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Making a Food Defense Plan Functional: It Won't Help If You Don't Use It!
By LTJG Kazuhiro Okumura, U.S. Public Health Service Commissioned Corps
In Small Plant News, Volume 3, Number 5, the article
"Developing Food Defense Plans: Shifting Greater Awareness Into Action" discussed
why you should adopt a food defense plan, its benefits, and the process in developing a plan.
Nick Bauer of the U.S. Department of Agriculture's (USDA) Food Safety and Inspection Service's (FSIS) Office of
Data Integration and Food Protection gives five reasons why you should adopt a food defense plan. It:
- Helps to protect your product and customers.
- Helps to maintain a safe working environment for employees.
- Increases establishment preparedness and facilitates an appropriate response to an emergency.
- Enhances establishment security.
- Helps to protect your company's bottom line.
"Having a food defense plan is an effective way to reduce the risk of intentional tampering or contamination of your products.
FSIS is encouraging businesses to not only have a food defense plan, but to make sure it's also functional," said Bauer.
So, what is a functional food defense plan? There are five elements:
- Conduct an assessment of your business and facility.
- Develop a food defense plan that can adequately protect your business and products.
- Implement the plan.
- Test the plan. This is a key difference between simply having a food defense plan and having a functional one. Every
functional food defense plan must be tested to make sure it works. A plan on paper may look and
sound good, but it may be a different story when it is put into action.
- Review and maintain the plan. Any changes in your operations and the results from testing should be considered, and
your food defense plan should be revised to incorporate any corrective actions you identified. The plan should be reviewed at
least once a year.
Graphs: Percentage of Plants With a Functional Food Defense Plan; Percentage of Small and Very Small Plants With a Functional Food Defense Plan:
See page 2 of PDF version, or these data tables.
For those of you who have a food defense plan, how do you know it is effective? Will it work when you need it? In other words,
if your facility was targeted for an intentional attack, will the plan help minimize losses to your business and your customers?
There has been an upward trend in plants adopting functional food defense plans across all establishment types and sizes.
FSIS conducted a survey in August 2010 and found that 74 percent of all plants had a functional food defense plan, which
represents an increase of 12 percentage points from December 2009. A total of 82 percent of small plants and 64 percent of
very small plants had a functional food defense plan, compared with 72 percent and 48 percent, respectively, in December 2009.
Detailed results of the August 2010 survey can be found at
www.fsis.usda.gov/Food_Defense_&_Emergency_Response/
Food_Defense_Plan_Survey_Results/index.asp.
A copy of the general food defense plan, Food Defense Plan: Security Measures for Food Defense, can be found on the
FSIS Web site at www.fsis.usda.gov/PDF/
GeneralFood-Defense-Plan-9-3-09%20_2_.pdf (PDF Only).
FSIS has many resources to help you develop a food defense plan and make it functional on its Web site at
https://webarchive.library.unt.edu/web/20120921151820/http://www.fsis.usda.gov/
Food_Defense_&_Emergency_Response/index.asp.
You can also request assistance on food defense guidance materials by contacting the Small Plant Help Desk at 1-877-FSISHELP
(1-877-374-7435) or by emailing
InfoSource@fsis.usda.gov.
The Help Desk is open from 8:00 a.m. - 4:00 p.m. ET, Monday through Friday.
For policy-related questions, please call the FSIS Policy Development Division at 1-800-233-3935 (6:00 a.m. - 5:00 p.m. CT, Monday through Friday, except
on Federal holidays), or submit a question to askFSIS at https://webarchive.library.unt.edu/web/20120921151820/http://askfsis.custhelp.com.
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Revised and New Performance Standards for Salmonella and Campylobacter in Effect
By Jane Johnson, DVM
On March 16, 2011, FSIS announced the implementation of revised and new performance standards for verification sample sets aimed
at reducing the prevalence of Salmonella and Campylobacter in young chickens and turkeys. The improved standards
went into effect July 1, 2011. After 2 years of implementing the new standards, the Agency estimates that the new
Campylobacter standards will prevent approximately 5,000 illnesses a year, and the revised Salmonella standards
will prevent approximately 20,000 illnesses a year.
