: (907) 465-3092

ARIZONA

Department of Agriculture, 

Division of Food Quality Services, Livestock Inspection and Animal Disease Control 

Programs: (602) 542-4373

Department of Environmental Quality

Emergency Response: (800) 234-5677

Department of Health Services

Office of Public Health- Emergency Preparedness & Response: (602) 364-3289

ARKANSAS

Department of Environmental Quality

Director’s Office: (501) 682-0959

Department of Health

Emergency Communications Center: (501) 661-2136

Department of Emergency Management

Incident/Disaster Reporting: (800)-322-4012

Livestock & Poultry Commission

(501) 907-2400
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CALIFORNIA

Department of Food & Agriculture

Meat & Poultry Inspection: (916) 654-0504

Animal Health & Food Safety Services: (916) 654-0881

Department of Natural Resources

Environmental Protection Agency-Deputy Secretary for External Affairs: (916) 323-2520

Health & Human Services Agency

Emergency Medical Services Authority: (916) 322-4336

COLORADO

Department of Agriculture

Inspection & Consumer Services: (303) 477-0076

Department of Public Health & Environment

Director’s Office: (303) 692-2700

CONNECTICUT

Department of Agriculture

Bureau of Regulation & Inspection Director’s Office: (800) 861-9939

Department of Environmental Protection

Emergency Spill Reporting: (860) 424-3338

Department of Public Health

Director of Environmental Health: (860) 509-7293

DELAWARE

Department of Agriculture

Food Products Inspection-Food Products Administrator: (302) 698-4539

Department Of Natural Resources

Hazardous Spills & Emissions - Environmental Emergency Notification and Complaints: 

(800) 662-8802

Emergency Management Agency

Emergency Center: (877) 729-3362

Department of Health & Human Services

Division of Public Health- Director’s Office: (302) 744-4701

FLORIDA

Department of Agriculture & Consumer Services

Division of Agricultural Environmental Services: (850) 488-3022

Division of Emergency Management

Director’s Office: (850) 413-9900
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Division of Environmental Protection

Secretary’s Office: (850) 245-2118

Department of Health

Division of Environmental Health: (850) 245-4250

GEORGIA

Department of Agriculture 

Animal Industry Assistant Commissioner: (404) 656-3671 

Food Safety Agricultural Manager: (404) 656-3632

Department of Natural Resources

Environmental Protection: (888) 373-5947

Emergency Management Agency

Director’s Office: (800) TRY-GEMA

Division of Public Health

Emergency Preparedness: (404) 657-2594

HAWAII

Department of Agriculture 

(808) 973-9560

Department of Health

Food & Drug Branch-Food Safety: (808) 586-4725

Department of Land and Natural Resources

Enforcement Hotline: (808) 587-0077

IDAHO

Department of Agriculture 

Division of Animal Industries: (208) 332-8540

Department of Environmental Quality

Director’s Office: (208) 373-0240

Department of Health & Welfare

Food Protection Program: (208) 334-5500

ILLINOIS

Department of Agriculture 

Food Safety Division Manager: (217) 785-5680

Emergency Management Agency

24-Hour Response: (800) 782-7860

Environmental Protection Agency

Office of Emergency Response: (217) 785-0830
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Department of Human Services

Office of Health Services: (217) 782-2736

INDIANA

Department of Agriculture 

Office of Commissioner: (317) 232-8774

Department of Environmental Management

Emergency Response: (317) 308-3049

Department of In-State Health 

Public Health Preparedness & Emergency Response Director: (317) 234-3545

IOWA

Department of Agriculture & Land Stewardship 

Meat & Poultry Bureau Chief: (515) 281-5597

Department of Public Health

Division of Acute Disease Prevention & Emergency Response: (515) 281-7996

Division of Environmental Health: (515) 281-5099

KANSAS

Department of Agriculture 

Food Safety Program: (785) 296-3556

Department of Health and Environment

Bureau of Epidemiology and Disease Prevention: (785) 296-1500

Report Public Health Incident: (877) 427-7317 

Report Bioterrorism Incident: (877) 427-7317 

Division of Environment Director’s Office: (785) 296-1535

KENTUCKY

Department of Agriculture 

Office of Consumer & Environmental Protection: (502) 573-0282 

Cabinet for Environmental & Public Protection 

Department of Environmental Protection: (502) 564-2150

Cabinet for Health Services

Division of Epidemiology & Health Planning: (502) 564-7243 

Division of Emergency Management

(800) 255-2587

LOUISIANA

Department of Agriculture & Forestry 

Animal Health Services: (225) 925-3962
Guidelines for the Disposal of Intentionally Adulterated Food Products and the Decontamination of Food Processing Facilities

