By Laurel Maloy, contributing writer, Food Online
Some companies may consider themselves more at risk than others. The truth is any food-processing facility is subject to the potential for intentional adulteration of its products
The Food Safety Modernization Act (FSMA) requires all foreign and domestic food-processing facilities to have a written food defense plan in place. That plan must address the preventive measures put in place to prevent malicious acts that could potentially cause “large-scale” public harm. The question you must evaluate is, “Do I have a system in place that will prevent intentionally harmful acts, on any scale?” The term “large-scale” is largely subjective.
Your written, food defense plan should already be in place, though with so many changes having to be made, many businesses are making those modifications in stages. With FSMA deadlines rapidly approaching, there is no better time than now to concentrate on your food defense plan, a not-so-little FSMA oversight.
A key place to begin your facility’s food defense plan is visitor access and controls. You could even title this portion Contractor and Visitor Access Control Procedures to reflect just. As you assess and reassess this part of your food defense plan, be sure to ask yourself these questions:
- Are there areas that should be off-limits to everyone but someone on the payroll?
- Are there areas that should only be accessed by top-level or thoroughly vetted employees?
- Who is responsible for monitoring or granting access to each area?
- Should visitors and/or contractors be escorted into all or some areas?
- How do you record visitors’ and contractors’ entrance into the plant, and then their forays into specific areas and activities within the plant?
- Do you have signage directing the activities of visitors and/or contractors?
- Is the parking lot monitored and/or gated, preventing unauthorized access, even during non-working hours?
- Do you require a visitor’s or contractor’s badge?
- How do you want employees to handle “strangers” in each area of the plant, i.e. on the production floor or in the break room?
- Do you have a sign-in and sign-out sheet designed to monitor both the entrance and exit?
- How do you report visitor and/or contractor accidents?
- What is the protocol for reporting suspected malicious activity, as it is happening or once it is discovered?
- Are bathroom facilities in sensitive areas? Should a public restroom be made available?
- Do you have a policy against firearms on the premises and how do you ensure compliance?
- What standard company policies and procedures are requirements for visitors as well?
If implementing a sign-in/sign-out procedure is part of your plan, assess the information you will want to collect. You may want to record their full name — ask for photo identification and/or make a copy — what company they represent, what their business is, and who they are there to visit. Be sure to keep good records of dates and times of both entrance and exit. If security cameras are not a part of your facility’s defense, the entrance and exits or where the sign-in procedure takes place may be the ideal location(s) for cameras. Also, consider the possibility of inside tampering. Keep all records in a safe place and in permanent ink. If you are in the habit of just keeping a hard copy, consider scanning the daily sheet into a computer file, and backing it up with the remainder of your files.
No one wants to think that people would intentionally adulterate a product to cause wide-spread illness and/or death. However, we all know that it happens and it can happen to your facility. Your facility is not immune; none are. This is why FSMA has addressed intentional adulteration, despite the FDA admitting it is “exceedingly rare.” There once was a time when no one would have thought the terrorist acts being carried out worldwide would become everyday news; and yet, they have.
FSMA has been signed into law and drafted in order to change the culture of food safety. The idea is to prevent foodborne outbreaks, as opposed to reacting to an incident after the fact. Unfortunately, we have to consider the very real possibility that the food supply could be utilized to spread terror and to wreak havoc. Designing a sensible and effective visitor access and control plan will protect your business, your brand, your product, your workforce, and the consumer.