With the recent media reports of intentional adulteration and tampering of grocery store products, FDA has re-issued the guidance document, Food Security Preventive Measures Guidance for Retail Food Stores and Food Service Establishments, intended to remind industry of its role in and recommendations for preventing intentional adulteration and food tampering. The guidance has a sequential focus on each segment of the food delivery system within operators’ control, in order to minimize the risk at each segment. But because the guidance is intended to cover retail food stores and foodservice establishments of all types – from bakeries to commissaries, camps, daycare providers, fairs, and vending machines, etc., as well as grocery stores and restaurants – all aspects will not apply to all facilities, so operators need to review the guidance as relevant to the components of their operation, and assess which preventive measures are suitable. In all cases, however, FDA notes that it is important that both management and staff are committed to, and participate in the development, review, and implementation of, the food defense strategies. As such, the guidance includes recommendations for management, staff, public, the facility, and operations in both preparing for the possibility of and dealing with an actual event of tampering or other malicious, criminal, or terrorist actions. Following is a brief overview of each: Management. The recommendations cover preparation, investigation, and evaluation, focusing on conducting an initial assessment and assigning security staff, developing a crisis management strategy and response, and having a communication plan both for staff awareness and emergency response. Management also is responsible for investigating any threats and alerting applicable authorities, having an evaluation program to learn from previous threats, reviewing and verifying security effectiveness, randomly performing food defense inspections, and verifying effectiveness of security contractors, if applicable. Staff. As related to staff, it is critical that management conduct pre-, at, and post-hire screening of all staff as appropriate to their position and access to sensitive areas. Have and retain updated information on all workers, their worksites, and shift; establish a system of positive identification and collect all such information and access cards upon an employee’s departure; limit staff access to areas needed for their jobs; restrict personal items allowed in non-public areas of the facility and regularly inspect lockers, etc.; and train all in food security procedures. It also is important to watch for unusual or suspicious behavior by staff as well as atypical health conditions and absences that could indicate tampering or other threats. Public. Customers should be restricted from non-public areas of the facility; and all public areas should be monitored (particularly restroom entrances and self-service food serving or display areas) for suspicious activity. Only visitors with a valid reason should be allowed in non-public areas, and these persons and reasons should be verified. Additionally, any packages and briefcases taken into or out of non-public areas should be inspected to the extent practical. Facility. Exterior security to non-public areas should be implemented as appropriate (e.g., fencing, door/window locks, storage room locks, guards, monitored video surveillance, etc.) It also is recommended that the number of entrances to these areas be limited, vehicle access controlled, and lighting be adequate for security. Additionally, areas anywhere in the facility that an intruder could hide after hours or intentional contaminants be hidden should be minimized. The storage and use of poisonous and toxic chemicals in the facility should be limited to those that are necessary (or for sale), with all properly labeled, tracked, and securely stored away from food handling and storage with access restricted. Investigation should be made of any irregularities or missing stock. Operations. As the longest section of the guidance, FDA focuses on recommendations for incoming products, storage, foodservice and retail display, water/utility security, mail/packages, and computer system access. As with the other sections (detailed above) the key to all is primarily that of setting procedures to ensure you know what should be coming in, when, and who from; tracking all storage; having a system for returned or left-behind products; restricting access as applicable; checking products, mail, etc., for evidence of tampering; restricting computer access, tracking all use, and validating its virus and security systems For each of these, FDA has provided detail and examples for retailers and foodservice management to apply as fit their operations. For the full guidance and a list of additional resource, visit the FDA Guidance webpage. Because retail and foodservice facilities are intended to have public access, and the more that enter the establishment, the better business is, food defense strategies can be even more complex than that of food manufacturing establishments. But taking preventive steps, limiting access to non-public areas, knowing and securing your facility to the extent possible, and vetting all staff and visitors will go a long way toward keeping your business, product, and customer safe from intentional adulteration and tampering of your food. About The Acheson Group (TAG) Led by Former FDA Associate Commissioner for Foods Dr. David Acheson, TAG is a food safety consulting group that provides guidance and expertise worldwide for companies throughout the food supply chain. With in-depth industry knowledge combined with real-world experience, TAG’s team of food safety experts help companies more effectively mitigate risk, improve operational efficiencies, and ensure regulatory and standards compliance. www.AchesonGroup.com
