Model FoodSec Plan Processing

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U.S. Department of Agriculture FoodSafety and Inspection Service

Model Food Security Plan

for

Meat and Poultry ProcessingFacilities

Draft of April 2005

relc


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1.0 Introduction

In May 2002, the Food Safety and Inspection Service (FSIS) issued the FSIS SecurityGuidelines f or Foo d Processors to assist meat, poultry, and egg product plants inidentifying ways to strengthen their food security protection. In ugust 200!, the FSIS

Safety and Security Guidelines for t he T ransportation and Distribution of Meat, Poultry,and Egg Products were issued, which focused on enhancing food safety and security in thetransportation and distri"ution segments of the supply chain. #hese guidelines are voluntaryand provide recommendations a"out types of security measures that may "e used to preventcontamination of meat, poultry, and egg products during processing, transportation, andstorage. particularly important aspect of the guidelines was the recommendation that eachfacility should develop and implement a Food Security $lan. #he purpose of this documentis to provide additional guidance a"out the development and implementation of foodsecurity plans for meat and poultry processing facilities.

2.0 Why Develop a Model Plan?

FSIS "elieves that the security of meat and poultry processing facilities can "e enhancedthrough the implementation of ris% management techni&ues that are tailored for the needs of each esta"lishment. #his process can "e facilitated "y the use of Food Security $lans. #hese

plans identify the types of preventive steps that esta"lishment operators may ta%e to minimi'ethe ris% that food products under their control will "e su" ect to tampering or other maliciouscriminal actions.

#he main value of a plan is to increase preparedness. lthough the plan should "e e ecuted atall times, it may "e particularly helpful during emergencies. *uring a crisis, when stress ishigh and response time is at a premium, a documented set of procedures provides facilityoperators the a"ility to more readily e ecute standard response actions while focusing on an

appropriate course of action for the specific event. #herefore, Food Security $lans will "e particularly "eneficial under elevated threat conditions, especially when there is reason to "elieve that the food sector may "e targeted for attac%. *evelopment and effectiveimplementation of prevention and response strategies at every esta"lishment will improve thesecurity status of supply chains in the food sector.

FSIS understands that, in addition to concern for product lia"ility and "rand name protection,mar%et+driven forces have already caused some companies in the food industry to invest insecurity enhancements for their esta"lishments. ne driver for these actions has "een there&uest for security improvements "y customers. In these cases, the security status of anesta"lishment typically is characteri'ed "y third party auditors using chec%lists adopted fromFSIS or Food and *rug dministration (F* ) guidelines. #he audit findings determine thenature of the security enhancements re&uired "y the customer.

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nother driver is the incorporation of food security re&uirements in government sponsored programs. For e ample, the -nited States *epartment of griculture s, (-S* )

gricultural Mar%eting Service ( MS) purchases food products for Federal nutritionassistance programs through the /ommodity $rocurement $rogram. MS intends to includefood security re&uirements in its contract specifications in the coming procurement cycle.

gainst this "ac%ground of Federal agency guidance and mar%et+driven re&uirements, FSISintends for these model plans to serve as the framewor% for a reasoned and costeffectiveapproach to improving the security status of the food sector. lthough these model plans may

"e useful to all types of food industry esta"lishments, the focus is on small and very small plants that may not have an internal security department or that lac% e perience dealing withfood security issues.

#his document presents a model food security plan that can "e used as a starting point for thedevelopment of a meat or poultry processing facility+specific plan. #his generic model is notintended to "e used as is1 for the facility+specific food security plan. Further, all of theguidance contained in this document may not "e appropriate or practical for every meat or

poultry processing facility. FSIS recommends that facility owners review the guidance andassess which preventive measures are suita"le for their operation. ample preventivemeasures are presented for the each of the security goals discussed in this document. #hesemeasures should not "e considered an inclusive list of all potential approaches to achievingfood security. ach esta"lishment should determine the most cost+effective means to achievefood security goals "ased on the current security status of the esta"lishment.

companion document provides a model food security plan for meat and poultryslaughter facilities. For esta"lishments that conduct "oth slaughter and processingoperations, the two models can "e merged into a single plant+specific plan.

!.0 3hat is Food Security4

Food security involves preventing, minimi'ing, or responding to the deli"erate contaminationof food products "y a variety of potential threat agents ("iological, chemical, radiological).#hese are criminal actions that involve willful intent to do harm5 they cannot "e anticipatedwithout intelligence information. #he motivation for these illegal actions includes the a"ilityto cause illness and deaths following consumption of adulterated products and the desire tocause economic and psychological damage, including inspiring fear among the pu"lic and lossof confidence in the safety of the food supply.