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Department of Health and Hospitals

Public Health Division- Food & Drug Program: (225) 763-5484

Homeland Security & Emergency Preparedness

24 Hour Communications Line: (225) 925-7500

MAINE

Department of Agriculture

Division of Quality Assurance & Regulation: (207) 287-2161

Division of Animal Health & Industry: (207) 287-3701 

Emergency Management Agency

(800) 452-8735

Department of Environmental Protection 

24-Hour Hazardous Materials Spill Hotline: (800) 452-4664

Bureau of Health

Environmental Health Unit: (866)-292-3474

MARYLAND

Department of Agriculture

Maryland Food Center Authority: (410) 379-5760

Office of Marketing, Animal Industries, & Consumer Services: (410) 841-5782

Emergency Management Agency

(877) MEMA-USA

Department of the Environment 

Environmental Emergencies: (866) 633-4686

Department of Health

Office of Environmental Health/Environmental Health Epidemiologist: (410) 767-5049

MASSACHUSETTS

Department of Agricultural Resources

Commissioner’s Office: (617) 626-1701

Department of Environmental Protection 

Environmental Strike Force: (617) 556-1000 

Department of Public Health

Emergency Preparedness & Response: (617) 624-5270

Emergency Management Agency

Public Information Officer: (508) 820-2002
Guidelines for the Disposal of Intentionally Adulterated Food Products and the Decontamination of Food Processing Facilities

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MICHIGAN

Department of Agriculture

Emergency Line for Agricultural Producers & Food Retailers: (517) 373-0440

Agriculture Pollution/Spills Hot Line: (800) 405-0101

Department of Environmental Quality

24-Hour Pollution Emergency Alert System: (800) 292-4706

Department of Community Health

General Information: (517) 373-3740

MINNESOTA

Department of Agriculture

Minnesota Duty Officer/24 Hour Incident Report Line: (651) 649-5451 (Twin Cities Metro 

Area and Outside MN) or (800) 422-0798 (Greater MN only). 

Environmental Quality Board

Animal Agriculture Helpline: (651) 296-2888

Health Department

Office of Emergency Preparedness: (651) 296–0047

MISSISSIPPI

Department of Agriculture & Commerce

Regulatory Services-Meat Inspection: (601) 359-1191

Emergency Management Agency

24-Hour Emergency Line: (800) 222-MEMA (6362)

Department of Environmental Quality

24-Hour State Warning Point: (601) 352-9100 

Department of Health 

Division of Epidemiology: (601) 576-7725

MISSOURI

Department of Agriculture

Meat & Poultry Inspection Program: (573) 522-1242 or (573) 526-2090

Department of Health and Senior Services 

Center for Local Public Health Services: (573) 751-6170

State Public Health Laboratory: (573) 751-0633

Department of Public Safety

State Emergency Management Agency Director: (573) 526-9101

Planning & Disaster Recovery Branch: (573) 526-9234

Department of Natural Resources

24-Hour Environmental Emergency Response line: (573) 634-2436
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MONTANA

