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Food Security Management

Development – To define detail, scope and purpose.

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Training participants will gain a basic understanding of Food Security Management and its applications within food safety and quality systems. Basic knowledge competency will be verified through successful completion of the accompanying Food Security Management assessment activity. Basic skill competency can be verified through the Food Security Management competency checklist available as a resource for this training activity.

Key Definitions for Food Security Management
- Contractor: A procured service or product provider within a food business premises.
- Economically Motivated Adulteration or EMA: Economically Motivated Adulteration is a Food Defence risk generally facilitated by the food manufacturer itself, with the intent of increasing profits or lowering production cost at the expense of public safety.
- Food Defence: Food Defence covers the methodologies applied to identify risk to food from acts of unsafe modifications or intentional adulteration.
- Food Fraud: Defined by the deliberate and intentional adulteration or unsafe modification of food, its ingredients or packaging, product information, labelling, or misleading statements made about a food product for economic gain that could negatively affect consumer health.
- Food Security Management: Food Security Management is about the methods implemented to ensure adequate and appropriate control of foods and related materials throughout the production and supply chain.
- HACCP: Hazard Analysis Critical Control Point or HACCP as it is commonly known, is a science based risk management system, relying on identification and recognition of specific hazards, and nominates measures for their control to ensure the safety of food.
- Product Recall: A product recall is a request to return to the manufacturer a batch or an entire production run of a product, usually due to the discovery of threatening safety issues.
- Product Withdrawal: A product withdrawal is a request to return to the manufacturer a batch or an entire production run of a product, usually due to the discovery of non-threatening quality issues.
- Visitor: An invited, expected, welcomed or accommodated visitor to a food business premises.
- TACCP: Threat Assessment Critical Control Point or TACCP is concerned with the prevention of deliberate and intentional food adulteration. Where VACCP focuses on discussing the vulnerability of multiple points, TACCP specifically identifies the threat of economically motivated food adulteration.
- VACCP: Vulnerability Assessment and Critical Control Point System or VACCP is the application of the HACCP system particularly to incidents of food fraud. This system helps identify the vulnerability of various points in the supply chain particularly due to the possible threat of economically-motivated adulteration.

Food Security Management Development
When considering the development, documentation and implementation of Food Security Management within food safety and quality management systems, the following information should be considered to ensure effective outcomes:

About Food Security Management
Security is a critical issue for every food industry sector. It is important to consider the potential for people to influence the safety or quality of a food product if the environment and conditions under which it is produced, handled, stored or transported are not appropriately controlled.

Food Security Management generally involves the control of potential deliberate contamination of foods by a variety of potential threats including biological, chemical and physical hazards. Deliberate contamination is a criminal action that involves wilful intent to inflict harm. The motivation for deliberate contamination often includes the ability to cause serious illness and deaths following consumption of adulterated product. This is aligned with the desire to cause economic damage whilst including inspiring fear among the public and loss of confidence in the safety of food supply.

Food security should always be considered as a separate element from food safety, though element of the two may be shared when applied to a food business. Food safety generally addresses the “unintentional” contamination of food products by biological, chemical or physical hazards. Because of the differences in applications for food safety and food security, a HACCP Plan should not be applied as a substitute for a food security plan; however, the HACCP methodology is commonly used as a risk assessment tool to define food security related risks.

Food Security Management may include the following aspects:
- Screening of staff members prior to beginning work at a food business;
- Using a system which allows tracking of staff movements;
- Video surveillance;
- Securing of the food premises, to ensure only authorised staff, visitors and contractors access specified areas;
- Using a visitor book to track the movements of visitors and contractors;
- Facilitating visitor and contractor screening and induction training.

It is important when initiating some of the above mentioned components, that the rights of staff, visitors and contractors are not compromised. The requirements of Privacy legislation are commonly used as a basis for the implementation of systems which track people’s movements, especially where the use of video surveillance is concerned.