Food security is not the same as food safety. Food safety addresses the accidentalcontamination of food products during processing or storage "y "iological, chemical or

physical ha'ards. #he main types of food safety ha'ards are micro"es, chemicals andforeign o" ects. #his unintentional contamination of food products can "e reasona"ly

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anticipated "ased on the type of processing. #his principle is the foundation of the6a'ard nalysis /ritical /ontrol $oint (6 //$) process used to ensure food safety.

7ote that "ecause of the differences "etween food safety and food security, a facility 6 //$$lan should not "e used as a su"stitute for a Food Security $lan. 6owever, li%e a 6 //$

$lan, a Food Security $lan should emphasi'e preventive over reactive measures.

8.0 3ho Might dulterate a Food $roduct4

3hen evaluating the potential vulnera"ility of a processing esta"lishment, the facilityoperator should consider a variety of potential perpetrators who may e ecute an attac% from

"oth inside and outside the facility. #hese include "oth opportunistic attac%s "y singleindividuals and planned attac%s "y lone or organi'ed aggressors. #a"le 9 lists somee amples of the types of individuals that might "e motivated to adulterate food products.Facility operators should contact their local law enforcement community for additionalinformation a"out potential local threats to their facility.

y#a"le 9. ample # pes of Internal and ternal ttac%ers

Internal ternal*isgruntled employee/leaning crew/ontractors#emporary employeesMem"ers of terrorist groups posing as

Individuals motivated to attac% a facility that do not have authori'ed access areconsidered to "e intruders or e ternal attac%ers. nother threat comes from internal

attac%ers, such as disgruntled employees and other insiders, who typically %now what procedures are followed in the plant and often %now how to "ypass many securitycontrols that would detect or delay an outside intruder.;.0 Food Security $rinciples

#he following guiding principles will assist facility operators in developing effectiveFood Security $lans for their esta"lishments)

>.0 Steps in *eveloping a Food Security $lan

In developing their esta"lishment+specific plans, FSIS recommends that meat and poultry processing facility operators use a three step process< (9) conduct a food security assessment

for the esta"lishment5 (2) develop a plan, "ased on ris% management principles, of preventivemeasures to minimi'e the potential vulnera"ilities identified in Step 95 and (!) implement andtest the plan.

#hese steps are discussed in greater detail in the following sections.

Step 9 D /onduct a Food Security ssessment

ach facility should designate an individual or team responsi"le for the security of theesta"lishment. #he team may use a num"er of different types of tools to aid in conductinga food security assessment. #hese tools include various models andchec%lists, such as the FSIS Industry Self-Assessment for C hecklist for Fo od Security(availa"le at http


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Model Food Security $lan for Meat and $oultry $rocessing Facilities ;


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Step 2 D *evelop a Food Security $lan

#he focus of a Food Security $lan is on the identification of cost+effective preventive actionsthat can "e ta%en to minimi'e the facility+specific vulnera"ilities identified in the securityassessment. #he plan should address a num"er of food security goals. t a minimum, the

plan should address the following


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oal 7um"er 2 D nsure $rocessing Security

#his goal addresses monitoring of the e&uipment used in the processing facility and theflow of all raw materials, finished products, returned goods, and other items that are usedin production. It also includes personnel security for employees.

Some e ample vulnera"ilities, and options for mitigation, are shown in thefollowing ta"le.

$rocessing Security

Sample :ulnera"ilities $otential Security Measures

#hreat agents placed in com"o Bimit access to com"o "ins. Store com"o "ins containing trim, variety "ins in loc%ed areas and limit access "asedmeats, or parts on o" function. Increase employee food

security awareness.

#hreat agents introduced at critical ?estrict access at critical operations to process points employees that receive additional training

andAor "ac%ground investigations (seeFigure 2). Increase employee foodsecurity awareness.

#hreat agents placed in water /hec% integrity of water supply system insupply or ingredients used to the plant5 ensure security of access points.

prepare in ection solutions ?estrict access to materials used insolution preparation. Screen and trainemployees wor%ing in these operations.

#emporary employees with access #rain permanent employees to raise their to critical operations food security awareness. ?e&uire use of

personnel identification "adges. -secolored uniforms, ac%ets, etc.

