Plant Food Defense
Procedure
Document No.: 2.20
Revision: 10
Approved By: Business Process Manager
Effective Date: 11/6//2018
Page 1 of 6
1.0
Purpose
1.1
To identify and reduce the likelihood or impact of an intentional harm to the facility, its
personnel and/or products.
2.0
Responsibilities
2.1
It is the responsibility of all employees to alert management of any issues or concerns relating
to the security of the building or products produced by the company.
2.2
It is the responsibility of the Business Process Manager to lead the site Food Defense
program.
2.3
It is the responsibility of the Food Defense Team to adhere to the procedure.
3.0
Definitions
3.1
N/A
4.0
Procedure
4.1
Threat/Vulnerability Assessment
4.1.1 A threat/vulnerability assessment (TVA) is conducted to develop the Food Safety
Program and reviewed for possible revisions anytime there is a change to the facility, if
there are any new security issues and on an annual basis as part of the prerequisite
program evaluations. All changes and updates will be recorded and retained per the
Document Control Procedure
4.1.2 The Food Defense Program will also be evaluated based on internal audits and routine
inspections. If a non-compliance is discovered, a Corrective Action Request Form will
be initiated and the Food Defense team members will be responsible for evaluating the
effectiveness of the corrective action.
4.1.3 As part of the TVA program, the company is prepared to respond to an incident by
making the contact information for local and federal authorities readily available, plus,
listed by shift, the employees who are certified as first responders. This information is
posted on the bulletin board in the break room and all employees are informed of the
location.
4.1.4 Results of the company Threat and Vulnerability Assessment are determined on a
scale of 1 to 10. If the issue receives a determination of 1, the facility would be
considered vulnerable. To the contrary, if an issue receives a determination of 10, the
facility would be considered extremely secure. This assessment is an accumulation of
the observations and facts gathered by the Food Defense Team members.
2.20 Plant Food Defense Program
If this document is printed, it shall be considered uncontrolled
Plant Food Defense
Procedure
Document No.: 2.20
Revision: 10
Approved By: Business Process Manager
4.2
Effective Date: 11/6//2018
Page 2 of 6
Records Maintenance
4.2.1 Records are kept, maintained and updated for all sources pertaining to raw materials,
4.3
chemicals, processes and transportation for a period up to 7 years. These records are
retained departmentally
Building and Grounds Security
4.3.1 All entrances to the facility are either locked or monitored by an company employee.
4.4
The two entrances that are monitored, main door and shipping areas, have sign-in logs
for visitors. The front entrance for visitors, customers and contractors is monitored by
the front desk receptionist and everyone must log-in.
4.3.2 Entry to the production areas is controlled by a perimeter gate to prevent unauthorized
access. A key pad code in which only current company employees know, must be keypunched in for employee access. Once an employee is terminated, the code is
immediately changed.
4.3.3 Visitors are retained in controlled areas, such as the shipping/receiving waiting area for
truckers and the conference room for office visitors. Visitors must sign in and out and
are escorted to their desired location. However, there are a few visitors that visit
frequently/periodically and have gained trust with the company and are therefore given
permission to have unescorted access to the facility. These particular people are listed
on an “Approved Visitors List”, but are still required to sign in and out. Truck Drivers
are only allowed on the Dock Facility. If truck drivers need to use the restroom, they
are escorted through the shipping/receiving area by an company employee and must
sign in and out on the Visitors log.
4.3.4 The back-lot has a partial perimeter fence enclosure in the front area and there is an
entrance gate. There is signage that warns against unauthorized persons entering the
grounds or facility. Therefore, security is limited to the established interior access
methods.
4.3.5 Surveillance cameras are used to monitor the production areas, and outside
surveillance cameras are used to monitor the outside building, grounds, parking lots
and back gravel lot. The recorded footage is evaluated weekly by the company
owners.
4.3.6 The water supply to the plant is secure by means of city evaluations for contamination.
This evaluation is kept on file and updated annually.
4.3.7 Direct access from the roof cannot be achieved in the production or warehouse areas.
However, the roof is inspected monthly for any possible issues with access and for
possible repair needs. Access to the roof is controlled via a gated ladder that is
padlocked closed.
4.3.8 Currently, there is no air handling systems connected to the production area.
Raw Materials and Chemicals
4.4.1 All raw materials delivered to the plant must undergo a transportation and material
inspection before they can be received. This process is outlined in the “Transportation
and Storage” program. The process requires inspections for both security and food
safety issues. Proof from these inspections is retained on the “Receiving Checklist” for
a period of no less than 7 years.
