Food Defense and the Food Safety Modernization Act (FSMA)
Tools for securing your assets
Enforcement of the Food Safety Modernization Act (FSMA) has placed the spotlight on food defense, a collective term used to encompass activities associated with protecting the nation's food supply from deliberate or intentional acts of contamination or tampering (Source: FDA). Given the nature of the feed manufacturing and grain handling industries — industries where the products often make their way through a number of touch points and encounter numerous counterparties (farmer, transportation, ingredient suppliers, etc.,) — these agribusinesses face unique challenges in securing the safety of their products.
“The big risk is the insider on the supply chain,” says Bob Hayes, managing director, The Security Executive Council. “From farm to fork, there are a lot of insiders. These are elements some grain companies don’t think about vetting because they are only worried about their piece of the pie. Once they put it on a truck, they wipe their hands of it.”
Hayes suggests every business have a professionally conducted risk-threat-vulnerability analysis to determine the answers to these questions:
- What are the risks?
- What could happen?
- How would it happen?
- How serious would it be if it happened?
- How much am willing to spend to prevent it?
- Am I willing to live with residual risk — can live with the results of an incident or do you need more preventative measures?
“Make an effort to define your risk appetite,” he states. “There are three things you can do with risk: Accept it, off set it with insurance or mitigate it. Small businesses don’t do this until they’ve had a problem but then it’s too late.”
Tips for securing your facility
Don Hsieh, director of commercial and industrial marketing with Tyco Integrated Security Food Defense, suggests agribusinesses revisit the most vulnerable portions of their operation, specifically:
1) Coating, mixing, grinding, rework areas: These steps in any process can result in the even distribution of a contaminant and can cause greater damage rather than an isolated batch or load;
2) Ingredients staging: A stage in the process that provides access to the production stream;
3) Bulk liquid receiving and loading: There is a high probability of uniform mixing and distribution of a contaminant;
4) Bulk liquid storage or non-bulk liquid holding: Tanks tend to be kept in isolated areas, allowing for easy access for adulteration.
Hsieh suggests companies focus on perimeter security and strictly monitoring who is allowed to come onto the property and enter authorized areas.
“Companies should determine which employees have access to sensitive areas and who shouldn’t be there — including monitoring the people in loose proximity to those critical points; do they have the right to be there?” Hsieh says.
Taking a preventative stance
FSMA urges companies to put controls in place to focus efforts on prevention rather than reaction.
Many companies utilize gate controls and identification cards; however, within large facilities with are large and open spaces, a neferious individual may have free rein once they gain access — especially if the site has a lot of vendor or contactor traffic. Beyond standard control systems, companies can use technology to mark out virtual hot zones.
“Many times there aren’t doors or a physical barrier to control access, but these areas can be virtually marked with RFID technology so when an unauthorized person passes through, the designated parties receive an immediate alert," Hsieh explains.
In many cases the damage may be done, but if the company has taken proactive measures to be alerted to an incident, it can better deal with and limit the damage.
Remote video auditing and monitoring can also be an option for grain and feed facilities of various sizes.
“With today’s video protocols you can have staff specialize in monitoring areas of risk,” Hsieh says, noting that footage can be used to conduct sample audits to determine if FSMA-compliant procedures are being followed. “Not simply believing the company is in compliance, but management can move to knowing it’s in compliance based on these regular sample video audits.”
An added benefit: These videos can also be used for training and safety purposes.