Food Defense procedure example for a food company

Food Defense procedure: introduction

QAssurance also offers a simplified version, consisting of bullet points of the food defense procedure in the following Link

Food Defense procedure: Management

• Preparation for potential tampering or other malicious, criminal, or terrorist activity
• Responsibility for security is assigned to production management.
• The quality service adheres, by means of the HACCP team consultations, engaged in the implementation and validation procedures and activities with regard to food safety, which they must keep confidential.
• With the emergency plan, quarantine procedure, or incident reporting and recall procedure, our company has a security management strategy in place to prepare for and respond to tampering or other malicious, criminal or terroristic activities, threats, as well as actual events, including identifying, isolating and securing the affected product.
• The evacuation plan for the emergency evacuation has been drawn up, including the prevention of breaches of safety regulations during the evacuation.
• All floor plans and production schedules are kept in a secure location outside the company by means of the backup procedure at certified companies.
• We are familiar with the emergency aid system in the municipality.
• The recall procedure provides company management with 24-hour contact information for local, state, and nation police/fire/rescue / public health/security services.
• With the recall procedure, we inform employees who should notify management about any safety problems (24-hour contacts).
• With the company security procedure, HACCP training and staff knowledge * questions, we promote food safety awareness by urging all employees to be alert to any indications of tampering or other malicious, criminal or terroristic activities or points that are vulnerable to such activities and to report any findings to designated members of the management.
• With iMIS food and the operational consultation, we have an internal communication system to inform employees about and keep them informed of relevant safety issues.
• With the recall procedure, we have a strategy for communicating with the public (for example, appointing a spokesperson for the media, compiling generic press releases and background information, and coordinating press releases with the relevant authorities).

Food Defense procedure: Supervision

• With visitor registration, onboarding of new staff, and rounds of audits, all employees, including cleaning and maintenance personnel, subcontractors, data entry, computer maintenance personnel, and new employees, are appropriately supervised.
• With the food defense analysis, construction survey and photo reports, we perform routine safety inspections of buildings and sites, including automated production lines, gaslight, and water supplies, and essential computer data systems (with frequency offered by the nature of the work) evidence of tampering or other malicious, criminal or terroristic activity or items vulnerable to such activity.

Food Defense procedure: Recall strategy

• With the recall procedure, we have designated the person responsible for it and a deputy.
• With the recall procedure, we ensure the correct handling and disposal of recalled products.
• With the recall procedure, we record clients’ contact, addresses, and telephone numbers.

Investigation of suspicious activity

• With the HACCP team, we investigate threats or information about indications of tampering or other malicious, criminal, or terroristic activities.
• With the HACCP team, we alert appropriate law enforcement and public health authorities of any threats, suspected tampering, or other malicious, criminal or terroristic activity.

Food Defense procedure: Evaluation program

• Together with the HACCP team, we evaluate lessons learned in the past regarding tampering or other malicious, criminal or terroristic activities and threats. This is included in the management review.
• With the HACCP team, we review and verify at least once a year, through the food defense analysis, the effectiveness of the security management (for example, by making use of experts from in-house or outside it to conduct exercises regarding tampering or other malicious, criminal or terroristic activities and simulating recalls and testing of computer security systems) and updating the program accordingly, and keeping this information confidential.
• With the HACCP team, we conduct unannounced food safety inspections of all eligible locations within the company (including unloading areas and storage areas, where applicable) using in-house or external experts and keeping this information confidential.
• We verified with the HACCP team that they hired security officers to do their job correctly.

Food Defense procedure: Human factors – employees

When hiring new personnel, we verify whether all new employees to be hired are entitled to work in accordance with the provisions of the law.

Screening (before, during, and after employment)

The background of all employees (including seasonal workers, subcontractors, and volunteers, whether directly hired or through a recruitment agency) is examined as appropriate for their position, taking into account the access candidates would have to the company and the extent to which they will be monitored and other relevant factors (for example, obtaining and verifying job references, addresses and telephone numbers, conducting a criminal record investigation by the local police or a contracting firm).

Daily work assignments

• Through our personnel planning, we know who is on the company property and who should be there, as well as where they should be for every shift.
• Presence information is regularly updated.

Identification

• There is a positive identification and recognition system adapted to the workforce’s nature.
• All materials issues are withdrawn when an employee is no longer associated with the company.

Access restriction

• Employees who must have unlimited access to all company premises are known.
• The access levels of all employees are periodically reviewed.
• Employees may only enter those areas that are necessary for their task and only during normal working hours.
• All issued materials are withdrawn when an employee is no longer associated with the company.

