Security Threats

SECURITY THREATS

Management Should Consider:
Preparing for the possibility of tampering or other malicious, criminal, or terrorist events assigning responsibility for security to knowledgeable individual(s) conducting an initial assessment of food security procedures and operations, which we recommend be kept confidential having a crisis management strategy to prepare for and respond to tampering and other malicious, criminal, or terrorist actions, both threats and actual events, including identifying, segregating, and securing affected products planning for emergency evacuation.

Including preventing security breaches during evacuation becoming familiar with the emergency response system in the community making management aware of 24-hour contact information for local, state, and federal police/fire/rescue/health/homeland security agencies making staff aware of who in management they should alert about potential security problems (24-hour contacts) promoting food security awareness to encourage all staff to be alert to any signs of tampering or malicious, criminal, or terrorist actions or areas that may be vulnerable to such actions, and to report any findings to identified management.

For example, providing training, instituting a system of rewards, building security into job performance standards.

Having an internal communication system to inform and update staff about relevant security issues having a strategy for communicating with the public (for example, identifying a media spokesperson, preparing generic press statements and background information, and coordinating press statements with appropriate authorities)

Supervision

Providing an appropriate level of supervision to all staff, including cleaning and maintenance staff, contract workers, data entry and computer support staff, and especially, new staff (for example, supervisor on duty, periodic unannounced visits by supervisor, daily visits by supervisor, two staff on duty at same time, monitored video cameras, off-line review of video tapes, one-way and two-way windows, customer feedback to supervisor of unusual or suspicious behavior by staff.

Conducting routine security checks of the premises, including utilities and critical computer data systems (at a frequency appropriate to the operation) for signs of tampering or malicious, criminal, or terrorist actions, or areas that may be vulnerable to such actions

Investigation of suspicious activity

Investigating threats or information about signs of tampering or other malicious, criminal, or terrorist actions
Alerting appropriate law enforcement and public health authorities about any threats of or suspected tampering or other malicious, criminal, or terrorist actions

Evaluation program

Evaluating the lessons learned from past tampering or other malicious, criminal, or terrorist actions and threats reviewing and verifying, at least annually, the effectiveness of the security management program (for example, using knowledgeable in-house or third-party staff to conduct tampering or other malicious, criminal, or terrorist action exercises and to challenge computer security systems), revising accordingly (using third-party or in-house security expert, where possible), revising the program accordingly, and keeping this information confidential.

Performing random food security inspections of all appropriate areas of the facility (including receiving and storage areas, where applicable) using knowledgeable in-house or third-party staff, and keeping this information confidential

Verifying that security contractors are doing an appropriate job, when applicable.

Human element — employees

Under Federal law, retail food store and food service establishment operators are required to verify the employment eligibility of all new hires, in accordance with the requirements of the Immigration and Nationality Act, by completing the INS Employment Eligibility Verification Form (INS Form I-9). Completion of Form I-9 for new hires is required by 8 USC 1324a and nondiscrimination provisions governing the verification process are set forth at 1324b.

Screening (pre-hiring, at hiring, post-hiring)

Examining the background of all staff (including seasonal, temporary, contract, and volunteer staff, whether hired directly or through a recruitment firm) as appropriate to their position, considering candidates’ access to sensitive areas of the facility and the degree to which they will be supervised and other relevant factors.

Obtaining and verifying work references, addresses, and phone numbers, participating in one of the pilot programs managed by the Immigration and Naturalization Service and the Social Security Administration [These programs provide electronic confirmation of employment eligibility for newly hired employees. For more information call the INS SAVE Program toll free at 1-888-464-4218, fax a request for information to (202) 514-9981, or write to US/INS, SAVE Program, 425 I Street, NW, ULLICO-4th Floor, Washington, DC 20536.

These pilot programs may not be available in all states], having a criminal background check performed by local law enforcement or by a contract service provider [Remember to first consult any state or local laws that may apply to the performance of such checks])

Note: screening procedures should be applied equally to all staff, regardless of race, national origin, religion, and citizenship or immigration status.

Daily work assignments

Knowing who is and who should be on premises, and where they should be located, for each shift keeping information updated

Identification

Establishing a system of positive identification and recognition (for example, issuing uniforms, name tags, or photo identification badges with individual control numbers, color coded by area of authorized access), when appropriate

Collecting the uniforms, name tag, or identification badge when a staff member is no longer associated with the establishment

Restricted access

Identifying staff that require unlimited access to all areas of the facility reassessing levels of access for all staff periodically.

Limiting staff access to non-public areas so staff enter only those areas necessary for their job functions and only during appropriate work hours.
For example, using key cards or keyed or cipher locks for entry to sensitive areas, color coded uniforms [remember to consult any relevant federal, state, or local fire or occupational safety codes before making any changes]

Changing combinations, rekeying locks, and/or collecting the retired key card when a staff member who is in possession of these is no longer associated with the establishment, and additionally as needed to maintain security

Personal items

Restricting the type of personal items allowed in non-public areas of the establishment
allowing in the non-public areas of the establishment only those personal use medicines that are necessary for the health of staff (other than those being stored or displayed for retail sale).