The revised and new standards include:
- The movement of young chicken and turkey establishments to the highest scheduling
priority due to the initiation of Campylobacter testing for these product classes.
- Analysis of all sample sets scheduled for young chicken and turkey establishments
for both Campylobacter and Salmonella, and analysis of followup sample sets responding to sample set
failure for either organism analyzed for both organisms.
- The new Salmonella standards accept 5 positive samples in a 51-sample
set for young chickens and 4 positive samples in a 56-sample set for turkeys.
- Salmonella performance Categories 1 and 2 for young chicken and turkey
establishments will be applied exclusively for Agency internal analysis and quarterly aggregate reporting.
- Web posting of a list of young chicken and turkey establishments that fail the
new Salmonella standards (Category 3) for their last set will begin when sample sets scheduled for July 2011 are
completed.
- Campylobacter performance standards and sample set criteria for tracking
and reporting to establishments are applied to results from the smaller of the two laboratory Campylobacter sample
portions (1 mL), which detects higher levels of contamination, making the performance standards 10.4 percent for young
chickens and 0.79 percent for turkeys.
- Campylobacter sample set criteria for tracking and reporting 1 mL results
are 8 positive samples acceptable per 51-sample set for young chickens and 3 positive samples acceptable per 56-sample set
for turkeys.
- Campylobacter results from the larger of the 2 laboratory Campylobacter
sample portions (30 mL for chickens, 24 mL for turkeys), which detects lower levels of contamination, are used for Agency
internal analysis.
- Agency responses to Campylobacter sample set results will follow current
Salmonella procedures for immediate followup testing for both organisms and for food safety assessments when necessary.
- Category 1/2/3 results will be posted in quarterly aggregate reports for all
establishments producing raw products subject to FSIS Salmonella testing, including young chickens and turkeys
under the new standards.
If you have any questions or wish to receive more information, feel free to contact the Small Plant Help Desk at 1-877-FSISHELP,
or email InfoSource@fsis.usda.gov.
The Help Desk is open from 8:00 a.m. - 4:00 p.m. ET, Monday through Friday.
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Commonly Asked Questions & Answers
Q. Can a charitable organization custom slaughter livestock in accordance with 9
Code of Federal Regulations (CFR) Part 303.1 (a)(2) and serve the meat or meat food products derived from that custom
slaughter to individuals who access the services of the charitable organization?
A. No. Meat or meat food products derived from the custom slaughter of livestock can only be used
by an owner, household members, nonpaying guests, and employees. Individuals who access the services of the charitable organization
are not "non-paying guests." They are clients who receive services from the charitable organization.
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BIFSCo Releases Guidance Document
By Jane Johnson, DVM
The Beef Industry Food Safety Council (BIFSCo) has posted a guidance document, Guidance Document for Sampling and Lotting of
Beef Products and Sample Analysis for Pathogens, on its Web site. The document was introduced at the council's ninth annual
Beef Industry Food Safety Summit, held in Dallas from March 2-4, 2011.
According to its introduction, it "provides best industry practices for components (lotting, sampling, and laboratory analysis)
of the pathogen-testing program as a part of an overall food safety system. It's important to recognize that these are just
components of the system, and their success depends on the proper implementation
of the best practices leading to these steps and after these steps." The document may be accessed at the council's Web site at
www.bifsco.org/CMDocs/BIFSCO/
Sampling,%20Lotting%20and%20Sample%20Analysis%20Document%20FINAL%20SEPT%202010.pdf (PDF Only).
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Small Plant NEWS
Editor: Keith Payne
Managing Editor: Jane Johnson, DVM
Production: Joan Lindenberger, Sally Fernandez
Design: Gordon Wilson, Duane Robinson
Contact: Small Plant News, USDA/FSIS, Patriots Plaza III, Rm. 9-267A, Mailstop 3778,
1400 Independence Ave., SW, Washington, DC 20250
1-800-336-3747
Email: SmallPlantNews@fsis.usda.gov
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