FSMA and Supply Chain
Security
Andrew Wynter MSc, CPP, PSP, PFSO.
Compliance and Investigations Manager
GIA Grace Kennedy
Setting the context:
Big Jamaican drug find overseas - Canadians
seize C$19m in contraband among shipment
of pumpkins
Canadian police have seized more than 626 kilograms of hashish, hash
oil and ganja stashed under
a shipment of Jamaican
produce including pumpkins, yams and sweet
potatoes.
The drugs, with an estimated street value of C$19 million (J$1,086,800,000) were
discovered on July 22 wrapped in plastic and hidden under a false floor in a
container shipped to Halifax, Nova Scotia, on the Atlantic Coast.
FSMA and Supply chain Security
SEC. 103. HAZARD ANALYSIS AND RISK-BASED
PREVENTIVE CONTROLS REQUIRES THAT
The owner, operator, or agent in charge of a facility shall, in
accordance with this section, evaluate the hazards that could
affect food manufactured, processed, packed, or held by
such facility, Identify and implement preventive controls to
significantly minimize or prevent the occurrence of such
hazards and provide assurances ….. monitor the performance
of those controls, and maintain records of this monitoring as
a matter of routine practice.
Components of a Supply chain
Primary & Secondary source
 Transportation
 Production or processing facility
 Warehouse / storage facility
 Distribution center
 IT / communication
 Wholesale or retail facility
 Customer/ consumer
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Example of a Modern Supply
Chain
Hazards that can affect the
Supply chain
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Piracy
Narcotic/ weapon smuggling
Regulations
Counterfeiting products
Diversion/ hijacking
Organized crime
Natural / manmade disasters
Contamination
◦ Biological
◦ Chemical
◦ Physical
Hazards that can affect the
Supply chain cont’d
Pilferage
 Fraud
 Labor unrest
 Weather
 Sabotage
 Inadequate Security
 People (Employee, suppliers, customers)
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Supply chain vulnerability.
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Any point along the chain
◦ Transportation
◦ Warehouses,
◦ DCs, storage yards,
◦ Manufacturing
◦ packaging facility
( Cargo at rest is cargo at risk)
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Anyone who has access to your products
Organized crime networks
◦ domestic
◦ international
Addressing hazards affecting the
supply chain
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Identify – Threats , hazards,
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Assess – Threats, hazards (Risk assessment )
Develop – Plans, procedures, and program to mitigate
threats, hazards.
 Implement – program
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Monitor and review – program, processes, procedures
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Implement corrective action program
FSMA and Supply chain Security
ELEMENTS OF SUPPLY
CHAIN SECURITY
DETAILS
Supply chain security (People)

Detailed background checks
Awareness training
Pre-employment / recruiting screening
Psychometric testing for honesty
Detailed background checks
Drug testing
Well designed and relevant policies and
procedures
Whistle blowing or reporting program
 Well conducted Investigations
Creation a culture of honest or risk intelligent
culture
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Supply chain Physical Security
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Construction of the facility
Access control
CCTV
Intrusion detection
Perimeter equipment (Fencing, Walls etc)
Guarding operations
Key control
Screening policies and procedures
Lighting
Supply chain conveyance
Registered or approved haulage contractors
 Registered and approved air and sea carriers
 Use seals that meet international
specification
 Proper custody and documentation
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Seals should be distributed in sequential order
Seals should be properly secured
Audit seals regularly
Shipper should sign as an indication that they are in
possession of seal(s)
 Keep proper records of seals issued and received
 Damaged or unused seals should properly destroyed
 Inspect seals before and after installation
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What regulators are looking for in the
program
 Regular auditing and reviewing of processes
 Compliance reports
 Security assessments
 Self assessments reports
 Corrective action plans reports
 Properly organized and maintained records
 Change management process
 Up to date certifications
What regulators are looking
for in the program
Risk assessment
 Training and awareness ( staff & suppliers)
 Well developed security program
 External audits, and reviews
 IT Security
 Properly documented procedures and
processes
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Benefits of good quality supply chain
security program
Protects your brand revenue and
reputation
 Reduces cost
 Improves efficiency of process
 Builds confidence with your customers
 Builds confidence with your suppliers
 Build confidence with the regulators
 Deters criminal activity
 Opens opportunity in new markets
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Summary of a high quality Supply
chain security program
Well develop security plan
Plan is owned and driven by management
Staff are trained on the supply chain security plan
Contracts have a clauses to address risk
Robust IT system with security protocols
Good relationships with law enforcement and
security professionals
 Facility for employees and/or third parties to make
reports
 Reported incidents are fully investigated
 Monitoring and reviewed regularly.
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Internationally recognized standards and
programs that support supply chain security
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BASC,
CTPAT,
ISO 28000 – Supply chain
ISO17712 – ( Mechanical )Freight Seals
ISO 31000- Risk Management
ISO22000
FSSC/ HACCCP
ISPS Maritime Security Codes
Little things that make a big difference
Fit and proper persons or companies
 No cleaning of containers or packages
 No inspection of containers
 Errors and mistakes on documentation
 Weak security controls and practices
 Out of date certifications
 Poor record keeping
 Poor employment practices
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Supply chain Security
Minefield or opportunity depends on how you manage your program
QUESTIONS