Who May Want to Contaminate Foods?
When evaluating the potential food security exposure of any food business, the Senior Management should consider a large variety of people who may potentially execute an attack from both inside and outside the business operation. Potential attacks may include both opportunistic attacks by single individuals and planned attacks by organized groups. The following listing provides some examples of people who may be motivated to adulterate food products from both internal and external sources:
- Internal Sources
- Disgruntled employee;
- Visitors or Contractors;
- Temporary or casual employees;
- Members of organized groups posing as employees.

External Sources
- Organized groups;
- Transport drivers;
- Visitors or Contractors;
- Raw Material Suppliers.

Additional threats are often identified through internal sources as perpetrators often have access to food business procedures and protocols that may make their goals more readily achievable. Food businesses should liaise with relevant regulatory authorities regarding potential local threats to their operation.

Food Security Management Risk Assessment
The following may be considered when conducting a food security risk assessment for your food business:

Define What Needs to be Protected
A clear understanding of potential threats and what needs to be protected will assist in ensuring that effective and appropriate control measures can be applied. It is important to identify the most vulnerable elements of any food business operation. Historical or current food security incidents built from within your business and externally can be used as resources to ensure you are considering an appropriate range of potential food security hazards.

Application of Food Security Management Controls
The application of Food Security Management control measure within any food business operation should be applied according to the defined severity of outcomes related to each nominated control measure. As with most business management systems, it is important to consider that the identified potential food security risks should be controlled in order from the one with the most severe potential outcomes, to the one with the least severe potential outcomes. This method generally facilitates a practical approach to resource allocation as applicable to each unique food business operation.

Contemporary Food Security Management protocols rely on a multi-layered approach in ensuring effective outcomes. A multi-layered approach, for example, may include elements such as:

Physical Security
Potential security measures include perimeter controls through the use of fencing, gates, guard stations, and key card or radio frequency emitting device access. All entry ways, windows, vents, and delivery docks should be secured. Exterior lighting and closed circuit camera systems may also be used.

Personnel Security
Staff training for Food Security Management. Logging of employee entry and exit is a common method for tracing staff movements within any food business operation.

Operational Security
Employment of internal or external security monitoring and reaction contractors or consultants, security cameras or security inspections. This may also include the application of central controls for service as air flow, water supply and, electricity, and nomination of supervision for contractors working within the operational areas of the food business.

Process Security
Maintaining control over access to the process and the application of Food Security Management procedures. This may include the application of tools such as Chemical Usage Inventories, which can track excessive or unauthorized chemical use which may potentially be used to deliberately contaminate foods. Receival, Dispatch and Transport security measures may include purchasing raw materials only from designated approved suppliers, establishing controls on incoming deliveries, limiting driver access to the food business during deliveries, thorough inspection and inventory accounting of delivered materials, use of tamper-evident packaging for finished products, and the use of tamper-evident seals on incoming and outgoing transport.

Product Security
Maintaining control over access to product and raw materials and the application of Food Security Management procedures. Raw Material and product storage areas security will protect against the intentional misuse of ingredients or non-food items as food adulterants. Storage areas should be adequately secured and monitored, with access limited to authorized personnel only.

Using elements such as these allows for an approach which supports Food Security Management from across the entire food business operation.

Implementing a Food Security Management Plan
The following steps may be considered in the implementation of a Food Security Management plan:

Assign Responsibilities
Responsibility for Food Security Management should be designated and documented to an individual with a thorough understanding of the food business operation. Further delegations may include specific individual responsibilities for elements of the Food Security Management systems.

Food Security Management Training
All staff, visitors and contractors should be trained in relevant aspects of the Food Security Management system. The purpose of security awareness training is to ensure that all relevant people are aware of their Food Security Management responsibilities. Food Security Management training should address system requirements including identification badges, access control protocols, access to restricted areas, protection of critical Food Security Management risks and procedures for reporting suspicious or confirmed inappropriate activities. Understanding the threat of intentional contamination and the potential outcomes off such an incident should assist staff, visitors and contractors in ensuring the ongoing application of the prescribed Food Security Management control measures.

