Checklists for All-Hazards Food Defense Planning

Military leaders have long known that an army “travels on its stomach,” which also is true of a nation’s civilian population. As such, one of the most important but less publicized responsibilities of political as well as military leaders is to protect their nations’ food supplies. Protecting this vital area of national preparedness and of daily living begins with a firm foundation on the basics of countermeasures – against agro-terrorism, foodborne illnesses, water degradation, bioterrorism, epidemiology, and zoonotic diseases.

Several U.S. federal agencies have the primary responsibility for certain aspects of food defense and response – for example, the Department of Agriculture’s Food Security Inspection Service (FSIS), the Department of Health and Human Services’ (HHS) Food and Drug Administration (FDA) and the Centers for Disease Control and Prevention (CDC), and the Department of Homeland Security’s Federal Emergency Management Agency (FEMA). Many other departments and agencies also participate – within their own primary areas of responsibility – in this collective effort, as well as during sudden emergencies. Voluntary planning documents, most of them prepared and distributed by FSIS, ensure there are effective measures in place to protect the nation’s food and food production processes from intentional harm.

Protecting Public Health & Economic Livelihood 

Simply by having and promulgating an effective and comprehensive Food Defense Plan ensures that farmers, producers, contractors, restaurants, and other food distributors can and will contribute both individually and collectively to a safer and more secure national food supply. The result, of course, will be improved protection for all citizens and public health employees, as well as greater economic livelihood of families, communities, businesses, and other essential components of the private, nonprofit, and public sectors. Functional food defense plans also: (a) guard against the risks posed by unsafe products and economic losses; (b) reduce theft and spoilage; (c) lessen the need for additional regulations on food defense; and (d) reduce potential liability claims.

The current U.S. food defense plan, which the FSIS composed and offered to the public as recommended guidance, is organized into four specific sections: Outside Security; Inside Security; Personnel Security; Incident Response Security. Of course, truly holistic food defense plans also should cover such related and crucial aspects of total preparedness as an emergency plan, a recall plan, and a security plan – all of which should be subjected to vigorous annual review processes. The overarching plan and numerous “sub-plans” should adhere to the following four principles of practical, effective planning: development, implementation, testing, and annual review and maintenance.

The following checklists encompass the principal guidelines and imperatives required to ensure the protection and preservation of the nation’s food supply. However, as with any chain, the nation’s food supply chain is only as strong as its weakest link. The following checklists describe measures that an organization may use to tailor a plan to meet the organization’s specific needs.

Outside Security Measures for Food Defense 

Physical Security

  • Establish clear and secure plant boundaries to prevent unauthorized entry (fences installed, as well as trespassing signs)
  • Secure entrances (locks, alarms)
  • Monitor plant perimeter for suspicious activity
  • Deter unauthorized activities with outside lighting
  • Secure windows and vents
  • Protect outside storage from unauthorized access
  • Ensure proper lighting is available, and in use, to monitor the establishment outdoors at night and in the early morning
  • Install self-locking doors and/or alarms on emergency exits
  • Ensure that premises are secured with locks, seals, and/or sensors when unattended (after hours/on weekends or holidays) to prevent unauthorized entry through outside doors, gates, windows, roof or vent openings, as well as tanker truck hatches, railcars, bulk storage tanks, silos, loading ports, and trailer bodies
  • Regularly conduct and document security inspections of storage facilities, including temporary storage vehicles
  • Restrict outdoor access to water wells/sources

