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:
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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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