With the 2011 passage of the Food Safety Modernization Act, considerable attention has been focused on the purity of our foods from the perspective of accidental contamination. Additionally, the possibility of deliberate tampering from criminal or terrorist sources should be acknowledged.
Businesses or plants that do not have access to specialized security-planning advice should find these guidelines particularly useful as they develop and improve their food security plans.
Due to space constraints, these suggestions are simplified. An in-depth discussion and plan of action should be a priority as your business implements a food security plan.
Food Security Plan Management
- Assign a food security management team and a food security management coordinator.
- Develop and implement a food security plan. The plan should address threats, product tampering and an evacuation plan for each facility.
- Corrective action taken in all cases
of product tampering should ensure that adulterated or potentially injurious products do not enter commerce.
- The plan should include the immediate recall and handling of adulterated products from trade and consumer channels.
- A relationship should be established with appropriate analytical laboratories.
- Procedures for notifying appropriate law enforcement and public health of officials should be detailed in the plan.
- Specially designated entry points for emergency personnel should be identified in the plan.
- Current local, State and Federal of officials should be listed in the plan. This list should be updated regularly.
- Members of the food security management team should be trained in all provisions of the plan.
- Food security inspections of the facility should be conducted regularly.
- Employees should be encouraged to report any sign of possible product tampering or break in the food security system.
- All threats and incidents of intentional product tampering should be immediately investigated and reported.
- Liaison with local Homeland Security and other law enforcement of officials should be pre-established.
- Plantboundariesshouldbesecuredtopreventunauthorizedentry.“NoTrespassing” signs should be posted.
- Integrity of the plant perimeter should be monitored for signs of suspicious activity or unauthorized entry.
- Outside lighting should be sufficient to allow detection of unusual activities.
- All access points into the establishment should be secured by guards, alarms, cameras or other security hardware.
- Emergency exits should be alarmed and have self-locking doors that can be opened only from the inside.
- Doors, windows, roof openings, vent openings, trailer bodies, railcars and bulk storage tanks should be secured at all times.
- Outside storage tanks for hazardous materials and potable water supply should be protected from, and monitored for, unauthorized access.
- An updated list of plant personnel with open or restricted access to the establishment should be maintained at the security office.
- Entry into establishments should be controlled by requiring positive identification.
- Incoming and outgoing vehicles should be inspected for unusual cargo or activity.
- Parking areas for visitors or guests should be situated at a safe distance from the main facility. Vehicles of visitors, and employees should be marked (placards, decals, etc.).
- Scheduled truck deliveries should be verified against a roster. Hold unscheduled deliveries outside the plant premises, pending verification of shipper and cargo.
- Restricted areas inside the plant should be clearly marked and secured.
- Access to central controls for air flow, water systems, electricity and gas should be restricted and controlled.
- Updated plant layout schematics should be available at strategic locations in the plant.
- Air ow systems should include a provision for immediate isolation of contaminated areas or rooms.
- Emergency alert systems should be regularly tested, and locations of controls should be clearly marked.
- Access to in-plant laboratory facilities should be strictly controlled. Security and disposal procedures should be in place, particularly for the control of reagents, hazardous materials and live cultures of pathogenic bacteria.
- Visitors, guests and other non-plant employees should be restricted to non-product areas unless accompanied by an authorized plant representative.
- Computer data systems should be protected using passwords, firewalls and current virus detection systems.
Shipping and Receiving Security
- All outgoing shipments should be sealed with tamper-proof, numbered seals that are included on the shipping documents.
- Incoming shipments should be sealed with tamper-proof, numbered seals, and the seal numbers be shown on the shipping documents for verification prior to entry to the plant.
- Shipping documents with suspicious alterations should be thoroughly investigated.
- All trailers on the premises should be locked and sealed when not being loaded or unloaded.
- A policy for off-hour deliveries should be established. An authorized individual should be present to verify and receive the shipment.
- Incoming shipments should be examined at the receiving dock for evidence of tampering.
- Advance notification required from suppliers for incoming deliveries. Notification should include pertinent details about the shipment, including the name of the driver.
- The FSIS Inspector-in-Charge should be notified immediately when animals with unusual behavior and symptoms are received at the plant.
- Loading docks should be secured to avoid unverified or unauthorized deliveries.
- The integrity of food security measures should be a priority in the selection of suppliers of meat and non- meat ingredients, compressed gas, packaging materials and labels.
Water and Ice Supply Security
- Outside access to wells, potable water tanks and ice-making equipment should be secured.
- Potable and non-potable water lines in food processing areas should be inspected periodically for possible tampering.
- The plant should arrange forimmediate notification in the event the potability of the public water supply is compromised.
Mail Handling Security
- Mail handling should be done in a separate room or facility, away from in-plant food production/processing operations,.
- Mail handlers should be trained to recognize suspicious pieces of mail using U.S. Post Office guidelines.
- A system of positive identification/recognition of plant employees should be in place.
- Procedures should be established for controlled entry of employees into the plant.
- Seasonal, temporary, permanent, and contract workers should be subjected to background checks before hiring.
- Orientation training on security procedures should be given to all plant employees.
- The plant should establish and enforce a policy on what personal items may and may not be allowed inside the plant and within production areas.