4.4.2 Control of stored raw materials is also outlined in the “Transportation and Storage”
program. The staging of raw materials for production is controlled by the Shipping
Department. There are minimal chances that materials could be contaminated while in
storage because the facility does not contain any microbial or allergen type substances;
2.20 Plant Food Defense Program
If this document is printed, it shall be considered uncontrolled
Plant Food Defense
Procedure
Document No.: 2.20
Revision: 10
Approved By: Business Process Manager
4.5
Effective Date: 11/6//2018
Page 3 of 6
material is kept covered until used; if any chemicals that are considered toxic were to
be put in contact with the material, the effects would be visibly apparent; and raw
materials at this facility have no heat sensitivity that would cause any food or safety
issues without being easily detected.
4.4.3 Chemicals and hazardous materials including toxic materials and cleaning compounds
are stored secured and proper inventory of these materials is maintained. Chemical
waste is disposed according to relevant regulations.
Transportation
4.5.1 The transportation of material from the plant is primarily customer driven. Specific
4.6
customer approved transport companies are used by the customers and compliance to
security and food safety issues are controlled through the “Transportation and Storage”
program.
4.5.2 An inspection of the transportation vehicle is performed by the Shipping Department
and recorded on the “Shipping Checklist” that is retained for a period of no less than 7
years.
4.5.3 Truck seals are used for full trailer-load shipments and the information is recorded and
retained on the Bill of Lading.
4.5.4 All materials that are shipped from the facility are packaged with layers of protective
materials (bags, corrugated boxes, plastic dust covers, and stretch-wrap).
Employees
4.6.1 Because disgruntled employees are a potential threat to intentional product
4.7
contamination, the following precautions have been established:
a)
Background criminal and employee reference checks are performed on all
potential employees.
b)
Random drug testing is used for screening potential employees.
c)
A zero tolerance policy is clearly stated in the employee handbook regarding
violence, weapons and illegal drug use.
d)
Internal locker inspections are performed semi-annually and are recorded.
Locker assessment reports are maintained on-file.
e)
The key pad access to the production area is reset instantly when an employee
is terminated.
f)
All verbal or written threats and suspicious behavior by terminated employees
will be reported to the local police department and communicated to all current
employees for their awareness and protection.
g)
A termination policy has been established and implemented into the Employee
Handbook. Within this policy, it is clearly stated that employees who have been
terminated are not permitted to have access to the building or grounds without
being escorted. Any peculiar behavior observed by ex-employees should be
reported to management right away.
Visitors
4.7.1 All visitors to the facility are required to:
a)
b)
c)
d)
Enter the facility through one of the monitored entrances.
Sign in and out of the “Visitor Log” and state their business
Read the company pamphlet regarding food safety and access rules (signing
the log signals compliance).
Stay contained in the designated areas unless escorted by an company
2.20 Plant Food Defense Program
If this document is printed, it shall be considered uncontrolled
Plant Food Defense
Procedure
Document No.: 2.20
Revision: 10
Approved By: Business Process Manager
e)
4.8
Effective Date: 11/6//2018
Page 4 of 6
employee, or given permission to have access to the facility without an escort.
If the visitor is listed on the Approved Visitors List, they have the same access
as an employee, except that they will not be given the code to the keypad
leading to the production area. A company employee will have to open the gate
for them (via key pad access code).
Disclose any chemicals or “questionable” materials that are brought into the
facility.
IT Security
4.8.1 Access to computer systems is protected through firewalls and/or passwords.
4.9
Computers lock after 60 seconds when not being in use. Data is automatically backed
up on external server every 24 hours.
Monitoring Inspection
4.9.1 The SQF Practitioner or back-up personnel will perform a monitoring inspection daily
4.10
following the criteria outlined on the Food Defense Checklist. This information will be
used to ensure that safety precautions are being following and are working effectively.
4.9.2 The SQF Practitioner or back-up personnel will retain the inspection records for no less
than 7 years.
Education and Training
4.10.1 All members of the Food Defense Team are trained by the Food Safety Coordinator
4.11
using information obtained from the FDA’s online courses and videos related to Food
Defense Awareness.
4.10.2 All other employees are trained for Food Defense awareness through the group
discussion focused on this procedure and information from the FDA website.
4.10.3 Training is documented. The documented training is filed in the Human Resources file.
Food Safety Program Team Members
4.11.1 Reference 2.20-W002 Emergency Contact List – Food Safety Program Team Member
4.12
list.
Food Fraud Mitigation Strategy
4.12.1 Food Fraud is a deliberate and intentional substitution, addition, tampering, or
misrepresentation of food, food ingredients, or food packaging; or false or misleading
statements made about a product, for economic gain.