Department of Livestock

General Information: (406) 444-7323

Animal Health Division: (406) 444-2043

Department of Environmental Quality

Director’s Office: (406) 444-2544

Department of Public Health and Human Services 

Public Information Officer: (406) 444-2596

Department of Military Affairs

Disaster & Emergency Services Division: (406) 841-3911

NEBRASKA

Department of Agriculture

Bureau of Animal Industry: (402) 471-2351

Poultry & Egg: (402) 471-4292

Bureau of Dairy & Food: (402) 471-2536

Department of Environmental Quality

Director’s Office: (402) 471-2186

Emergency Management Agency

Emergency Line: (402) 471-7421

Department of Health and Human Services 

Regulations & Licensure-Epidemiology: (402) 471-6450

NEVADA

Department of Agriculture

Division of Animal Industry: (775) 688-1182 ext. 231 

Department of Conservation & Natural Resources

Division of Environmental Protection: (775) 687-4670

Department of Public Safety

Division of Emergency Management: (775) 687- 4240

Department of Human Resources

Health Division-Epidemiology: (775) 684-5946

NEW HAMPSHIRE

Department of Agriculture, Markets & Food

Division of Animal Industry: (603) 271-2404 

Department of Safety

Bureau of Emergency Management: (800) 852-3792 
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Environmental Services Department

To Report a Potential Violation: (603) 271-2973

Health and Human Services Department

Public Health Services: (603) 271-4501 

NEW JERSEY

Department of Agriculture

Division of Animal Health: (609) 292-3965

Department of Environmental Protection

24-Hour Hotline to Report an Environmental Incident: (877) 927-6337

Department of Health and Senior Services 

Consumer & Environmental Health Services: (609) 588-3120

Communicable Disease Service: (609) 588-7539

NEW MEXICO

Department of Agriculture

Standards & Consumer Services Division: (505) 646-1616

Veterinary Diagnostic Services: (505) 841-2576

Department of Environment 

Environmental Protection Division: (800) 219-6157

Department of Health

(505) 827-2613

Department of Public Safety

Office of Emergency Management: (505) 476-9622

NEW YORK

Department of Agriculture & Markets

Division of Food Safety & Inspection: (518) 457-4492

Emergency Management Office

Emergency Coordination Center Staffed 24 Hrs: (518) 457-2200

Department of Environmental Conservation

24-Hour Confidential Environmental Violation Line: (800) 847-7332

Department of Health

Public Health Preparedness & Response to Bioterrorism: (518) 474-2893

NORTH CAROLINA

Department of Agriculture & Consumer Services

Emergency Programs Division Director: (919) 807-4307
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Department of Environment & Natural Resources

Enforcement Division: (919) 733-4984

Division of Environmental Health: (919) 733-2870

Department of Health and Human Services

Epidemiology Section: (919) 733-3421

Department of Crime Control & Public Safety

Emergency Management Switchboard: (919) 733-3867

NORTH DAKOTA

Department of Agriculture

Meat Inspection Director: (701) 328-4762

Division of Emergency Management & State Radio Communication

24-Hour Hotline (800) 472-2121

Department of Health

Environmental Health Section/Report an Incident: (701) 328-5210 or 5166

OHIO

Department of Agriculture

Food Safety & Meat Inspection Issues Hotline: (800) 282-1955

Emergency Management Agency

24-Hour contact: (614) 889-7150

Environmental Protection Agency

24-Hour Hotline to Report Emergencies: (800) 282-9378

Department of Health

Division of Food Safety: (614) 466-1390

OKLAHOMA

Department of Agriculture, Food, & Forestry

Food Safety Director: (405) 522-6113

Oklahoma Department of Civil Emergency Management

Director’s Office: (405) 521-2481

Department of Environmental Quality

For Environmental Complaints: (800) 522-0206 or (405) 271-4468

Department of Health

Health Department Civil Emergency Management: (405) 590-2554

Communicable Disease Division: (405) 271-4060

OREGON

Department of Agriculture

Food Safety Division: (503) 986-4720
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Department of Environmental Quality

Office of Compliance & Enforcement: (503) 229-6585

Emergency Response System: (800) 452-0311

Office of Homeland Security

Emergency Management: (503) 378 2911

Department of Human Services

Office of Disease Prevention and Epidemiology: (800) 422-6012

PENNSYLVANIA

Department of Agriculture

Bureau of Food Safety & Laboratory Services: (717) 787-4315

Department of Environmental Protection

Emergency Response: (800) 541-2050

Citizen Complaint Line: (866) 255-5158

Department of Health

Emergency Information Line (after hours, weekends & holidays): (717) 737-5349

General Information: (877) PA-HEALTH

RHODE ISLAND

Office of the Secretary of State

Emergency Management Agency: (401) 946 -9996

Department of Environmental Management

After Hours Emergencies: (401) 222-3070

For General Information: (401) 222-6800

Division of Agriculture: (401) 222-2781

Department of Health

Division of Environmental Health: (401) 222-3118

SOUTH CAROLINA

Department of Agriculture

Laboratory Services Division: (803) 734-2210

Emergency Management Division

(803) 737-8500

Department of Health & Environmental Control

Office of Public Health Preparedness: (803) 898-3708

SOUTH DAKOTA

Department of Agriculture

Animal Industry Board: (605) 773-3321
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Department of Environment & Natural Resources

