Chapter 9 - Emergency Situations
9.7 Bio-terrorism or Tampering
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The food chain is a possible target for a bio-terrorist attack. This could be by introduction of an animal or plant disease or by chemical, biological, physical or radiological contamination of food or water.
Upon suspicion of a bio-terrorist or other food tampering situation, staff must bring the situation to the immediate attention of program specialists, the Regional Veterinary Officer or the Inspection Manager, and/or the security officer. Final responsibility for handling of the suspicious product(s) or material(s) rests with police officials or those equipped and trained to deal with hazardous materials.
Operators of food establishments are encouraged to review their current procedures and controls in light of the potential for tampering or criminal or terrorist actions and make appropriate improvements.
There are seven areas that relate to the individual components of a food establishment operation that should be reviewed and implemented by plant management:
- management of food security;
- physical security;
- computer systems;
- raw materials;
- packaging, operations; and
- finished products.
9.7.1 Management of Food Security
This entails assigning responsibility for security to qualified individual(s), encouraging all staff to be alert to any signs of tampering with product or equipment, other unusual situations, or areas that may be vulnerable to tampering, and alerting identified management about any unusual findings. Conduct a review of company procedures and facilities, shipping and distribution systems to identify vulnerable areas and outline control measures for each of these.
Management should immediately investigate all information about suspicious activity, and should provide an appropriate level of supervision to all employees, including cleaning and maintenance staff, contract workers, data entry and computer support staff, and especially new employees.
9.7.2 Physical Facility
Visitors, truck drivers and service staff must be controlled and access to food handling and storage areas must be restricted.
The perimeter of the establishment should be controlled with fencing or other appropriate deterrent, and doors and windows must be secure.
All access to the establishment should be restricted to authorized personnel, and hazardous chemicals must be stored away from food handling areas and must be locked.
A system for screening employees, especially new employees, should be instituted. Management must know who is and who should be on premises, and where they should be located.
All new employees should be provided with food security training, and a system of positive identification and recognition is desirable.
Access should be limited so employees enter only those areas necessary for their job functions, personal items (e.g., lunch containers, purses) must not be brought into food handling areas, and management should watch for suspicious behaviour by employees or by outside workers.
9.7.4 Computer Systems
Restrict access to computer process control systems and critical data systems to those with appropriate clearance.
9.7.5 Raw Materials and Packaging
The operator must use only known, appropriately licensed or approved sources for all ingredients, compressed gas, packaging, and labels, and inspect all incoming materials, and must have the ability to trace back all input materials. These requirements are all part of the HACCP Prerequisite Program.
Ensure the security of access to the sources of water and air, use tamper evident connectors and valves, and arrange periodic inspections. Develop procedures to ensure the integrity and security of manufacturing equipment.
9.7.7 Finished Products
Keep track of finished products and investigate missing or extra stock or other irregularities. Develop procedures and anti-tampering measures that will ensure the security and integrity of products once they are produced and shipped to retail.
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