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Developing countermeasures and the food defense plan instructions

Writing the food defense plan is an easy step once you have completed the vulnerability assessment worksheet. First you need to describe the specific element you considered to be non-secure, for example the driveway has no gate. Remember, not all risks can be minimized at a reasonable cost or effort. As you review the specific vulnerabilities you need to decide if it would be practical (e.g. reasonable and economical) to develop a countermeasure to reduce the risk for contamination by correcting that specific element. If the answer to the question of practicality is no you do not need to develop a countermeasure and you can stop for that specific element; if the answer is yes move on to countermeasure development (see example in table below).

Countermeasures are actions taken to shield vulnerable areas, thus reducing the risk of intentional contamination. They are measures taken to protect your people (family, workers, and customers), your product (reputation and livelihood) and your property (assets). The goal is to provide protection in the most economical ways possible. As a general rule of thumb, procedural changes are the most economical. For example, checking references of potential employees is easy to do and not very expensive. If procedural changes don’t fill the bill, the next most economical option will likely be technology. Can you find a technology (e.g. dusk to dawn lighting or a lock) that will reduce the risk of intentional contamination? If neither of those options will work for your operation, additional personnel may be needed which is the least economical option. Be free thinking and creative in countermeasure development and keep in mind the three L’s: light it, lock it, and limit access.

Do not underestimate the value of your family or employees as security agents. Training is the key here. They will need to know what you expect from them. An example of a very easy training program is SCAN, which stands for See, Challenge, Ask, and Notify. Instruct your employees (even if they are your family) that if they see an unfamiliar person on the premises they should challenge (not in a threatening manner, but face and make eye contact with the newcomer). They should then ask, “Can I help you?” The next step should be to notify you, a supervisor, or a manager. The initial training does not take long and can be reinforced easily.

Once the more obvious vulnerabilities and countermeasures have been addressed it is time to deal with some of the challenges presented with marketing. If you are niche-marketing (e.g. retained ownership cattle, organic grain), contract-marketing, or direct-marketing (e.g. farmers’ markets, retail outlets) any food liability issues must be considered. For example, who is liable for the livestock or vegetables while they are in transit or awaiting auction? We recommend a two pronged approach to liability, which we refer to as the double C’s. Check and Challenge are the two principles to consider. Check your contract (verbal or written) and negotiate the liability. The goal here is to make sure that you are liable only when the food is in your possession. Challenge means making it more difficult for anybody to contaminate your products. Presenting physical barriers (e.g. by adding layers to your packaging, using tamper resistant packaging, locking the trailer while in transit) or procedural barriers (e.g. working out transit details with your hauler that will reduce the risk to your cargo or supervising visitors constantly during tours).

It may be helpful to have your map and copies of any operational documents such as HACCP, SOP, BQA, or PQA available as you work through this section.

For each vulnerability you consider practical to address, write down a countermeasure and make sure to indicate who is responsible for implementing it. It is also important to specify a timeline for completion. Once the responsible person has completed implementing the countermeasure, make sure to initialize and date the plan. Viola! You now have a food defense plan that can stand alone or be added to any HACCP, BMP, BQA, PQA or other plans you may have.

See the table below for a sample food defense plan.

Completed by ____________________________________________ Date _______________
Q# Specific vulnerability Practical Yes/No Countermeasure Who will Implement Timeline to Implement Date completed
Initials*
1 Driveway has no gate Yes Add a gate at driveway Murray, Brangus and Angus 11/18/09 10/10/09
MGM
1 No exterior cameras No        
1 No signage on perimeter fence Yes Add “no trespassing” and “no hunting” signs to fence Murray, Brangus and Angus 6/18/09 7/20/09
AM
1 Perimeter fencing is not monitored regularly Yes Implement a schedule for monitoring fence line monthly Brangus and Angus

6/18/09

6/10/09
BM
2 Door for pharmaceutical and chemical storage not locked Yes Add lock to door and limit number of keys issued (family members only) Murray 6/18/09 11/15/09
MGM
3 Procedures for feeding, doctoring, processing cattle are not done in a secure manner No        
3 Visitor log Yes Implement a visitor log system Murray   10/15/09
MGM
4 Liability for cattle not in shipping and sellers agreement Yes Negotiate the agreement so liability for calves sold at auction is with hauler and then auction facility Murray 6/18/09 6/7/09
MGM
5 No inventory system for feed chemicals or pharmaceuticals Yes Develop and inventory system Murray 11/18/09 9/28/09
MGM
6 Well head is not locked Yes Lock well head Murray 11/18/09 9/15/09
MGM
6 Access to ponds not controlled No        
8 No security training for family Yes Familiarize family with SCAN and other security training Murray 11/18/09 10/2/09
MGM
9 Fences between farms don’t limit access to livestock No        
9 Feed is not stored in a lockable facility No        

Use this page to identify the specific vulnerabilities you need to consider (they should be circled on the previous worksheet.)

If the answer to is this practical is yes, then you will need to find a countermeasure, determine who will implement it and suggest a timetable for completion.

*Give a specific date for implementation