Induction Training
All staff involved with the handling of food must be trained to recognise and practice good manufacturing practices and safe working procedures at all times. It is generally considered best practice to ensure all new employees complete relevant induction training before actually starting within their new position. As a base level requirement, food and personal hygiene training should be addressed for all relevant staff during the induction process. Supervisory staff may be required to undertake specific and more comprehensive food safety training in the related areas.

Induction training commonly includes the following subjects:
- Company induction;
- Food hygiene and handling;
- Storage, handling and refrigeration;
- Food poisoning and foodborne illness including cause and effect examples;
- Food Processing procedures;
- Food preservation methods;
- Training, Competency and Resources Requirements ;
- Quality Policy;
- CCP monitoring and completion of records;
- Personal Hygiene;
- Basic HACCP;
- GMP;
- Food Security Management;
- Other industry sector specific requirements.

It is also important to consider that Visitors and Contractors may also require induction training commensurate with their interactions within any food business. Food business policies should define what induction, GMP and personal hygiene training are required for non-staff members entering the premises.

Conduct Mock Food Security Drills
Mock food security drills should be scheduled, conducted, recorded and reviewed on an ongoing basis to ensure the effectiveness of related procedures and protocols. The outcomes of such activities should be used to apply changes where non-conformance issues or opportunities for improvements are identified.

Develop Contact Listings
Current, regularly reviewed and updated contact listings should be maintained as an element of any Food Security Management plan. Contact listings should include names, positions, departments, addresses business and after hours phone numbers, email addresses and fax numbers for key internal food business contacts, customers, regulatory departments and officials. Contact listings should also include back-ups for instances in which the primary contacts can’t be made.

It is important to consider that an actual food security incident may very realistically lead to a food recall or food withdrawal. Procedures and flow processes should be clearly defined to ensure a food recall or food withdrawal is facilitated where required as an outcome of a food security incident.

Restricted Items in Specified Areas
There are many materials that are often prohibited in food production areas due to their potential for causing harm to consumers.

The presence of the following items in production, packaging, storage and handling areas is of major concern:
- Paper clips;
- Rubber bands;
- Thumb tacks;
- Pins, nails, screws;
- Steel wool;
- Wood: If wooden materials such as wooden pallets must be used, it is highly recommended that they be maintained in a good state of repair;
- Staples;
- Glass where applicable: May be unavoidable as light fittings and instruments, but can still be contained through common sense methods of control and management;
- Packaging containers: Can cause contamination during opening, either from external sources, or by parts of the packaging breaking loose, and contacting the food;
- Associated physical food hazards: Ingredients such as dried goods can be sifted or screened prior to use to reduce the possibility of foreign matter within the packaged or stored product being transported further into the production process.

Additional Relevant Information
The following information is provided from other foodindustrycompliance.com Training Activities as the content is relevant to Food Security Management:

Chemical Storage Segregation and Security
Chemicals used within food businesses must be properly stored and located with insecticides and rodenticides stored separately from cleaning compounds and other chemicals. All chemicals and pesticides must be stored separate from food, food contact surfaces and single-use and single-service articles. In this context, the term separate does not include storage of toxic chemicals above food, food contact surfaces, single-use and single-service articles.

The storage of chemicals must also meet local regulatory and environmental protection requirements.

Where necessary, adequate facilities for the storage and handling of food, ingredients and non-food chemicals including cleaning chemicals, pest control chemicals, lubricants and other maintenance chemicals must be provided.

Where appropriate, food storage and handling facilities should be designed and constructed to:
- Permit adequate maintenance and cleaning;
- Avoid pest access and harbourage;
- Enable food to be effectively protected from contamination during storage and handling;
- Where necessary, provide an environment that minimises the deterioration of food through controls including temperature and humidity.

The type of facilities required will depend on the nature of the food items being stored and handled by a food business. Where necessary, segregated and secure storage facilities should be provided for cleaning chemicals, pest control chemicals, lubricants and other maintenance chemicals. Storage facilities for ingredients, packaging and other materials should also be appropriately secured and adequately ventilated.

About Visitor and Contractor Management
It is paramount to food safety that visitors and contractors behave appropriately when visiting a food manufacturing business.  Any visitors and contractors on the premises and their actions are the responsibility of the management.

