Basic Fundamentals of Writing a Food Defense Plan

Basic Fundamentals of Writing a Food Defense Plan

Carol L. LorenzenAssociate Professor

Division of Animal SciencesUniversity of Missouri

Food Defense PlanDefense plans are encouraged but not

required for food establishments.

Courtesy of Food Technology magazine, from "Defending the Food Supply," August 2005, Vol. 59, No.8. Food Technology is a publication of the Institute of Food Technologists, www.ift.org.

Facilities Currently Required to Participate in Food Defense

Since July 1, 2006 all vendors providing processed fruits and vegetables to USDA must be in compliance with the Food Defense System.

Who Will Be Responsible?

Designate a Food Defense Coordinator to develop, implement and maintain the Food Defense Plan

Decide who will assist with the vulnerability assessment

Five Basic Steps for Developing a Food Defense Plan

Assess the vulnerabilities of the facility.

Write a food defense plan. Design countermeasures to reduce the risk in those areas deemed most critical.

Develop a response plan in case of intentional contamination.

Five Basic Steps continued

Implement the plan. Adapt countermeasures into operating procedures.

Evaluate the plan. Evaluate the effectiveness, review and revise defense measures as needed.

Maintain the plan. Ensure continued effectiveness, through training etc.

Assess the vulnerabilities

Look for vulnerable points in the facility. Assess using CARVER + Shock.

Consultation or workshop with “experts” can be completed in 2-3 days.

CARVER + Shock software is available from the FDA and can be completed in 6 – 8 hours.http://www.cfsan.fda.gov/~dms/vltcarv.html

Water and Ice Security: Is access to water reuse systems restricted?Mail Handling Security: Is mail handling conducted way from food processing operations?

Storage Security: Is an access log maintained for ingredient storage areas?

N/ANoYesQuestion

Personnel Security: Do all plant employees receive training on security procedures as part of their orientation training?

Slaughter and Processing Security: Are lines that handle and transfer products, water, oil and other ingredients monitored to ensure integrity?

Inside Security: Are all restricted areas (authorized employees only) clearly marked?

Outside: Are the plant’s grounds secured to prevent entry by unauthorized persons?

Mizzou MeatsVulnerability Assessment

Write the plan

Develop a countermeasure to defend each vulnerable point identified as high risk.

Create a written plan including those countermeasures that are reasonable for the situation.

CountermeasureVulnerabilityArea

Establish security training for new employees

Security training not part of orientation

Personnel Security:Training

Relocate mail room to site further from processing

Mail room is too close to processing

Mail Handling Security:

Secure reuse system with access code

Unrestricted access to water reuse system

Water/Ice Security:Reuse system

Place access log in storage room

No access log for storage room

Storage Security:Access Log

Have employees monitor line regularly

Product transfer line is not monitored.

Slaughter/Processing Security: Transfer lines

Post signs “AUTHORIZED EMPLOYEES ONLY” in restricted areas

Restricted Areas are not clearly marked

Inside Security:Restricted areas

Install perimeter fence with gates (phased installation)

Facility has no perimeter fence

Outside Security:Perimeter

Mizzou MeatsFood Defense Plan

CountermeasuresCountermeasures are actions taken to shield

vulnerable areas, reducing the risk of intentional

contamination.

CountermeasuresStaff – Pre-employment screening, employee supervision, identification, access, food security training.

CountermeasuresPublic - Restrict entry to facility, check identification, visitors sign log, supervise visitors.

CountermeasuresFacility – Perimeter fences, locks on doors, windows, monitoring of security, lighting, vehicle access, etc.

CountermeasuresOperations - Incoming supplies, delivery procedures, storage, water and utilities, shipping of product, mail procedures, computer access, etc.

Develop a Written Response Plan

Plan for handling of contaminated productEmergency Planning

Facility MapEmergency Contact Phone ListVisitor LogEmployee Emergency InformationSupplier/Customer Contacts

Handling of Contaminated Product

Retained or recalled product will need to be stored prior to disposal

Storage will need to be separate from non contaminated product

Prepare a plan for disposal, to be reviewed by FSIS and state authorities

FSIS will witness the execution of the plan

Facility Map

Name, address, and phone of owner/proprietor

Relationship of the facility to adjacent properties and/or structures.

