[Best Practices] Staying ALERT

If you have been in the industry since 2001, you have witnessed an evolution in food protection from “just” food safety to food defense. You know that defending products from deliberate contamination is a critical aspect of product protection, but do you understand the issues related to food defense? Do you  know what to do to prevent intentional food contamination within your span of control and facilities? And, do you truly believe it could happen to you?

In an effort to assist industry in this area, the U.S. Food and Drug Administration (FDA) and the Department of Health and Human Services created a new Food Defense Awareness Initiative, ALERT, identifying five key areas of focus for decreasing the risk of intentional food contamination at food processing facilities. Earlier this year, FDA took it a step further, developing a Web-based training module for the initiative.

The training was developed to bring to light food defense issues and preparedness. As is explained in the program’s presentation, “When it comes to intentional food contamination, there is often a misguided notion that it won’t happen, but the truth is that it does happen. … The food supply chain is fragile and although there are strict regulations in place to address food safety, there are no current regulations to address food defense. Stakeholders in the food industry must put aside the notion that ‘it can’t happen to me’ and begin to think about how to protect their food businesses and industries from attacks on our food.”

The ALERT Food Defense Awareness module asks five questions intended to increase awareness that contamination can happen anywhere while also providing a basis for discussion of preventive measures and identification of elements for integration into a food defense plan. The module also includes an application activity for each of the five ALERT areas.

Use the following to assess your own facility and food defense initiatives:

How do you Assure that your supplies and ingredients are from safe and secure sources?

• Know your suppliers. Use only known, appropriately licensed, certified or permitted sources for all ingredients and supplies.
• Encourage suppliers to practice food defense measures. And confirm these through compliance audits or vendor approval programs.
• Request locked and/or sealed vehicles, containers or railcars. If a seal or lock is broken, have it inspected and trace back the chain of custody for protection.
• Supervise off-loading of incoming materials. Note any unusual changes in delivery routine or personnel. 

How do you Look after the security of products and ingredients in your facility?

• Implement a system for handling products. The goal of the system is to minimize their potential for being compromised or compromising other products.
• Track materials. This should include not only ingredients and supplies, but also salvaged and reworked products as well as returns.
• Store product labels in a secure location and destroy outdated or discarded product labels. This helps to ensure correct product labeling and prevent label tampering.
• Limit access and inspect facilities. In addition to limiting visitor access, sensitive areas within the facility should be accessible only by authorized persons.
• Keep track of finished products. Don’t assume that a finished and packaged product is safe from tampering.
• Encourage your warehousing operations to practice food defense measures. Audit public warehousing for food security compliance.

What do you know about your Employees and visitors?

• Conduct background checks on staff, including seasonal, temporary, contract and volunteers, with particular detail toward those who will have access to sensitive areas.
• Know who belongs in your facility and where they should be for each shift.
• Establish an employee identification system. Consider color-coded uniforms, photo IDs, individual control numbers — and collect all these items when a person ends employment for any reason.
• Limit staff access. Staff should be able to enter only areas necessary for their job functions.
• Prevent visitor access to critical facility areas. All non-public food preparation, storage, dishwashing and loading dock areas should be off limits to visitors.

Can you provide Reports on the security of your products while under your control?

• Periodically evaluate the effectiveness of your security management system. On at least an annual basis, review and verify your program, revise as needed — and keep all information confidential.
• Perform random food defense inspections. Use knowledgeable in-house or third-party staff, and, again, keep all information confidential.
• Establish and maintain records. This is, in fact, mandated by Section 306 of the Bioterrorism Act.
• Evaluate lessons learned. Knowing of and understanding any industry tampering or terrorist actions or threat can provide information for defense of your own product.

What do you do if you have a Threat, issue or suspicious activity at your plant?

• Hold any product that you believe may have been infected.
• Report threats or suspicions to local law enforcement officials.
• Then contact the 24-hour emergency number for the federal agency that regulates your product:
  USDA/Food Safety and Inspection Service (meat, poultry, eggs) — 866/395-9701
  Food and Drug Administration (all other products) — 301/443-1240

The author is Staff Editor at QA magazine.