Guide to Developing a Food Defense Plan for a Food Processing Plant
What is Food Defense?
Food defense is putting measures in place that reduce the chances of the food supply from becoming intentionally contaminated using a variety of chemicals, biological agents or other harmful substances by people who want to do us harm. These agents could include materials that are not naturally-occurring or substances not routinely tested for in food products. A terrorist’s goal might be to kill people, disrupt our economy, or ruin your business. Intentional acts generally occur infrequently, can be difficult to detect, and are hard to predict.
Food defense is not the same as food safety. Food safety addresses the accidental contamination of food products during storage and transportation and focuses on biological, chemical, or physical hazards. The main types of food safety hazards are microbes, chemicals, and foreign objects. Products can become contaminated through negligence and contamination can occur during storage and transportation.
Why Develop a Food Defense Plan?
A Food Defense Plan helps you identify steps you can take to minimize the risk that food products in your establishment will be intentionally contaminated or altered. A plan increases preparedness. Although the plan should be in place at all times, it may be particularly helpful during emergencies. During a crisis, when stress is high and response time is at a premium, a documented set of procedures improves your ability to respond quickly.
A Food Defense Plan will help you maintain a safe working environment for your employees, provide a safe product to your customers, and protect your business.
To help owners and operators of food processing plants, we have created this guide to assist you in developing a cost-effective Food Defense Plan for your facility.
It is important to remember that there is no “one size fits all” approach to creating your Food Defense Plan. The plan can be as long or as short as is appropriate for your operation.
Who might Adulterate a Food Product?
Below are some examples of the types of individuals who might be motivated to intentionally adulterate food products. You should contact your local law enforcement community for additional information about potential local threats to your facility.
Examples of Threats
- Disgruntled current or former employee
- Members of terrorist or activist groups posing as:
- Cleaning crew
- Contractors
- Temporary employees
- Truck drivers (shipping and receiving)
- Visitors
- Utility Representatives
Individuals that want to intentionally adulterate product and do not have authorized access to your facility are considered intruders. Another threat may come from an internal source, such as disgruntled current or former employees and other insiders, who typically know what procedures are followed in the facility and often know how to bypass many security controls that would detect or delay an outside intruder.
Steps in Developing a Food Defense Plan
We recommend using the following three steps when developing a Food Defense Plan. If you follow and complete these steps and use the forms provided as a template, you will have developed a food defense plan for your facility.
Step 1 – Conduct a Food Defense Assessment
Begin by choosing a person or team to be responsible for the security of your plant. The team or responsible person will answer the questions in the assessment to help you understand which parts of your facility may be more vulnerable. When completing this assessment remember to consider both potential internal and external threats. The results of the assessment should be kept confidential so that they do not provide a roadmap for future attacks.
Step 2 – Develop a Food Defense Plan
Now that you have identified the aspects of your food processing plant that may be vulnerable you will need to identify cost-effective preventive actions that can be taken to minimize those vulnerabilities.
At a minimum, your Food Defense Plan should address:
- inside security
- outside security
- storage security
- shipping and receiving security
Step 3 – Implement the Food Defense Plan
Assigning Responsibilities:
Individual employee’s food defense responsibilities should be defined and documented in your plan. Assign overall responsibility for food defense to a single employee, if possible, who has an understanding of the security requirements.
Staff Training
Train staff in all provisions of the plan. The purpose of food defense awareness training is to ensure your employees know their responsibilities. Training should address access control procedures, access to restricted areas, protecting critical components, and procedures for reporting suspicious activities. Understanding the threat of intentional adulteration and the potential consequences should help employees consistently execute preventive measures, increasing the overall effectiveness of the plan. Encourage the “neighbourhood watch” concept – employees can be your “eyes and ears”.
Food Defense Plan Assessment and Revision
Review your plan and revise it, as needed, at least annually or when there is a change in your process. You may need to revise the plan to address changing conditions such as adding a new customer; adding a new technology; etc. Record the fact that you have done.
Emergency Contact Numbers
In addition to plant employees, current local, state and federal government Homeland Security contacts and public health officials should be listed in the plan. Local law enforcement and FBI offices should also be included in the contact list. Update the list regularly. You may wish to keep this list near your phones for a ready reference.
Product Recall Procedures
You probably already have Product Recall Procedures developed and included in some other plan in your operation. Please review your recall procedures and determine if any updates need to be made to address food defense concerns. If you do not have established recall procedures in place, please contact an industry trade association for additional information.
For more information, please Chat with us Ask The Expert.