Road access including transportation routes

Perimeter boundaries, include fences, and gates (with dimensions)

Facility Map continued

Buildings, outbuildings, doors, windows, AC/heating, ventilation Utilities (water, gas, electric, phones) location and shutoff Septic System and drainage areas with direction of flowWeb sites such as Google Earth www.earth.google.com

Parking

Mizzou Meats Facility Map

Receiving

Shipping

Drainage

Processing

H20

Employee Entrance Main Gate8ft.

Delivery Gate12 ft

Electric/Gas

ParkingPa

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Waco Road

Perim

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Parking

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Park

ing Phone

Septic

A/C

Heat

ing

RefrigerationCold

Storage

Mizzou Meats Inc. 6715 Waco Rd. Columbia MO 65202573-874-1289

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ft.

Loading Dock

Storage

Visitor Entry

A/CHeating

Emergency………………………………….……….911Columbia Police………………………………442-6131Boone County Sheriff……............................442-6131Missouri State Highway Patrol………1-800-525-5555University Hospital…………………………...882-4141Poison Control………………………...1-800-222-1222Ameren UE…………………………….1-800-552-7583Centurytel……………………………...1-800-824-2877Columbia Water and Light…………………...875-2555FSIS 24 hour emergency number…...1-866-395-9701FDA 24 hour emergency number……1-301-443-1240Missouri Dept. of Health and Senior Services……………………….1-800-235-5503Missouri State Emergency Management Agency…………………1-573-526-9100Missouri Dept of Homeland Security..1-573-522-3007

Mizzou Meats Emergency Phone List

Tour882-2610MO 456789

Univ. of MO256 Stringer Columbia MO

Truman M. Tiger

Sales Call645-9035KS098763

K State451 AppleManhattan KS

Willie K. Wildcat

Espionage389-4296NE123456

Univ. of NE

765 MaizeLincoln NE

Herbie N. Husker

Reason for visitPhoneDL # AffiliationAddressName

Mizzou Meats Visitor Log

657-9324Grandma Grizzly289-1657675-9874Judge B. Bear653-4531Lil Redwagon191-8978653-7619Sooner O. Schooner

666-1111C.J. Chickenhawk123-4567666-9999Jay J. Hawk456-8901Lassie Comehome931-7623456-9800Reveille C. AggieContact #Emergency ContactCell #Home #Name

Mizzou Meats Employee Emergency Contacts

Sue Snackstick573-634-2000Capital ConsumersFrank Flatiron573-875-4211Beefsteak Inc.

Contact PersonPhoneCompany

Sam Supplyline123-456-7890KochPhil Flanksteak573-657-1000Truman’s Packing Inc.

Contact PersonPhoneCompany

Mizzou Meats Supplier Contact List

Mizzou Meats Customer Contact List

Implement the plan

The food defense plan is implemented when the countermeasures are installed.

Countermeasure to Be InstalledResponsible Party

Chair committee to plan mail room relocationCal CycloneInstall water access code and change weeklyCisco CowboyInstall storage access log and monitor dailyJester JayhawkInstall Signage for restricted areasWilly WildcatInstall perimeter fenceTruman T. Tiger

Mizzou Meats Food Defense Implementation

Evaluate the plan

Make unannounced entrances at various checkpoints.

Check locks in vulnerable areas.

Check employee badges.

Perform a mock recall.

Test inventory procedures.

Evaluate continued

Review and revise the plan to accommodate new and newly elevated risks.

Is the transfer line monitoring adequate?Is the perimeter fence checked regularly?

Is the contact information reviewed and updated regularly?

Is there a designated person to manage and update the Food Defense plan?

N/ANOYESEvaluation Question

Mizzou Meats Food Defense Plan Evaluation

Maintain the plan

Ensure that measures implemented continue to be effective.

Train the employees regarding their effort in:Prevention

Detection

Response

Re-evaluate the plan annually, as new products, or processes are added or as facilities change.

www.fsis.govwww.cfsan.fda.govwww.bt.cdc.govwww.dhs.govwww.dhs.ca.gov

References