Hazardous Waste: (605) 773-3352

Spills: (605) 773-3296

Main Department: (605) 773-3151

Department of Health

Office of Public Health Preparedness & Response 24/7 Disease Surveillance: (800) 592-

1861 (in SD only) or (605) 773-3737

Office of Homeland Security

Bioterrorism Hotline: (800) 592-1861 

TENNESSEE

Department of Agriculture

Ag Crime Unit Supervisor: Office (615) 837-5181, Pager (800) 428-1359,

Cell (615) 351-4815

Department of Environment & Conservation

Environmental Assistance Centers and other Environmental Related Contacts: (888) 891-

TDEC (8332)

Department of Homeland Security

Emergency Management Agency: (800) 262-3300

Regional Information Center: (877) 250-2333

Department of Health

Communicable & Environmental Disease Services: (615) 741-7247 or (800) 404-3006 

After Hours Emergency Consultation Available (615) 741-7247

TEXAS

Department of Agriculture

General Information: (512) 463-7476

Nationwide Toll Free Phone: (800) TELL-TDA (800-835-5832)

Commission on Environmental Quality

Environmental Release Hotline or the Texas Natural Resource Conservation Commission: 

(800) 832-8224 Regional Office, Monday through Friday 8:00 to 5:00

24-Hour Hotline: (512) 239-2507 or (512) 463-7727

Department of Public Safety

Division of Emergency Management: (512) 424-2138 or (512) 424-2000

Department of Health

Bureau of Environmental Health: (512) 834-6640

Toxic Substances Control Division: (512) 834-6600 
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UTAH

Department of Agriculture & Food

Meat and Poultry Inspection Program Manager: (801) 538-7117

Assistant Manager: (801) 538-7163 

Department of Public Safety 

Division of Emergency Services and Homeland Security: (801) 538-3400 or (800) SLFAULT

Department of Environmental Quality

Environmental Response and Remediation24 Hour Emergency Line: (801) 536-4123

Department of Health

Bureau of Food Safety and Environmental Health: (801) 538-6750

VERMONT

Agency of Agriculture, Food & Markets

Director, Food Safety & Consumer Protection- Meat Inspection: (802) 828-2426

Department of Public Safety

Emergency Management Agency: (802) 244-8721 or (800) 347-0488

HazMat Hotline: (800) 641-5005 (24-hour State Police Dispatch)

Department of Environmental Conservation

Waste Management Division: (802) 241-3888

Department of Health

(802) 863-7200 or (800) 464-4343 (from within Vermont)

VIRGINIA

Department of Agriculture & Consumer Resources

Food Safety and Security Program: (804) 786-2035

Department of Emergency Management

24 Hour State Police Domestic Terrorism Hotline: (866) 488-8554

Department of Environmental Quality

Deputy Director for Operations: (804) 698-4484

Department of Health

Emergency Response & Preparedness Programs Deputy Commissioner: (804) 864-7026

WASHINGTON

Department of Agriculture & Consumer Resources

Food & Agriculture Security: (360) 902-1813

Emergency Management Division

24-Hour Emergency Line: (800) 258-5990
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Department of Health

Emergency Preparedness & Response/Consumer Hotline: (800) 525-0127

Division of Environmental Health-Food Safety & Shellfish: (360) 236-3330

Department of Ecology

Spill Prevention, Preparedness & Response (800) 258-5990

WEST VIRGINIA

Department of Agriculture

Meat & Poultry Inspection Division: (304) 558-2206

Department of Environmental Protection

Office of Environmental Remediation: (304) 926-0455

Office of Environmental Health Service

(304) 558-2981

Office of Emergency Services

(304) 558-5380

WISCONSIN

Department of Agriculture, Trade & Consumer Protection

Food Emergencies during Business Hours (7:45 a.m. - 4:30 p.m., Monday - Friday): 