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increasingLevel of

Protection

ility Access

Figure 2. ample of varying employee access levels "y sensitivity of the operation.reas containing the most vulnera"le operations should "e restricted to a limited num"er

of employees, and these employees should receive "ac%ground investigations andadditional training.

oal 7um"er ! D nsure Storage Security

#his goal addresses measures to control access to ingredient and product storage areas andthe maintenance of appropriate records. nsuring storage security will protect against theintentional misuse of ingredients or non+food items used in the plant as food adulterants.Storage areas should "e ade&uately secured and monitored, with access limited toauthori'ed personnel only.

Some e ample vulnera"ilities, and options for mitigation, are shown in the followingta"le.

Storage Security

Sample :ulnera"ilities $otential Security Measures#hreat agents placed in non+meatingredients (spices, additives) andnon+food items (disinfectants,cleaners)

#hreat agents placed in com"o "inscontaining trim, variety meats, or

parts destined for further processing

Geep storage areas loc%ed and limitaccess "ased on o" function. ?e&uireuse of personnel identification "adgesand utili'e card %ey system to monitor access to storage areas. ?e&uire use of logs for inventory material control.Ma%e periodic chec%s of inventories ande amine integrity of pac%aging.

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In addition to ensuring general inside security, processing security, and storage security, aFood Security $lan for meat and poultry processing facilities may also address ensuringgeneral outside security and shipping and receiving security. sta"lishment operatorsshould assess whether these goals are relevant to their operation and then designapproaches to efficiently and effectively accomplish them.

oal 7um"er 8 D nsure eneral ut side Security

#his goal addresses access to the esta"lishment "y unauthori'ed intruders. $otentialsecurity measures include perimeter control through the use of fencing, gates, guardstations, and %ey card access. ll entry ways, windows, vents, and delivery doc%sshould "e secured. terior lighting and closed circuit camera systems may also "eused.

eneral utside Security

Sample :ulnera"ilities $otential Security Measurespen perimeter, allowing access

to facility

terior access to storage tan%s,silos, onsite trailers used for coldand dry storage

Secure all entry ways, windows, vents,

loading "ays, and other access points.

Fence e terior access points to storagestructures. Secure all access points,including loading and sampling ports.Install e terior lighting. -se tamper evident loc%s or seals on trailers.

oal 7um"er ; D nsure Shipping and ?eceiving Security

#his goal addresses the need to ensure the integrity of the raw materials received andthe finished products shipped from the facility. $otential security measures include

purchasing raw materials only from recogni'ed vendors, esta"lishing controls onincoming deliveries, limiting driver access to the facility during deliveries, carefulinspection and inventory accounting of delivered materials, use of tamper+evident

pac%aging for finished products, and the use of tamper+evident seals on incomingand outgoing shipments.


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Shipping and ?eceiving Security

Sample :ulnera"ilities $otential Security Measures-nscheduled raw material deliveries $urchase materials only from

$roducts shipped in unsecured

recogni'ed vendors. ccept receipt of only scheduled deliveries. Inventory

pac%ages against manifest and order forms and e amine pac%age integrity.?e&uire vendors to ship materials intamper+evident pac%aging.

ll truc% shipments should "e securedtruc%s, or multiple deliveries per "y use of tamper+evident seals. *riversshipment (less+than+truc%load) should "e trained and certified.

useful source for additional information on preventive measures is the set of recommendedminimum security standards for Federal facilities developed "y the -nited States MarshalsService of the -.S. *epartment of Hustice (* H 9CC;). #his report recogni'es that the

security needs of Federal facilities are influenced "y a range of factors, including num"er ofemployees, use, the need for pu"lic access, agency mission, crime statistics and threatintelligence. Standards have "een recommended for facility perimeter security, entry security,interior security, and security planning.

Step ! D Implement the $lan

nce the Food Security $lan is developed, it should "e tested and implemented. Geyelements of implementation include assigning responsi"ilities, training staff, conductingdrills, developing contact lists, and creating a recall plan.

ssign ?esponsi"ilitiesIndividual security responsi"ilities should "e defined and documented. ssignoverall responsi"ility for food security to a single employee who has anunderstanding of the security re&uirements for the facility.

#rain Facil ity Staff on lements of the $lan #rain facility staff in all provisions of the plan. #he purpose of security awareness training is to ensure that employees%now their food security responsi"ilities. #raining should address "adging and access control

procedures, access to restricted areas, protection of critical components, and procedures forreporting suspicious activities. -nderstanding the threat of intentional adulteration and the

potential conse&uences should help employees consistently e ecute preventive measures,increasing the overall effectiveness of the plan.