Personal belongings

• Personal belongings that may be brought into the company are limited to the changing rooms/lockers. This is also laid down in our hygiene procedure.
• Only medication for personal use that is necessary for the health of employees is allowed. All medications for personal use are properly labelled and may not be present in production. This is also established in our hygiene procedure. Medicines are checked using the iMIS PDA patrols.
• Personal belongings may not be taken into production. This is checked using the iMIS PDA patrol and is laid down in our hygiene procedure.
• The contents of employee lockers are regularly inspected, as are bags, packages, and vehicles on company premises to the extent permitted by law. The registration takes place via the iMIS PDA patrols.

Training in food safety procedures

• With the company safety procedure, HACCP training, and personnel knowledge questions, we advance food safety awareness, including information on preventing, recognising, and responding to tampering or other malicious, criminal or terroristic activities or threats. This is done in employee training programs which include seasonal workers, temporary workers, subcontractors, and volunteers.
• With the company safety procedure, HACCP training, and personnel knowledge questions, we periodically highlight the importance of food safety procedures.
• With the company safety procedure, HACCP training, and personnel knowledge questions, we promote and encourage support from the staff.

Unusual behaviour

• We keep an eye out for unusual or suspicious behaviour from our employees.

Food Defense procedure: Human factors – the public

Visitors

• (For example, contractors, representatives of suppliers, delivery personnel, clients, couriers, representatives of extermination companies, accountants from outside the company, inspectors, reporters, and field trips)
• As much as practically enforceable, we inspect the incoming and outgoing vehicles, packages, and briefcases for suspicious, misplaced, or unusual objects or activities. Most checks are done at visitor registration, receipt of goods, and outgoing transport.
• Access to the company is restricted. All visitors must report and sign in following the procedure. Visits are always guided.
• The reason for the visit is provided before granting access to the company – take care of unsolicited visitors when necessary.
• The identity of unknown visitors is verified. In our company safety procedure and in training, attention is given to unknown visitors. Each staff member reports this to the manager.
• Access to locations where foodstuffs are processed or stored is limited. All visitors must report and sign in the following the procedure. Visits will always be guided.
• Access to changing rooms is limited.

Food Defense procedure: Company areas

Structural security

• The property is secured.
• All doors (including loading and unloading doors that are not in use and not monitored and emergency exits), windows, roof vents and roof hatches, vents, ventilation systems, storage areas, ice making and storage areas, attics, trailers, tankers, railway cars and storage tanks for liquids, solids, and compressed gas must be locked as much as possible. The lockup is checked with the iMIS PDA patrol.
• The outside doors are secured as well as possible and equipped with an alarm.
• The number of access roads to locations that are prohibited from unauthorized persons has been minimized.
• Unloaders are locked when not in use and are inspected prior to use.
• All issued keys are recorded in our crucial issue.
• The company premises are secured using appropriate methods.
• All places, where practical, that can be used to temporarily hide substances for deliberate contamination (for example, nooks and crannies, false ceilings) are minimized.
• There is adequate indoor and outdoor lighting, including emergency lighting, to facilitate the detection of suspicious or unusual activity.
• There is a management system for vehicles with a permit to park on the company premises.
• The parking spaces are not located near locations where foodstuffs are stored or processed or near gas, light, and water installations, where practical.

Laboratory security

• Access to the laboratory is limited.
• The laboratory material does not leave the laboratory except when necessary for sampling or other legitimate activities.
• Access to risk-bearing substances is limited.
• An expert has been appointed who is responsible for the integrity of positive control substances.
• The reagents and positive control substances must be present in the company, and their tracing has been recorded.
• An investigation is initiated immediately for missing reagents or positive control substances, or other irregularities outside a normal course variability. The appropriate law enforcement and public health agencies on unresolved issues, where appropriate, will be promptly notified.
• Disposal of excess reagents and positive controls is carried out to minimise the risk of them being used as a contaminant.

• Storage and use of poisonous and toxic chemicals (for example, cleaning and disinfecting agents, pesticides)
• Poisonous and toxic chemicals in our company, from what is needed for operation and maintenance of the company and what is kept in stock for sale, is limited.
• The storage of poisonous and toxic chemicals is as far away as possible from food production, and storage areas are practically possible.
• The storage areas for poisonous and toxic chemicals that are not held in stock for sale are locked up. Access is also limited. The securing of these areas is controlled by the iMIS PDA patrols.
• The poisonous and toxic chemicals are correctly labelled. This is checked on delivery and with the iMIS PDA patrols.
• Only approved insecticides and rodenticides are used. Pest control is outsourced to a specialized company. The MSDS has verified annually.
• All poisonous and toxic chemicals present in the company are recorded and traceable.
• Research into missing stocks or other irregularities outside a standard variability path is investigated in the stock count. Appropriate law enforcement and public health agencies will be notified of unresolved issues if necessary.