Madison (608) 224-4700

Southern region (608) 224-4661

Eau Claire (715) 839-3844

Green Bay (920) 448-5120

Non Business Hours: (800) 943-0003 Wisconsin Emergency Management. Ask the duty 

officer to contact DATCP- Division of Food Safety

Emergency Management

24-Hour Duty Officer: (800) 943-0003

Department of Natural Resources

24-Hour Environmental Clean Up Line: (800) 943-0003

WYOMING

Department of Agriculture

Consumer Health Services: (307) 777-7321

Department of Environmental Quality

24-Hour Emergency Call Line: (307) 777-7781

Department of Health

All Hazards Response Program on Call Surveillance: (888) 996-9104
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ENVIRONMENTAL PROTECTION AGENCY (EPA) REGIONAL OFFICES

EPA Region 1 (covering Connecticut, Massachusetts, Maine, New Hampshire, Rhode 

Island, and Vermont)

1 Congress Street

Suite 1100

Boston, MA 02114-2023

(617) 918-1111 or (800) 372-7431 within Region 1

EPA Region 1 RCRA Enforcement Contacts:

Enforcement Manager: (617) 918-1751

Connecticut Liaison: (617)918-1882

Massachusetts Liaison: (617) 918-1757

Maine, Rhode Island, and Vermont Liaison: (617) 918-1756

New Hampshire Liaison: (617) 918-1756

Solid Waste Reduction/Recycling: (617) 918-1813/1792 

EPA Region 2 (covering New Jersey, New York, Puerto Rico, and the Virgin Islands)

290 Broadway

26th Floor

New York, NY 10007-1866

(212) 637-3000

RCRA Compliance Branch: (212) 637-4145

Hazardous Waste Compliance Section: (212) 637-4140

Special Wastes Team: (212) 637-4135

EPA Region 3 (covering Washington, DC, Delaware, Maryland, Pennsylvania, Virginia, 

and West Virginia)

1650 Arch Street

Philadelphia, PA 19103-2029

(215) 814-5000 or (800) 438-2474 in Region 3

Waste and Chemicals Management Division: (215) 814-3110

Municipal Solid Waste: (215) 814-3298

Toxic Waste – Land: (215) 814-3396/3388

EPA Region 4 (covering Alabama, Florida, Georgia, Kentucky, Mississippi, North 

Carolina, South Carolina, and Tennessee)

Atlanta Federal Center

61 Forsyth Street, SW

Atlanta, GA 30303-3104

(404) 562-9900 or (800) 241-1754 in Region 4

Managing Solid Wastes: (404) 562-8688/ 8457/ 8482
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RCRA Compliance State-by-state Coordinators

Alabama: (404) 562-8601

Florida (404) 562-8597

Georgia (404) 562-8594

Kentucky (404) 562-8590

Mississippi (404) 562-8617

North Carolina (404) 562-8605

South Carolina (404) 562-8589

Tennessee (404) 562-8556

EPA Region 5 (covering Illinois, Indiana, Michigan, Minnesota, Ohio, and Wisconsin)

77 West Jackson Boulevard

Chicago, IL 60604

(312) 353-2000 or (800) 621-8431 in Region 5

Pollution Prevention and Program Initiatives Section: (312) 886-0976

EPA Region 6 (covering Arkansas, Louisiana, New Mexico, Oklahoma, and Texas)

1445 Ross Avenue

Suite 1200

Dallas, TX 75202-2733

(214) 665-2200 or (800) 887-6063 in Region 6

Emergency & Hot Line Phone Numbers

National Response Center: (800) 424-8802

Superfund Hot Line: (800) 533-3508

Environmental Emergencies: (866) 372-7745

EPA Region 7 (covering Iowa, Kansas, Missouri, and Nebraska)

901 North 5th Street

Kansas City, KS 66101

(913) 551-7000 or (800) 223-0425 in Region 7

EPA Emergency Response: (913)281-0991

Office of External Programs: (913) 551-7003 or (800)-223-0425

EPA Region 8 (covering Colorado, Montana, North Dakota, South Dakota, Wyoming, and 

