FSMA Intentional Adulteration Rule
Site Security & Vulnerability Assessment
What is a site-specific security & vulnerability assessment?
A food facility food defense vulnerability assessment is a process by which The Global Food Defense Institute experts conducts a survey of your existing food defense measures, plans, policies and procedures and make recommendations to company management on those areas in which a risk of intentional product tampering and the food defense of your personnel, products assets and people are considered. The goals are to assist management reduce, mitigate and manage potential food defense vulnerabilities. Additionally, the food defense assessment is strategically designed to assist plant management identify ways in which someone with ill intent and from one of the following categories, could cause harm to persons or interruption to business operations; Criminals, Terrorist, Protestors, Rogue or Disgruntled Insiders, Subversives. Our approach at conducting site specific vulnerability assessments is not just to provide a report, but to ensure that members of your food defense team and management are keenly aware of vulnerabilities and the consequences these risks may pose. Further, the assessment not only meets the requirements of the FDA/FSMA Intentional Adulteration Rule for food defense, but exceeds the recommendations in a practical, easy to understand, real-world format. Pictures and photo images are taken as part of the assessment as they are critical in showing the identified food defense concerns.
Key Activity Type; Actionable Process Step Hybrid Assessment
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Are all FDA recommended, Key Activity Type (KAT) areas reasonably secure to mitigate risk and intentional contamination to the products or ingredients?
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Are appropriate perimeter protection measures in place? This includes an examination of the exterior perimeter (fencing and gates) as well as the physical building protection measures.
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Is the outdoor lighting adequate especially under the cover of darkness? Is the lighting adequate for use with an outdoor surveillance camera?
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Are current security protocols adequate for identifying transportation and truck drivers, and are the drivers following existing procedures for pickup and delivery of products and ingredients?
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Are current security measures adequate to enable plant management to quickly identify and respond to possible breaches of security policy and procedures and to immediately react to hazards and other acts of suspicious behavior?
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Are perimeter doors, gates, window and docks secured and in good working condition?
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Identify deficiencies in facility security or protocols, and any events or threats that could potentially pose a threat to the business continuity brand image, and/or reputation of the company, or to products and people at the facility site, or to the wider public (collectively, “External Threats”). Further, by identifying these external threats, recommendations can be made to develop response measures, incident recovery and business restoration.
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Identification of internal exposures and self-induced threats, which could be potentially hazardous to the operations of the business (collectively, “Internal Threats and, together with External Threats, “Threats”). Examples of Internal Threats would be vulnerabilities in those protections in place to guard or mitigate events such as workplace violence, theft, or internet/intranet system compromise and breach.
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The site security analysis enhances the overall culture of security at the facility by allowing employees and management to develop the essential skills and build expertise in the area in which they work that focuses on security events that may affect the operations or personnel of the business.
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