Ensuring that these personal use medicines are properly labeled and stored away from stored food and food preparation areas.
Preventing staff from bringing personal items (for example, lunch containers, purses) into nonpublic food preparation or storage areas.

Providing for regular inspection of contents of staff lockers (for example, providing metal mesh lockers, company issued locks), bags, packages, and vehicles when on company property (Remember to first consult any federal, state, or local laws that may relate to such inspections)

Training in food security procedures

Incorporating food security awareness, including information on how to prevent, detect, and respond to tampering or other malicious, criminal, or terrorist actions or threats, into training programs for staff, including seasonal, temporary, contract, and volunteer staff

Providing periodic reminders of the importance of security procedures (for example, scheduling meetings, providing brochures, payroll stuffers)

Encouraging staff support (for example, involving staff in food security planning and the food security awareness program, demonstrating the importance of security procedures to the staff)

Encouraging staff support (for example, involving staff in food security planning and the food security awareness program, demonstrating the importance of security procedures to the staff)

Unusual behavior

Watching for unusual or suspicious behavior by staff.
For example, staff who, without an identifiable purpose, stay unusually late after the end of their shift, arrive unusually early, access files/information/areas of the facility outside of the areas of their responsibility; remove documents from the facility; ask questions on sensitive subjects; bring cameras to work)

Staff health

Being alert for atypical staff health conditions that staff may voluntarily report and absences that could be an early indicator of tampering or other malicious, criminal, or terrorist actions

For example, an unusual number of staff who work in the same part of the facility reporting similar symptoms within a short time frame), and reporting such conditions to local health authorities

Human element — public
Customers

Preventing access to food preparation and storage and dish washing areas in the non-public areas of the establishment, including loading docks

Monitoring public areas, including entrances to public restrooms (for example, using security guards, monitored video cameras, one-way and two-way windows, placement of employee workstations for optimum visibility) for unusual or suspicious activity

For example, a customer returning a product to the shelf that he/she brought into the store, spending an unusual amount of time in one area of the store)

Monitoring the serving or display of foods in self-service areas (for example, salad bars, condiments, open bulk containers, produce display areas, doughnut/bagel cases)

Other visitors (for example, contractors, sales representatives, delivery drivers, couriers, pest control representatives, third-party auditors, regulators, reporters, tours)

Restricting entry to the non-public areas of the establishment (for example, checking visitors in and out before entering the non-public areas, requiring proof of identity, issuing visitors badges that are collected upon departure, accompanying visitors)

Ensuring that there is a valid reason for all visits to the non-public areas of the establishment before providing access to the facility – beware of unsolicited visitors

Verifying the identity of unknown visitors to the non-public areas of the establishment
inspecting incoming and outgoing packages and briefcases in the non-public areas of the establishment for suspicious, inappropriate or unusual items, to the extent practical

Facility
Physical security

Protecting non-public perimeter access with fencing or other deterrent, when appropriate
securing doors (including freight loading doors, when not in use and not being monitored, and emergency exits), windows, roof openings/hatches, vent openings, ventilation systems, utility rooms, ice manufacturing and storage rooms, loft areas and trailer bodies, and bulk storage tanks for liquids, solids and compressed gases to the extent possible.

For example, using locks, “jimmy plates,” seals, alarms, intrusion detection sensors, guards, monitored video surveillance [remember to consult any relevant federal, state, or local fire or occupational safety codes before making any changes])

Using metal or metal-clad exterior doors to the extent possible when the facility is not in operation, except where visibility from public thoroughfares is an intended deterrent (remember to consult any relevant federal, state, or local fire or occupational safety codes before making any changes)

Minimizing the number of entrances to non-public areas (remember to consult any relevant federal, state, or local fire or occupational safety codes before making any changes)
accounting for all keys to establishment (for example, assigning responsibility for issuing, tracking, and retrieving keys)

Monitoring the security of the premises using appropriate methods (for example, using security patrols [uniformed and/or plain-clothed], monitored video surveillance)

Minimizing, to the extent practical, places in public areas that an intruder could remain unseen after work hours
Minimizing, to the extent practical, places in non-public areas that can be used to temporarily hide intentional contaminants (for example, minimizing nooks and crannies, false ceilings)

Providing adequate interior and exterior lighting, including emergency lighting, where appropriate, to facilitate detection of suspicious or unusual activity

Implementing a system of controlling vehicles authorized to park in the non-public parking areas (for example, using placards, decals, key cards, keyed or cipher locks, issuing passes for specific areas and times to visitors’ vehicles)

Keeping customer, employee, and visitor parking areas separated from entrances to non-public areas, where practical

Storage and use of poisonous and toxic chemicals (for example, cleaning and sanitizing agents, pesticides) in non-public areas