Utah)

One Denver Place

999 18th Street

Suite 500

Denver, CO 80202-2466

(303) 312-6312 or (800) 227-8917 in Region 8

Solid and Hazardous Waste Program: (303) 312-7081 or

1-800-227-8917 ext. 7081 

Tribal Solid and Hazardous Waste Coordinator: (303) 312-6149/7008
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EPA Region 9 (covering American Samoa, Arizona, California, Guam, Hawaii, Nevada the 

Northern Mariana Islands, and unincorporated U.S. Pacific possessions)

75 Hawthorne Street

San Francisco, CA 94105

(415) 744-1305 

Environmental Emergencies: (415) 947-4400

EPA Region 10 (covering Alaska, Idaho, Oregon, and Washington)

1200 Sixth Avenue

Seattle, WA 98101

(206) 553-1200 or

(800) 424-4372 in Region 10

Solid Waste & Toxics Unit: (206) 553-1060

Below is the link for EPA’s regional and state Solid Waste offices websites.

http://www.epa.gov/epaoswer/osw/regions.htm
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NUCLEAR REGULATORY COMMISSION (NRC) REGIONAL PUBLIC 

AFFAIRS OFFICES

Region I

475 Allendale Road

King of Prussia, PA 19406-1415

(610) 337-5330

Region II

61 Forsyth Street

Suite 23 T85

Atlanta, GA 30303-3415

(404) 562-4416

Region III

801 Warrenville Road

Lisle, IL 60532-4351

(630) 829-9663

Region IV

611 Ryan Plaza Drive

Suite 400

Arlington, TX 76011-8064 

(817) 860-8128
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FEDERAL BUREAU OF INVESTIGATION (FBI) FIELD OFFICES 

BY STATE

ALABAMA

Mobile Division 

200 North Royal Street

Mobile, AL 36602

Phone: (251) 438-3674

Fax: (251) 415-3235 

Birmingham Division 

2121 8th Avenue North, Suite 1400 

Birmingham, AL 35203

Phone: (205)326-6166

ALASKA

Anchorage Division 

101 E. 6th Ave.

Anchorage, AK, 99501

(907) 276-4441

ARIZONA

Phoenix Division

201 E. Indianola

Phoenix, AZ 85012

(602) 279-5511

ARKANSAS

Little Rock Field Office

24 Shackleford West Blvd.

Little Rock, AR 72211

(501) 221-9100

CALIFORNIA

Los Angeles Field Office

11000 Wilshire Blvd. Suite 1700

Los Angeles, CA 90024

(310) 477-6565

Sacramento Field Office

4500 Orange Grove

Sacramento, CA 95841

(916) 481-9110
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San Diego Division

9797 Aero Dr.

San Diego, CA 92123

(858)-565-1255

San Francisco Division 

450 Golden Gate Avenue

13th Floor

San Francisco, CA 94102

(415) 553-7400

COLORADO

Denver Division

Byron G. Rogers Federal Building

1961 Stout Street, Suite1823

Denver, CO 80294

(303) 629-7171

CONNECTICUT

New Haven Division

600 State Street

New Haven, CT 06511

(203) 777-6311

DELAWARE (all counties are covered by the FBI field office in Baltimore)

Baltimore Field Office

2600 Lord Baltimore Drive

Baltimore, MD 21244

(410) 265-8080

DISTRICT OF COLUMBIA 

Washington Field Office

601 4th Street NW

Washington DC 20535

(202) 278-2000

FLORIDA

Jacksonville Division

7820 Arlington Expressway, Suite 200

Jacksonville, FL 32211

(904) 721-1211

Miami Division

16320 Northwest 2nd Avenue

North Miami Beach, FL 33169

(305) 944-9101
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Tampa Division

500 Zack Street, Suite 610

Tampa, FL 33602

(813) 273-4566

GEORGIA

Atlanta Division

2635 Century Center Parkway, NE, Suite 400

Atlanta, GA 30345

(404) 679-9000

HAWAII

Honolulu Division

300 Ala Moana Boulevard, Suite 4-230

Prince Jonah Kuhio Federal Building

Honolulu, HI 96813

(808) 566-4300

IDAHO (all counties are covered by the FBI field office in Salt Lake)