Visitors and contractors entering a food manufacturing, processing or handling area should, where appropriate, wear protective clothing and adhere to the other personal hygiene provisions in this section. A policy to this effect should be documented, and a copy provided to each contractor and visitor prior to entry the site.

It is generally considered standard practice for visitors and contractors to be signed into a food business, and identified by an appropriate badge. Visitors may also be required to review documented materials relating to the food safety and workplace health and safety before admission to critical areas of operation. Depending on the purpose of the visit, visitors, contractors and internal staff not attired appropriately may be required to wear a hygienic outer covering such as a fresh lab coat or full uniform while visiting food production areas. Visitors and contractors should be accompanied by an authorised staff member at all times unless they have conducted appropriate induction training and have passed established medical and security screening protocol.

As elements of established site security protocols, employees of the business should be encouraged through specified training to challenge anyone seen within operational areas of the site if they are not appropriately identified or accompanied by an authorised person.

Visitor and Contractor Training
For higher-risk or larger food businesses, it is common for a Visitor and Contractor induction process to be developed, documented and implemented to ensure the ongoing compliance of Visitors and Contractors to the food business. This is particularly important where, for example, maintenance contractors are used long term and are permitted to work unaccompanied within operational areas of the food business. In this context, it is important to consider that Visitors and Contractors, though they are expected to comply with the standard policies and procedures, may not totally appreciate their legal responsibilities in meeting such requirements.

In instances where, for example, maintenance contractors are used long term, it is also common for re-inductions to be scheduled, conducted and recorded to ensure ongoing compliance with the nominated Visitor and Contractor requirements.

It is also common for labour hire companies to conduct relevant training and induction processes on behalf of the company to which they will provide temporary staff. In this case, it is important that a food business is using labour supplied through a company responsible for relevant and induction training to verify and validate the facilitation and outcomes of such activities. This is commonly considered as an element of the approved supplier of service provider programs.

 About TACCP

The Threat Assessment Critical Control Point or TACCP should be used by food businesses as part of their general risk management processes. TACCP can also be used as a way of assessing risks systemically.

TACCP aims to:
- Decrease the odds of a deliberate attack; 
- Decrease the impact of an attack; 
- Protect the company’s reputation;
- Reassure the public, the media and especially customers that necessary steps have been taken to guarantee food protection;
- Surpass international expectations and provide support towards trading partners; and
- Show reasonable precautions are set in place in protecting food.

TACCP will accomplish this by:
- Identifying possible threats to the organization’s business;
- Studying the chances of an attack happening by considering the motives of the potential attacker, the vulnerabilities in a specific process, their capability as well as the numerous opportunities they have of carrying out the attack;
- Measuring the potential impact by considering a “what if they were successful?” scenario;
scoring the priority to be given to different threats based on impact and likelihood;
planning on setting the right type of barriers to hinder the attacker and provide early notification of an actual attack; and
- Ensuring information and intelligence systems are ready for possible revisions of priorities.

Though it is based on a structured and considered methodology, TACCP is not capable of stopping individuals or organizations who claimed to have adulterated the food. It is intended to be used as a Risk Assessment and Control Methodology. 

The Vulnerability Assessment Critical Control Point or VACCP is the systemic management of risk through evaluation of different kinds of vulnerabilities in the food supply chain. A vulnerability is defined as a state of being that can lead into an incident, an exposure to risk. It’s like leaving a window open. An open window makes your house more vulnerable to a break in than if you close your window. The act of you closing the window is the VACCP and the possibility of an attacker breaking your window to get inside anyway is what TACCP covers.

The key difference is the likelihood to contaminate or adulterate food. TACCP protects food from attackers who would contaminate the food regardless of any deterrent while VACCP concerns itself from the individual’s inexperience with handling a specific food product such as accidental spoilage, or product spills which could contaminate other food products.

You can find out more about TACCP and VACCP within the Food Defence element of foodindustrycompliance.com. 

If your food business supplies foodstuffs manufactured to a customer’s specifications, it is important to consider any specific Food Security Management Development requirements in relation to their items.

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