Shipping/Receiving Security

  • Examine incoming shipments for potential tampering
  • Examine incoming and outgoing vehicles for suspicious activity
  • Schedule and/or monitor loading and unloading activities
  • Control, monitor, or lock loading-dock access to avoid unverified or unauthorized deliveries
  • Secure incoming shipments with locks or seals
  • Lock or seal outgoing shipments
  • Handle mail away from food, including ingredients and packaged food products
  • Ensure that employees who handle mail are aware of and follow the proper handling procedures required under U.S. Postal Service guidelines for suspicious mail
  • Closely monitor loading and unloading of vehicles transporting raw materials, finished products, or other materials used in food processing
  • Inspect tanker trucks and/or rail cars to detect the presence of any material – solid or liquid – in tanks before loading liquid products
  • Require advance notification from suppliers for all deliveries
  • Immediately investigate suspicious changes in shipping documents
  • Check all deliveries against a roster/planning list of scheduled deliveries
  • Hold unscheduled deliveries outside establishment premises pending verification
  • If off-hour delivery is accepted, require prior notice of the delivery and an authorized person to be present to verify and receive the delivery
  • Require incoming shipments of raw products, ingredients, and finished products to be sealed with tamper-evident or numbered, documented seals and verify the seals prior to entry – reject if seals are broken or missing
  • Select transportation companies and suppliers with consideration of their security measures
  • Examine returned goods at a separate location for evidence of tampering before salvage or rework
  • Maintain records on the disposition of returned goods
  • Require drivers and other delivery personnel to provideentification, complete with a photo – and record their names
  • Minimize the time a truck is unlocked during loading or delivery

Inside Security Measures

  • Report suspicious packages to appropriate authorities
  • Clearlyentify restricted areas
  • Check previously unattended materials before use
  • Report unexpected changes in inventory (product or equipment)
  • Ensure that emergency lighting is in place
  • Identify, test, and review an emergency alert system with emergency contacts (for example, police or fire personnel)
  • Install and monitor security cameras
  • Increase visibility within the establishment (improve lighting and openness, increase supervision, add cameras)
  • Regularly take inventory of keys to secured/sensitive areas of the establishment
  • Restrict access to controls (lock door/gate or limit access to designated employees) for heating, ventilation, and air conditioning (HVAC), propane, natural gas, water, electricity, disinfection systems, clean-in-place (CIP) systems, centralized chemical systems

Slaughter/Processing Area Security

  • Restrict access to live animals, ingredients, and packaged products
  • Control access to animal handling areas and/or carcass coolers
  • Restrict access to process-control equipment such as ovens and/or mixers
  • Examine ingredients for possible tampering
  • Ensure traceability of records for one step backward, one step forward, or both
  • Maintain records to allow the efficient tracing of materials and finished product
  • Reduce the time an area is left unmonitored
  • Reduce access to product containers or processing equipment
  • Do not allow unnecessary personal items within the production area

Storage Security

  • Restrict access to storage areas
  • Practice proper stock rotation (first in, first out)
  • Control labels and packaging materials
  • Require periodic examinations for tampering of materials in storage
  • Maintain an access log for product and ingredient storage areas
  • Regularly check the inventory of finished products for unexplained additions and withdrawals from existing stock
  • Restrict access to external storage facilities to designated employees only

Ingredients/Water/Ice Security

  • Restrict access to storage tanks for potable water and to water-reuse systems
  • Examine and restrict access points to lines that transfer water or ingredients
  • Control access to plant ice-making equipment
  • Control restricted ingredients (nitrites, for example)
  • Request supplier food safety/security information
  • Examine packages of ingredients before use for evidence of tampering
  • Restrict access to product, ingredient, and packaging storage areas to designated employees only, by locked door/gate
  • Ensure that water is from a municipally controlled source
  • Inspect water lines for possible tampering (perform visual inspection for integrity of infrastructure)
  • Make arrangements with local health officials to ensure immediate notification if potability of the public water supply is compromised

Chemical/Hazardous Material Control Security

  • Store chemicals/hazardous materials – including pesticides, cleaning, and/or laboratory materials, as well as sanitizers –in a restricted area or secure them with a lock
  • Maintain an up-to-date inventory of hazardous materials and chemicals, and of investigative discrepancies
  • Control potentially hazardous waste (biological or chemical) and dispose of it properly
  • Restrict access to the in-plant laboratory
  • Ensure that procedures are in place to control receipt of samples
  • Ensure that procedures are in place to receive, securely store, and dispose of reagents