Business operations

Incoming materials and contractor work

• We only use recognized and approved suppliers of products and services. In accordance with our supplier and supplier assessment procedure.
• Our suppliers, contractors, and shipping agents take appropriate measures in practice with regard to food safety. In accordance with our supplier, supplier assessment, visitor, and hygiene measure procedures.
• All labelling, packaging configurations, and product coding/expiration date (where applicable) systems for incoming materials are coded prior to receiving the cargo, especially for new products.
• If necessary, we ask for closed and/or sealed vehicles/containers/rail cars, and, if sealed, we request the seal number from the supplier and verify upon receipt. When a seal is broken, for example, for an inspection by a government agency or as a result of multiple deliveries, we monitor the safety.
• We ask the freight forwarder to verify the location of the load at all times, where practicable.
• The delivery schedules are known. In case of delayed or missed shipments, an investigation is started, and deliveries or drivers are rejected.
• We monitor the unloading of incoming materials, including deliveries outside regular working hours. This is according to our receipt procedure.
• Upon receipt, the product and the quantity received are compared with the product and quantity as ordered and the product and quantity stated on the invoice and shipping documents, taking into account any sampling prior to receipt. This is also laid down in our procedure.
• Shipping documents with suspicious changes are being investigated.
• All incoming materials, including ingredients, compressed gas, packaging, labelling, returned products, and research & development materials for evidence of tempering, contamination or damage, or “counterfeiting” will be rejected.
• The control is verified and validated. This looks at the usefulness and whether the check has revealed indications of tampering.
• Suspicious foods are rejected.
• Designated law enforcement and public health agencies are notified of any discrepancies in regards to evidence of tampering, “counterfeiting”, or other malicious, criminal or terroristic activity.

Storage

• There is a procedure for receiving, storing, and handling dismounted, damaged, returned, and modified products to minimize their potential to be compromised or compromise the safety of other products.
• All incoming materials and materials in use including ingredients, compressed gas, packaging, labels, recycled products, modified products, and returned products are traceable. This is recorded in our tracking procedure.
• Missing or surplus stocks or other irregularities outside a normal course of variability are investigated. Unresolved issues are reported to appropriate law enforcement and public health agencies, where appropriate.
• Product labels are kept in a secure location. Outdated or discarded product labels are destroyed.
• Reuse of containers, transport packaging, cardboard and the like is minimized, where practicable.

Security of gas, light, and water supplies

• Access to control mechanisms for air circulation, water, electricity, and cooling is limited as much as possible.
• Non-municipal wells, standpipes, storage areas, and processing installations are secured.
• Water systems and tankers are equipped with backstops.
• Where practically possible, the water systems are chlorinated. And the chlorination equipment is monitored, especially for non-municipal water systems.
• Non-municipal sources are regularly tested for potability, also on the basis of random samples. We are alert to changes in the profile of the results.
• We remain attentive to any warnings in the media regarding public water supply problems, where applicable.
• We have alternative sources available for use during emergencies where common water systems are compromised. This is laid down in our emergency plan.

End products

• We have appropriate security measures at public storage companies and transport companies (vehicles and vessels).
• We perform unannounced inspections of storage areas, vehicles, and vessels.
• We evaluate the usefulness of testing finished products to reveal tampering or other malicious, criminal or terroristic activity.
• We request and/or sealed vehicles / containers / train wagons and forward the seal number to the recipient.
• We ask our shipping agent whether they have the capacity to verify the location of the load at all times.
• We determine the collection schedules and the rejection of collection.
• All our end products are traceable.
• We investigate missing or surplus supplies or other anomalies outside a normal course of variability and report unresolved issues to appropriate law enforcement and public health agencies as appropriate.
• Our sales personnel are trained to be on the lookout for counterfeit products and to alert company management of any discovery of problems.

Postal parcels

• Our FDA procedure ensures the safety of incoming letters and packages.

Access to computer systems

• Access to automated process control systems and essential data systems is limited to those with adequate privileges.
• When an employee is no longer associated with the company, access to the computer systems is revoked.
• We have a tracking system for computer transactions.
• We periodically evaluate the adequacy of anti-virus systems and procedures for backing up critical computer data systems.
• The security of the computer system is validated.