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Food Defense Plan
Food Defense Plan
Food Defense Plan
INTRODUCTION
All food processing facilities need to address food defense. The first step is to develop
a functional food defense plan that assesses the existing security measures and risk
reduction programs already in place to reduce the likelihood that a terrorist could
adulterate or contaminate the finished product through contamination of raw materials,
in-process formulations or finished products at the end of the production process.
Although it may not appear that a small or very small establishment would be a target
for a terrorist activity, all establishments need to go through the exercise of assessing
where they may be vulnerable to terrorist activity and how they might reduce any risk
that exist. In the development of the food defense plan, the establishment will look at
where the vulnerabilities may arise. These may be from the outside through the
incoming raw materials, through unauthorized entry or through the water supply, or they
may be through internal means such as employees that have access to raw materials
and ingredients, in-process formulations or even finished products.
Forming a food defense team is a good place to start. Depending on the size and
structure of an establishment’s organization, team members may come from areas such
as management, security, quality assurance, human resources, maintenance,
engineering and even the FSIS inspectors.
After the establishment identifies potential vulnerabilities, it will then examine possible
risk-reduction methods such as the use of physical security or hardware (e.g., closed
circuit TV, alarms, doors, guards, access control systems), personnel security (e.g.,
background checks, colored hats, screening, training, awareness) or procedural security
(e.g., key control, having two persons present when raw materials are accessed,
testing).
Once the key vulnerabilities are addressed with risk-reduction methods, the
establishment needs to ensure that the risk-reduction techniques are being used (e.g.,
doors are kept locked, visitors are not allowed into the plant without an escort). This
verification should be documented, as well as periodic challenges to the system, and
reviews of the plan. Templates for these activities are included in the following plan
development model.
FOOD DEFENSE PLAN
Establishment # __________________
Do you have a select supplier program in place? A select supplier program includes
such criteria as sampling and testing by a long-term (one year) supplier, auditing to
verify their use of critical control points appropriately, documentation that indicates that
the supplier has a food defense plan, signed specification agreements, crisis
management programs, and stock recovery plans.
No: _____
Yes _____
If yes, approximate % raw material supply covered by select supplier program ____
(1)
List your raw materials & ingredients, including water. It may be helpful to begin with major raw
materials and ingredients and work toward minor ones; however, note that sometimes minor raw
materials or ingredients can impact a large volume of finished products (this is important to understand in
developing food defense and is captured in column 3)
(2)
Package type should define how the raw material or ingredient is received, e.g., 2,000-pound combo
bin, 40-pound frozen block, 50-pound paper sack, 25-pound plastic pail, 5,000-pound bulk liquid
(3)
Estimate the number of pounds of finished product that could contain the raw material or ingredient,
using one package, e.g., 10,000 pounds raw ground beef from 2,000-pound combo, 500 pounds cooked
meat balls from 40-pound frozen block, 25,000 pounds of cooked chicken from 50-pound sack of corn
flour
(4)
Capture the QA checks done on the raw material and ingredients here, e.g., visual check for package
integrity, temperature reading, visual check for extraneous material
ADDITIONAL BACKGROUND INFORMATION ON ESTABLISHMENT
(1)
List your chemicals being as specific as possible.
(2)
Package type should define how the chemical is received, e.g., 5,000-gallon bulk liquid, 55-gallon
drum; 40-pound liquid pail, 40-pound powder in plastic bag
(3)
Provide details on product storage, e.g., locked in cage, unlocked in storage room, locked in bulk-
storage tank
Internal _____ External (contracted) _____ Both internal & external _____
If you use an external company for cleaning & sanitation, how many years have you
used this service? ___________ How many persons on the crew? ________
Question Yes No
Do employees undergo background checks?
Do employees have identification badges for entry?
Are non-employees always escorted in the establishment?
Are truck drivers kept out of food storage & preparation areas?
Are barriers (locked doors, fences) in place to prevent unauthorized entry
into the grounds, building and operations areas?
Are limited-access areas secured?