4.12.2 2.30 Food Fraud Mitigation Strategy documents the sites opportunity and the
motivation behind the risk.
4.12.3 The vulnerability assessment and mitigation strategy is reviewed by members of the
Food Defense Team on an annual basis.
2.20 Plant Food Defense Program
If this document is printed, it shall be considered uncontrolled
Plant Food Defense
Procedure
Document No.: 2.20
Revision: 10
Approved By: Business Process Manager
4.13
Effective Date: 11/6//2018
Page 5 of 6
Food Defense Resource Guide:
4.13.1 World Health Organization (WHO) – “Terrorist Threats to Food – Guidelines for
Establishing and Strengthening Prevention and Response Systems” (ISBN 92 4
154584 4)
http://www.who.int/foodsafety/publications/general/terrorism/en/
4.13.2 U.S. Food and Drug Administration (FDA) – Food Defense & Terrorism
http://www.cfsan.fda.gov/~dms/defprog.html
4.13.3 U.S. Food and Drug Administration (FDA) – “Retail Food Stores and Food Service
Establishments; Food Security Preventive Measures Guidance”
http://www.cfsan.fda.gov/~dms/secgui11.html
4.13.4 U.S. Food and Drug Administration (FDA) – ALERT: The Basics
https://www.accessdata.fda.gov/videos/CFSAN/alert/alrt01.cfm
4.13.5 FSIS General Food Defense Plan:
http://www.fsis.usda.gov/wps/wcm/connect/99f95182-0c9e-4214-9762e98197f54ebf/General-Food-Defense-Plan-9-3-09+_2_.pdf?MOD=AJPERES
4.13.6 Additional web-based resources can be found at the following link:
enter the web address www.usda.gov and search on the words “food defense
guidance.”
4.13.7 FDA Food Defense Tools & Educational Materials.
4.14
http://www.fda.gov/Food/FoodDefense/ToolsEducationalMaterials/default.htm
4.13.8 The National Center for Food Protection and Defense (NCFPD) is a research
consortium that looks at our Nation’s food system with respect to the vulnerabilities of
attack through intentional contamination with biological or chemical agents.
http://www.ncfpd.umn.edu/
First Responders and Regulatory Agencies Contact Information
4.14.1 Reference the Emergency Contact list which is posted by the reception desk
5.0
Corrective Actions
5.1
Any non-conformance with this procedure will require immediate corrective action, including
correction of the root cause and training of the personnel involved. All actions will be recorded
on the CAPA form by the SQF Practitioner or designee.
6.0
Verifications
6.1
The SQF Practitioner or designee at least once per month will verify this procedure and the
records by choosing one element of this procedure and reviewing the documents or visually
observing that the element is compliant.
2.20 Plant Food Defense Program
If this document is printed, it shall be considered uncontrolled
Plant Food Defense
Procedure
Document No.: 2.20
Revision: 10
Approved By: Business Process Manager
7.0
Forms and Records
7.1
7.2
7.3
7.4
7.5
2.3-F001
Receiving Inspection Checklist
2.18-F001
Shipping Dock Audit
2.20-F001
Food Plant Defense Inspection Checklist
2.20-F002
Approved Visitors List
2.20-F003
Visitors Log
8.0
Reference Documents
8.1
8.2
8.3
2.20-F004
Food Defense Threat & Vulnerability Assessment
2.20-W002
Emergency Contact List
2.30
Food Fraud Mitigation Strategy
Effective Date: 11/6//2018
Page 6 of 6
REVISION HISTORY:
Revision
Date
Revision
#
9/13/2016
4
12/6/2016
5
10/7/2017
6
10/28/2017
7
11/15/17
8
9/10/18
9
11/06/18
10
2.20 Plant Food Defense Program
Revision Description
Food Defense coordinator responsibility was assigned to Business
Process Manager. QA Manager contact information was removed
from the Program.
Added new team members, removed reference to sharing gravel
back lot with tenant
Added frequency of monitoring and corrective and verifications;
revised Food Defense Team Members,
Doc # change
Added Business Process Manager are responsible for Food
Defense; updated threat assessment to include camera monitored
daily and personnel practices procedure as additional control against
allergens, threat level reduced to 5.
Removed Food Defense team and added reference to 2.20-W002,
2.30; removed appendix A; updated training section; adds new
section 4.12 Food Fraud Mitigation Strategy.
Changed title of document; Removed Threat and Vulnerability
assessment to new form
If this document is printed, it shall be considered uncontrolled