Salt Lake City Division

257 East 200 South, Suite 1200

Salt Lake City, UT 84111 

(801) 579-1400

ILLINOIS

Chicago Division

219 South Dearborn Street, Suite 905

Chicago, IL 60604

(312) 431-1333

Springfield Illinois Division

400 West Monroe Street, Suite 400

Springfield, IL 62704

(217) 522-9675

INDIANA

Indianapolis Division

575 North Pennsylvania Street, Room 679

Indianapolis, IN 46204

(317) 639-3301

IOWA (all counties are covered by the FBI field office in Omaha)

Omaha Division

10755 Burt Street

Omaha, NE 68114-2000

(402) 493-8688
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KANSAS (all counties are covered by the FBI field office in Kansas City, MO)

Kansas City Division

1300 Summit

Kansas City, MO 64105

(816) 512-8200

KENTUCKY

Louisville Field Office

600 Martin Luther King Jr. Place, Room 500 

Louisville, KY 40202 

(502) 583-3941

LOUISIANA

New Orleans Division

2901 Leon C. Simon Blvd.

New Orleans, LA 70126

(504) 816-3000

MAINE (all counties are covered by the FBI field office in Boston)

Boston Field Office

One Center Plaza, Suite 600

Boston, MA 02108

(617) 742-5533

MARYLAND

Baltimore Field Office

2600 Lord Baltimore Drive

Baltimore, MD 21244

(410) 265-8080

MASSACHUSETTS

Boston Field Office

One Center Plaza, Suite 600

Boston, MA 02108

(617) 742-5533

MICHIGAN

Detroit Field Office

477 Michigan Avenue, Fl. 26

Detroit, MI 48226

(313) 965-2323
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MINNESOTA

Minneapolis Division

Federal Bureau of Investigation

111 Washington Avenue South, Suite 1100

Minneapolis, MN 55401

(612) 376-3200

MISSISSIPPI

Jackson Division

100 W. Capitol Street, Suite 1553 

Jackson, MI 39269 

(601) 948-5000

MISSOURI

Kansas City Division

1300 Summit

Kansas City, MO 64105

(816) 512-8200

St. Louis Division

2222 Market Street

St. Louis, MO 63103

(314) 589-2500

MONTANA (all counties are covered by the FBI field office in Salt Lake)

Salt Lake City Division

257 East 200 South, Suite 1200

Salt Lake City, UT 84111 

(801) 579-1400

NEBRASKA

Omaha Division

10755 Burt Street

Omaha, NE 68114-2000

(402) 493-8688

NEVADA

Las Vegas Division

700 East Charleston Boulevard

Las Vegas, NV 89104

(702) 385-1281
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NEW HAMPSHIRE (all counties are covered by the FBI field office in Boston)

Boston Field Office

One Center Plaza, Suite 600

Boston, MA 02108

(617) 742-5533

NEW JERSEY

Newark Division

11 Centre Place

Newark, NJ 07102

(973) 792-3000

The Newark Division covers all counties in New Jersey with the exception of Camden, 

Gloucester and Salem. These counties are covered by the Philadelphia Division.

Philadelphia Division

8th Floor 

600 Arch Street 

Philadelphia, PA 19106 

(215) 418-4000

NEW MEXICO

Albuquerque Division

4200 Luecking Park Avenue NE

Albuquerque, NM 87107

(505) 889-1300

NEW YORK

Albany Division

200 McCarty Avenue

Albany, NY 12209

(518) 465-7551

Buffalo Field Office 

One FBI Plaza

Buffalo, NY 14202

(716) 856-7800

New York Field Office

26 Federal Plaza

New York, NY 10278

(212) 384-1000
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NORTH CAROLINA

Charlotte Field Office

400 South Tryon Street

Suite 900

Charlotte, NC 28285

(704) 377-9200

NORTH DAKOTA (all counties are covered by the FBI field office Minneapolis)