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/onduct *rills and ?evise $lan/onduct drills regularly to test and verify the effectiveness of the plan anddocument lessons learned. /ontinually review policies and procedures in the

plan for process improvements. ?evise the plan as needed to address changingconditions.

*evelop /ontact Bists/urrent local, State and Federal government 6omeland Security contacts and

pu"lic health officials should "e listed in the plan. Bocal law enforcement andF=I offices should also "e included in the contact list. #his list should "eupdated regularly. $rocedures for notifying appropriate law enforcement and

pu"lic health officials when a food security threat is received, or when evidenceof actual product tampering is o"served, should "e detailed in the plan.

*evelop a ?ecall $lan Food Security $lan should include details on how to conduct a recall of

adulterated products from trade and consumer channels. Safe handling anddisposal of products contaminated with threat agents should also "e included inthe plan.

sample food security plan for a meat processing facility is presented in ppendi =.

?eferences /ited

*epartment of nergy. 9CC>. 6a'ard and =arrier nalysis uidance *ocument. -.S.*epartment of nergy, 6+!!, ffice of perating perience nalysis and Feed"ac%.

?ev. 0. 7ovem"er 9CC>.*epartment of Hustice. 9CC;. :ulnera"ility ssessment of Federal Facilities. -nitedStates Marshals Service, -.S. *epartment of Hustice. Hune 2@, 9CC;.


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#6IS $ I7# 7#I 7 BBJ B F# =B 7G


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ppendi + Food Security ssessments

A food security vulnerability assessment is processing, stora ge, or d istribution facilities to evaluate th e p oten tial vulnerabilities of t heiroperations t o tampering or ot her malicious act s. Based on the results of the assessm ent,

corrective act ions can be t aken to redu ce t he ri sk of product adulteration. The assess mentserves as a guide b y identifying t he n eed for secu rity u pgrades, modications of operationalprocedures, and/or p olicy ch anges t o m itigate t he u nique vu lnerabilities at a sp ecicestablishment.

The elements of a food security assessment include:

Characteri ze f acility operations Identify a nd prioritize p otential adverse con sequences Determine cri tical production components t hat m ight be su bject to criminal actions Evaluate existing preventive m easures an d the n eed for ad ditional countermeasures Develop a prioritized plan for co rrective a ctions t o reduce o r m itigate p otential

vulnerabilities

y#a"le +9. lements of a Food Securit ssessment

Basic ElementPoints to ConsiderCharacterize facility operations Develop asimple diagram that shows t he st epsthe company uses when it processes the product,or use the owchart developed for the HACCPPlan. Consider acces s t o the facility a nd theproduct at each step. Figure A-1 is an example of

a generic process ow diagram for m eat andpoultry p rocessing. Operations to con siderinclude:

Receipt of raw materials Storage of raw materials an d nished

products Processing Shipping of nished products

adverse consequences

consequences m ay include:

Identify and prioritize potential Factors toconsider in assessi ng potential

Number of product servingscontaminated

Economic impact (loss of revenue) Damage to brand name

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Table A-1. Elements of a Food Security Assessment (continued)Basic Element Points to Consider

Determine cri tical components t hatmight be su bject to cri minal actions

Where in the production process are criminalactions m ost l ikely t o o ccur?

Receipt of raw materials Cold and dry st orage of raw materials Water supply Processing - grinding, emulsication,

solution injection Cleaning materials Transportation

Evaluate ex isting preventivemeasures an d the n eed for add itionalsecurity enh ancements

(Depending on cu rrent controlmeasures, some cr itical componentsmay a lready be su fficiently protected.

This step will help to identify agreatest con cern.)

What means does the facility currently employ todeter c riminal actions? Identify existing policiesand procedures for:

Perimeter security Access control Operating p rocedures a t critical

components Cleaning crews Vendor deliveries Storage secu rity Water security Person nel security, including con tractor

staff

Develop prioritized plan for ri skreduction

Strategi es for red ucing potential vulnerabilitiesgenerally fall into three b road categories:

Physical access c ontrols e. g., locks,tamper-evident seals, guards, cameras

Personnel controls e. g., awarenesstraining, background checks, employeeidentication badging

Operational controls - e. g., shipping an dreceiving procedures, recall plans


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Figure +9. eneric $rocess Flow *iagramfor Meat and $oultry $rocessing

9

$ac%agingBa"eling

K amples include

Model FoodSec Plan Processing

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