Charles H. Bronson, Commissioner    -    Dr. Marion Aller, Director

FOOD SECURITY GUIDE

For the Public, Producers, Processors,

 Transporters, and Retailers

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General Information

Historically, the records of mankind are filled with episodes of bioterrorism, with terrorists attempting to demoralize the general population through attacks on the food supply.  The modern bioterrorist seeks to promote fear, not necessarily casualties.   As a nation dependent upon a centralized food production system, any disruption could have dire consequences. The food supply is certainly vulnerable, but taking proactive measures can strengthen the security of both the food supply and delivery system.

This guide is designed as an aide to operators of food establishments (i.e., firms that produce, process, store, repack, relabel, distribute, or transport food or food ingredients or that prepare or distribute food at retail.)  It identifies preventive measures that can be taken to minimize the risk to which food might be subject.  Operators are encouraged to review their current procedures and controls in light of the potential for tampering or criminal or terrorist actions, and make appropriate improvements.  This guide is designed to focus on each segment of the farm-to-table system within the operator's control.  Implementing enhanced preventive measures requires the commitment of both management and employees to be successful.


Management of Food Security


Security Procedures

  • Assign responsibility for security to qualified individuals.
  • Encourage all staff to be alert to any signs of tampering with product or equipment, other unusual situations or areas that may be vulnerable to tampering, and to alert identified management about any findings.

Investigation of Suspicious Activity

  • Immediately investigate all information about suspicious activity
  • Alert local law enforcement about all suspected criminal activity
  • Alert Agricultural Law Enforcement at  1-800- 342-5869

Supervision

  • Provide an appropriate level of supervision to all employees, including cleaning and maintenance workers, contract workers, data entry and computer staff, and especially new employees.
  • Conduct daily security checks of the premises for signs of tampering with product or equipment, and other unusual situations.

Physical Facility


Visitors

  • Inspect incoming and outgoing vehicles for suspicious, inappropriate or unusual items or activity.
  • Limit or restrict entry to establishment
  • Ensure that there is a valid reason for the visit before providing access to the facility - beware of unsolicited visitors
  • Restrict access to food handing and storage areas
  • Restrict access to locker rooms
  • Apply the above procedures to everyone, including contractors, supplier representatives, truck drivers, customers, couriers, third-party auditors, regulators, reporters, visitors, etc.

Physical Security

  • Protect perimeter access with fencing or other appropriate deterrent
  • Minimize the number of entrances to restricted areas (remember to consult any relevant federal, state, or local fire safety codes before making any changes)
  • Account for all keys to establishment
  • Use security patrols and video surveillance, where appropriate
  • Provide adequate interior and exterior lighting, including emergency lighting
  • Minimize places that could be used to temporarily hide intentional contaminants

Employees


Pre-hiring Screening

  • Screen employees
  • Check immigration status when appropriate
  • Perform criminal background checks
  • Apply these procedures to all employees to the extent possible, including seasonal, temporary, contract, and volunteer employees

Daily Work Assignments

  • Know who is and who should be on premises, and where they are located
  • Be specific to shift
  • Keep information updated

Restricted Access

  • Limit access so employees enter only those areas necessary for their job function
  • Change combinations and/or collect the retired key card when an employee is terminated
  • Reassess levels of access for all employees periodically

Personal Items

  • Restrict personal items allowed in establishment
  • Prevent workers from bringing personal items into food handling areas

Training in Food Security Procedures

  • Provide food security training to all new employees, including information on how to prevent, detect, and respond to tampering, and criminal or terrorist activity
  • Provide periodic reminders of the importance of security procedures
  • Ensure employees "buy in" (i.e., involving employees in food security planning and demonstrating the importance of security procedures to the employees themselves)

Unusual Behavior

  • Watch for unusual behavior by new employees or workers (i.e., stay unusually late after the end of their shift, arrive unusually early, ask questions on sensitive subjects, bring cameras to work)

Raw Material and Packaging


Suppliers

  • Use only known, appropriately-licensed or permitted sources for all ingredients, compressed gas, packaging and labels
  • Ensure that suppliers and transporters practice appropriate food security measures and screen their personnel
  • Inspect incoming ingredients and return products with signs of tampering or counterfeiting (inappropriate product identity, labeling, product code or specifications)
  • Supervise off-loading of incoming ingredients
  • Investigate missing or extra stock or other irregularities outside of pre-determined normal range of variability

Operations


Security of Water

  • Secure water wells, hydrants, storage and handling facilities
  • Ensure that water systems are equipped with backflow prevention
  • Regularly test your water to ensure it meets appropriate standards.  Include random checks, and be alert to changes in the profile results
  • Maintain contact with public water provider to be alerted to problems
  • Identify alternative sources of potable water

Security of Establishment Air

  • Secure access to air intake points for the facility to the extent possible
  • Examine the physical integrity of air intake points routinely

Finished Products


Security of Finished Products

  • Keep track of finished products
  • Ensure that the public storage warehousing and shipping vehicles practice appropriate security measures
  • Perform random inspection of storage facilities, vehicles and vessels
  • Evaluate the utility of finished product testing for detecting tampering and criminal or terrorist activity
  • Monitor closely the serving of foods in open display areas

Security Strategies


Response to Tampering and Criminal or Terrorist Events

  • Have emergency and security plans in place
  • Plan for emergency evacuation, including preventing security breaches during evacuation
  • Identify critical decision-makers
  • Identify management personnel that employees should alert about potential security problems
  • Identify and post 24-hour contact information for local, state, and federal police/fire/rescue/government agencies
  • Ensure employees know where emergency numbers are posted and that they have ready access to them
  • Alert Agricultural Law Enforcement of any unusual events at 800 342-5869.   This contact is available 24 hours a day, 7 days a week

Recall Strategies

  • Identify the responsible person and back-up
  • Provide for proper disposition of recalled product
  • Identify customer contact by addresses and phone numbers

Additional Steps

  • Maintain any floor or flow plan in a secure, off-site location
  • Become familiar with the emergency response system and the Emergency Command Center operations in your area
  • Make employees aware of company contacts and where they can be reached for potential security problems



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