ADDITIONAL BACKGROUND INFORMATION ON ESTABLISHMENT
(1)
Indicate whether or not your establishment has the processing step in any of your manufacturing
processes. Add additional steps as needed.
(2)
Capture the QA checks done at the specific processing step, if any, e.g., temperature reading, fat
analysis, visual check for extraneous material; if no QA check is done, check column 4
ANALYSIS OF BACKGROUND DATA FOR FOOD DEFENSE PLAN
What are those areas or procedures in your facility and operation that you believe are
more vulnerable to possible attack by a terrorist (i.e., critical nodes)?
Now that you have identified some areas outside or inside your establishment, or
procedures used in daily operations that are more vulnerable than others, you can think
of ways to reduce the risk at that area or processing step. In order to do that, copy
those critical nodes identified above into column 2 below and complete the table. You
may not have vulnerabilities in all areas listed in the table (add additional rows if
needed).
Non-employees
Raw materials
Ingredients
Processing
Chemicals &
Sanitation
Other
(1)
There currently is no list of countermeasures you may use; although industry task forces have
addressed common vulnerabilities; and these may be obtained through trade associations for the meat
and poultry industries. It is recommended that a team from the establishment evaluate the vulnerabilities
identified and think of the best way in their operation to reduce the risk. This is important because each
operation can be unique in terms of its physical design, number and types of employees, hours of
operation, raw materials and ingredients used in the operation, et cetera.
FUNCTIONAL FOOD DEFENSE PLAN
The Food Safety and Inspection Service has an expectation that each federally-
inspected meat and poultry establishment will have a functional food defense plan.
What you have just completed is a simplified vulnerability assessment and the
beginning of work to implement countermeasures against those vulnerabilities where
such a mitigation strategy is possible.
Written: You are nearly complete as you answer the following questions and place this
completed document in a folder, electronic file or notebook entitled Food Defense Plan.
_____ check here once the plan is written and filed
Implemented: This means you are doing those written procedures in your plan that help
reduce the risk or vulnerability (e.g., checking name badges, wearing color-coded hats).
_____ check here if an Implementation Monitoring Schedule exists
(see following pages for example Implementation Monitoring Schedule)
Tested: Testing your plan means that someone challenges (e.g., by moving around the
plant without clearance) a component of the written plan to determine whether an
employee challenges the activity based on their training and understanding of food
defense.
_____ check here if an Test Schedule exists
(see following pages for example Test Schedule)
Maintained: You need to review the plan at some frequency (e.g., quarterly) to ensure it
covers the establishment’s activities, signing off on the review to demonstrate the
maintenance schedule for the plan.
_____ check here if a Maintenance Schedule exists
(see following pages for example Maintenance Schedule
FOOD DEFENSE PLAN - IMPLEMENTATION MONITORING SCHEDULE
(1)
Write in the activity that is observed, e.g., badge checking, personnel only in designated area, outdoor
door secured
(2)
Acceptable = activity was occurring according to the written plan; Needs Improvement = activity was
not occurring according to the written plan – in this case, an action plan should be included to improve the
risk-reduction activity (see below)
(1)
Write in the planned activity to strengthen the risk-reduction activity that was observed to need
improvement
FOOD DEFENSE PLAN – TEST/CHALLENGE SCHEDULE
(1)
Write in the procedure or method that is challenged, e.g., outside door, personnel in designated area
only, secured ingredients or chemicals
(2)
Acceptable = risk-reduction procedure or method that was physically challenged; Needs Improvement
= procedure was not occurring as it should – in this case, an action plan should be included to improve
the risk-reduction procedure or method (see below)
(1)
Write in the planned activity to strengthen the risk-reduction activity that was challenged and found to
need improvement
FOOD DEFENSE PLAN - MAINTENANCE SCHEDULE
(1)
Write in the reason for the review, e.g., quarterly scheduled review, new product lines changing risk
profile, FSIS recommendations following audit
It also is a good idea to identify resources (contact name and phone numbers) that
would be contacted in the event that a terrorist activity does occur. Having these
resources identified in advance will decrease the reaction time.