Minneapolis Division

Federal Bureau of Investigation

111 Washington Avenue South, Suite 1100

Minneapolis, MN 55401

(612) 376-3200

OHIO

Cincinnati Division

John Weld Peck Federal Building

550 Main Street 

Suite 9000

Cincinnati, OH 45202

(513) 421-4310

Cleveland Division

1501 Lakeside Avenue

Cleveland, OH 44114

(216) 522-1400

OKLAHOMA

Oklahoma City Division

3301 W. Memorial Rd.

Oklahoma City, OK 73134

(405) 290-7770

OREGON

Portland Division

1500 S.W. First Avenue

Suite 400

Portland, OR 97201

(503) 224-4181

PENNSYLVANIA

Philadelphia Division

8th Floor

600 Arch Street 

Philadelphia, PA 19106

(215) 418-4000
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Pittsburgh Division

3311 East Carson Street

Pittsburgh, PA 15203

(412) 432-4000

RHODE ISLAND (all counties are covered by the FBI field office in Boston)

Boston Field Office

One Center Plaza, Suite 600

Boston, MA 02108

(617) 742-5533

SOUTH CAROLINA

Columbia Division

151 Westpark Boulevard

Columbia, SC 29210

(803) 551-4200

SOUTH DAKOTA (all counties are covered by the FBI field office Minneapolis)

Minneapolis Division

Federal Bureau of Investigation

111 Washington Avenue South, Suite 1100

Minneapolis, MN 55401

(612) 376-3200

TENNESSEE

Knoxville Field Office

710 Locust Street, Suite 600 

Knoxville, TN 37902

(865) 544-0751

Memphis Field Office

225 N. Humphreys Boulevard, Suite 3000 

Memphis, TN 38120 

(901) 747-4300

TEXAS

Dallas Field Office

One Justice Way

Dallas, TX 75220

(972) 559-5000

Houston Field Office

2500 East T.C. Jester

Houston, TX 77008

(713) 693-5000
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El Paso Field Office

660 South Mesa Hills Drive, Suite 3000

El Paso, TX 79912

(915) 832-5000

San Antonio Field Office

615 East Houston Room 200

San Antonio, TX 78205

(210) 225-6741

UTAH

Salt Lake City Division

257 East 200 South, Suite 1200

Salt Lake City, UT 84111 

(801) 579-1400

VERMONT (all counties are covered by the FBI field office in Albany)

Albany Division

200 McCarty Avenue

Albany, NY 12209

(518) 465-7551

VIRGINIA

Richmond Division

1970 E. Parham Road

Richmond, VA 23228 

(804) 261-1044

Norfolk Division

150 Corporate Blvd.

Norfolk, VA 23502

(757) 455-0100

WASHINGTON

Seattle Division

1110 Third Avenue

Seattle, WA 98101-2904

(206) 622-0460

WEST VIRGINIA (all counties are covered by the FBI field office in Pittsburgh)

Pittsburgh Division

3311 East Carson Street

Pittsburgh, PA 15203

(412) 432-4000
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WISCONSIN

Milwaukee Field Office

330 E. Kilbourn Ave. Suite 600

Milwaukee, WI 53202

(414) 276-4684

WYOMING (all counties except Yellowstone National Park are covered by the FBI field 

office in Denver)

Denver Division

Byron G. Rogers Federal Building

1961 Stout Street, Suite1823

Denver, CO 80294

(303) 629-7171

For Yellowstone National Park use the Salt Lake Division

Salt Lake City Division

257 East 200 South, Suite 1200

Salt Lake City, UT 84111 

(801) 579-1400
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APPENDIX E – WORKING GROUP MEMBERS

Food Safety and Inspection Service

Carol Maczka 

Perfecto Santiago 

Judy Riggins

Nathaniel Clark

Richard Van Blargan

Michelle Catlin

Environmental Protection Agency

Laura Flynn

David Bartenfelder

Paul Cassidy

Thea McManus

Carlton (Jeff) Kempter

Cayce Parrish

Rosemary Workman

Linda Strauss

Consultants

Lou Borghi

Phuoc Le

Curtis Travis

Dorothy Yuan

Anne Roberts

Also Interviewed

Zygmunt Sala (FSIS)

Food and Drug Administration

John J. Guzewich

Donald Kautter Jr.

LeeAnne Jackson