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Emergency Preparedness—
Food and Drug Administration Milk Security Guidelines

Food Security Preventive Measures Guidance
Management
Human Element
Facility

Food Security Preventive Measures Guidance

The FDA has released industry guidance which represents the FDA's current thinking on the kinds of measures that operators of dairy farms, bulk milk transportation operators, bulk milk transfer stations, and fluid milk processing facilities may take to minimize the risk that fluid milk under their control will be subject to tampering or other malicious, criminal, or terrorist actions. Only the portions that apply to dairy farm operators have been reprinted here. The FDA's guidance documents, including this guidance, do not establish legally enforceable responsibilities.

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Management

FDA recommends that operators consider:

  • Conducting an initial assessment of the adequacy of food security procedures and operations, which we recommend be kept confidential.
  • Developing a security 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 product.
  • Developing a product recall strategy.
  • Providing training in food security awareness to encourage all staff to be alert to any signs of tampering or other malicious, criminal, or terrorist actions, or areas that may be vulnerable to such actions, and report any findings to management. The training may also encourage staff to be alert to the presence of unidentified or unknown individuals or individuals that are in areas to which they are not designated access, and to directly question such individuals or report them to management.
  • Providing appropriate supervision to all staff with access to raw and unpasteurized milk storage, vitamin supplement receiving and storage, and milk processing and packaging areas of the facility, including cleaning, maintenance and quality control staff, seasonal, temporary, contract, and volunteer staff, and especially new staff. The supervision may include watching for unusual or suspicious behavior by staff (e.g. 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).
  • Conducting routine security checks of the raw and pasteurized milk storage, vitamin supplement receiving and storage, and milk processing and packaging areas of the facility, for signs of tampering or malicious, criminal, or terrorist actions, or areas that may be vulnerable to such actions.
  • Alerting appropriate law enforcement and public health authorities about any threats of or suspected tampering or other malicious, criminal, or terrorist actions. FDA may be contacted through its 24-hour emergency number, (301) 443-1240, or through a local FDA District Office.
  • Reviewing, at least annually, the effectiveness of the food security plan, using knowledgeable in-house or third party staff, and revising the program accordingly, which we recommend be kept confidential.

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Human Element

FDA recommends that operators consider:

  • Obtaining and verifying work references, addresses, and phone numbers of all staff with access to raw and pasteurized milk storage, vitamin supplement receiving and storage, and milk processing and packaging areas of the facility, including cleaning, maintenance and quality control staff, seasonal, temporary, contract, and volunteer staff.
  • Having a criminal background check performed by local law enforcement or by a contract service provider for the above listed staff, except if such staff are under direct supervision when they access the above listed areas.
  • Limiting access to raw and pasteurized milk storage, vitamin supplement receiving and storage, and milk processing and packaging areas of the facility to those staff that need to enter because of their job functions and only during appropriate work hours.
  • Preventing staff from bringing personal items (e.g. lunch containers, purses) into raw and pasteurized milk storage, vitamin supplement receiving and storage, and milk processing and packaging areas of the facility.
  • 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 (e.g. an unusual number of staff who work in the same part of the facility reporting similar symptoms within in a short time frame) and reporting such conditions to local health authorities.
  • Accompanying all visitors.

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Facility

FDA recommends that operators consider:

  • 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, loft areas, trailer bodies, tanker trucks, and bulk storage tanks, to the extent possible.
  • Inspecting bulk unloading equipment and pumps in the receiving area before use.
  • Monitoring the security of the premises.

FDA further recommends that operators of dairy farms consider:

  • Locking or sealing, with serially numbered seals, all entrances to the milk house or all entry ports on the bulk milk tank from the time the bulk milk tank is washed until the time it is emptied, except when it is under direct, visual supervision.

The complete guidance document can be found at "Guidance for Industry: Dairy Farms, Bulk Milk Transporters, Bulk Milk Transfer Stations and Fluid Milk Processors: Food Security Preventive Measures Guidance".

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Last modified October 06 2010 09:10 PM

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