Food Defense for Small Plants
Food defense is the latest new concept on the regulatory horizon. Food defense differs from food safety, in the food defense procedures protect your products from intentional contamination, while food safety procedures protect your products from unintentional contamination. Large meat processors have dealt with food defense issues for a number of years, to prevent consumers or disgruntled employees from tampering with their products. The more recent concern is with terrorist attempts to cause a public panic by contaminating food products.
Some people believe that our food supply will be the target of the next terrorist activity in the U.S. Whereas most people would assume that terrorists would target food products made in larger companies, to have a greater impact, there is also the viewpoint that terrorists will target the weakest options that they have available to them. Since larger companies would be more difficult to infiltrate, smaller food companies could be targets for future terrorist activity.
According to USDA FSIS Directive 5420.1, Revision 2 (7/20/05), when the Threat Condition level is raised to Yellow, Orange or Red, by the Office of Homeland Security, USDA FSIS inspectors will follow Food Security Verification Procedures, upon the direction of the District Office. Under the circumstances of heightened alert level, if the FSIS inspector notes a breach in security in an establishment (with no evidence of contaminated product), the inspector will prepare an MOI (memorandum of incidence) and meet with establishment. The establishment is not obligated to respond to the breaches identified in the MOI. However, if the inspector finds a breach in security and evidence of contaminated product exists, the inspector will not only notify the establishment, but will also do an 02 HACCP procedure and document his/her findings in an NR.
If the inspector determines that the product adulteration is not a food safety risk, then the inspector is to verify that the establishment takes corrective actions.
Companies are first encouraged to conduct a self-assessment of their operations. USDA FSIS has prepared a checklist to assist in this process, which you can access at:
www.fsis.usda.gov/PDF/Food_Security_Checklist_Worksheet.pdf Please call me for a copy of this check list, if you do not have Internet access. This assessment would be the basis of your Food Security Plan, as “No” responses on the checklist would indicate points of vulnerability in the security of your establishment.
In developing a Food Security Plan, FSIS identifies the following elements of a plan, in which the establishment identifies potential problems and solutions:
Inside Security – employees, contractors (sanitation, maintenance, construction, etc.), unescorted visitors, water supply, etc.
Storage Security – spices, non-meat ingredients, cleaners, sanitizers, etc.
Outside Security – plant entrances, windows, vents, docks, etc.), outside storage tanks, trailers for refrigerated or dry storage, etc.
Receiving and Shipping Security – unscheduled deliveries/unknown carriers or suppliers, unsecured trucks/trailers.
Operations (Slaughter, Processing, etc.) Security – access to large mixers, combo bins, grinder hoppers, brine mixing tanks, scalding tanks, chill tanks, carcass rinses, etc.
By Lynn Knipe, Ohio State University
A Food Security Plan worksheet is also available online at:
Once the plan has been developed, responsibilities for carrying out plan need to be defined and assigned, employees would need to be properly trained regarding their responsibilities, effectiveness of the plan tested/verified, a contact list developed and, a recall program established, if one doesn’t already exist.
A model Food Security Plan for meat processing can be accessed at: www.fsis.usda.gov/PDF/Model_FoodSec_Plan_Processing.pdf
The FSIS verification procedures, in the event of heightened Threat Condition Level, are outlined in USDA FSIS Directive 5420.1, Revision 2. This directive can be accessed at: www.fsis.usda.gov/regulations_&_policies/5000_Series-Program_Services/index.asp
The following points were taken from Directive 5420.1, Revision 2, to summarize the Food Security Verification Procedures, that your FSIS inspectors may be following, in the event that the Threat Condition level is raised to Yellow, Orange or Red.
Outer Premises: Verify that all plant entrances are “secured against unauthorized entrance,” which would include truck entrances, parking areas, trucks used for onsite dry or cold storage of processing ingredients. Window, roof and vent openings need to be checked to ensure that they are “properly secured, to the extent possible.” This could include: metal exterior doors, locks, accounting for door keys, jimmy plates, seals, alarms, intruder detection sensors, video cameras, adequate internal and external lighting,
Control and Use of Hazardous Chemicals
Verify that entry to hazardous chemical “storage areas is controlled, and that useage logs are maintained and current,” particularly for cleaning materials, laboratory reagents, and bacterial cultures.
Live Animals (Slaughter Establishments Only)
Verify that animals received do not have “symptoms of diseases that may indicate the introduction of a biological agent (e.g., foot and mouth disease) into the livestock population.”
Verify the proper equipment calibration.
Verify that there are no unattended deliveries on the loading docks and no unmarked vehicles in the parking lots, truck drivers have “no unsupervised access to product receiving and storage areas.”
Incoming Raw Materials
Verify that raw material “deliveries are checked against shipping documents,” to ensure that the “bills of lading are accurate, timely, on file (if documents received prior to the shipment, and match the incoming materials.”
Verify that maintenance, construction and repair personnel are “properly identified and authorized to perform such activities,” and “denied access to sensitive processing operations where bulk products will be mixed (e.g., grinding, emulsification, dry and cold storage areas,” etc.).
Verify that there is no evidence of tampering in cold and dry storage areas, including checks for package integrity of meat, spices, curing ingredients, etc.
Verify that the security of wells, municipal and internal water supply lines and all storage tanks, such as brine mixing tanks, ice makers, etc., is maintained.
Verify that no tampering has occurred during processing (e.g., mixing, chopping) and storage and handling of raw materials.
Verify that only employees that are in an area, particularly sensitive areas (e.g., mixing, chopping), that work in that area, through use of color-coded uniforms, picture IDs, etc.
The FSIS website for the materials presented at the Food Security Workshops is: www.fsis.usda.gov/Food_Security_&_Emergency_Preparedness/Workshop_Food_Security/index.asp