Information Security

  • Control access points to sensitive information, site plans, and processing details
  • Protect access to computer systems through firewalls and/or passwords
  • Track customer complaints/comments for trends
  • Keep details of food defense procedures confidential as necessary
  • Have up-to-date and quickly available establishment layout/blueprints for local law enforcement – including, if needed, local fire/police departments

Personnel Security Measures 

Employee Security

  • Ensure that methods to recognize orentify employees in the facility are in place
  • Conduct background or reference checks for new hires
  • Restrict what employees can bring in or take out from the facility, such as cameras
  • Authorize appropriate employees to stop a process for significant concerns
  • Control access by employees and non-employees entering the establishment during both working and non-working hours, using coded doors, receptionist on duty, swipe cards
  • Restrict temporary employees and non-employees to areas relevant to their work
  • Implement system toentify personnel with their specific functions, assignments, or departments, with corresponding colored uniforms and/or hair covers
  • Prohibit employees from removing company-provided uniforms or protective gear from the premises
  • Maintain an updated roster for each shift
  • Non-Employee Security (visitors, contractors, guests, customers, truck drivers)
  • Maintain a log of non-employees entering the establishment
  • Establish a method to recognize orentify non-employees within the establishment
  • Chaperone non-employees on-site
  • Restrict non-employees to appropriate areas
  • Ensure that non-employees follow restrictions on what they can bring in or take away from the facility

Security Training

  • Provide awareness training on security measures to new employees
  • Offer refresher awareness training on security measures to employees on a periodic basis
  • Train employees to report suspicious activities or unusual observations
  • Follow requirements to electronically verify the employment eligibility of new hires (at http://www.dhs.gov/files/programs/gc_1185221678150.shtm) – E-verify, an internet-based system operated by the federal government, also is available for employers to use at no charge

Incident Response Security Measures

  • Ensure that adulterated or potentially harmful products are isolated and held in a protected area by having appropriate procedures in place
  • Investigate customer comments
  • Encourage the reporting of unusual activities
  • Provide information to employees on how to respond to phone or other threats
  • Enable employees to stop activities to minimize a potential food defense incident
  • Investigate reported security breaches (alarms, suspicion of tampering)
  • Establish and test effective evacuation procedures
  • Establish the procedures needed for responding to threats as well as actual product contamination events/incidents
  • Pre-establish communication with local, state, and federal incident response personnel

Emergency Contact Security Measures

  • Maintain current plant personnel contact information and emergency contact lists
  • Maintain and periodically review a product recall plan
  • Train key personnel in product recall/withdrawal procedures
Kay Goss
Kay C. Goss

Kay Goss has been the president of World Disaster Management since 2012. She is the former senior assistant to two state governors, coordinating fire service, emergency management, emergency medical services, public safety, and law enforcement for 12 years. She then served as the Associate Federal Emergency Management Agency (FEMA) Director for National Preparedness, Training, Higher Education, Exercises, and International Partnerships (presidential appointee, U.S. Senate confirmed unanimously). She was a private sector government contractor for 12 years at the Texas firm Electronic Data Systems as a senior emergency manager and homeland security advisor and SRA International’s director of emergency management services. She is a senior fellow at the National Academy for Public Administration and serves as a nonprofit leader on the Board of Advisors for DRONERESPONDERS International and for the Institute for Diversity and Inclusion in Emergency Management. She has also been a graduate professor of Emergency Management at the University of Nevada at Las Vegas for 16 years, İstanbul Technical University for 12 years, the MPA Programs Metropolitan College of New York for five years, and George Mason University. She has been a Certified Emergency Manager (CEM) for 25 years and a Featured International Association of Emergency Managers (IAEM) CEM Mentor for five years, and chair of the Training and Education Committee for six years, 2004-2010.

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