Limiting poisonous and toxic chemicals in the establishment to those that are required for the operation and maintenance of the facility and those that are being stored or displayed for retail sale

Storing poisonous and toxic chemicals as far away from food handling and food storage areas as practical

Limiting access to and securing storage areas for poisonous or toxic chemicals that are not being held for retail sale (for example, using keyed or cipher locks, key cards, seals, alarms, intrusion detection sensors, guards, monitored video surveillance [remember to consult any relevant federal, state, or local fire codes before making any changes])

Ensuring that poisonous and toxic chemicals are properly labeled
Using pesticides in accordance with the Federal Insecticide, Fungicide, and Rodenticide Act (for example, maintaining rodent bait that is in use in covered, tamper-resistant bait stations)

Knowing what poisonous and toxic chemicals should be on the premises and keeping track of them

Investigating missing stock or other irregularities outside a normal range of variation and Alerting local enforcement and public health agencies about unresolved problems, when

appropriate
Operations
Incoming products

Using only known and appropriately licensed or permitted (where applicable) sources for all incoming products

Informing suppliers, distributors, and transporters about FDA’s food security guidance, “Food Producers, Processors, and Transporters: Food Security Preventive Measures Guidance” and “Importers and Filers: Food Security Preventive Measures Guidance,” available at: http://www.cfsan.fda.gov/~dms/guidance.html.

Taking steps to ensure that delivery vehicles are appropriately secured
requesting that transporters have the capability to verify the location of the load at any time, when practical

Establishing delivery schedules, not accepting unexplained, unscheduled deliveries or drivers, and investigating delayed or missed shipments

Supervising off-loading of incoming materials, including off hour deliveries
reconciling the product and amount received with the product and amount ordered and the product and amount listed on the invoice and shipping documents, taking into account any Sampling performed prior to receipt

Investigating shipping documents with suspicious alterations
inspecting incoming products and product returns for signs of tampering, contamination, or damage (for example, abnormal powders, liquids, stains, or odors, evidence of resealing, compromised tamper-evident packaging) or “counterfeiting” (for example, inappropriate or mismatched product identity, labeling, product lot coding or specifications, absence of tamper-evident packaging when the label contains a tamper-evident notice), when appropriate rejecting suspect food

Alerting appropriate law enforcement and public health authorities about evidence of tampering, “counterfeiting,” or other malicious, criminal, or terrorist action

Storage

Having a system for receiving, storing, and handling distressed, damaged, and returned products, and products left at checkout counters, that minimizes their potential for being compromised

For example, obtaining the reason for return and requiring proof of identity of the individual returning the product, examining returned or abandoned items for signs of tampering, not reselling returned or abandoned products

Keeping track of incoming products, materials in use, salvage products, and returned products

Investigating missing or extra stock or other irregularities outside a normal range of variability and reporting unresolved problems to appropriate law enforcement and public health authorities, when appropriate
Minimizing reuse of containers, shipping packages, cartons, etc., where practical

Food service and retail display

Displaying poisonous and toxic chemicals for retail sale in a location where they can be easily monitored

For example, visible by staff at their work stations, windows, video monitoring)
periodically checking products displayed for retail sale for evidence of tampering or other malicious, criminal, or terrorist action (for example, checking for off-condition appearance

For example, stained, leaking, damaged packages, missing or mismatched labels], proper stock rotation, evidence of resealing, condition of tamper-evident packaging, where applicable, presence of empty food packaging or other debris on the shelving), to the extent practical

Monitoring self-service areas (for example, salad bars, condiments, open bulk containers, produce display areas, doughnut/bagel cases) for evidence of tampering or other malicious, criminal, or terrorist action

Security of water and utilities

Limiting, to the extent practical, access to controls for airflow, water, electricity, and refrigeration
Securing non-municipal water wells, hydrants, storage, and handling facilities
ensuring that water systems and trucks are equipped with backflow prevention

Chlorinating non-municipal water systems and monitoring chlorination equipment and chlorine levels
Testing non-municipal sources for potability regularly, as well as randomly, and being alert to changes in the profile of the results

Staying attentive to the potential for media alerts about public water provider problems, when applicable

Identifying alternate sources of potable water for use during emergency situations where normal water systems have been compromised (for example, bottled water, trucking from an approved source, treating onsite or maintaining onsite storage)

Mail/packages

Implementing procedures to ensure the security of incoming mail and packages

Access to computer systems

Restricting access to critical computer data systems to those with appropriate clearance

For example, using passwords, firewalls)
Eliminating computer access when a staff member is no longer associated with the establishment
Establishing a system of traceability of computer transactions
Reviewing the adequacy of virus protection systems and procedures for backing up critical computer-based data systems
Validating the computer security system

Emergency Point of Contact:

U.S. Food and Drug Administration
5600 Fishers Lane
Rockville, MD 20857
301-443-1240

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