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Developing response plan instructions

Through the countermeasures that you have already developed you can reduce the risk of intentional contamination, but you cannot prevent it. Like Boy Scouts, you need to be prepared. Any operation which has experienced an emergency – as a result of intentional contamination or the aftermath of severe weather – can tell you that getting back into operation as quickly as possible is the key to staying afloat. If you have plans prepared ahead of time, your response will be faster and more efficient. As you begin to prepare your response plan, you will want to have your facility map on hand and as well as contact information for your suppliers, customers, and local emergency responders. Any operational plans (i.e. HACCP, SOP’s, BMP, BQA or PQA) that you have may have information valuable to your response plan such as regulatory agency numbers, emergency protocols etc. To contain and minimize any emergency situation, understanding the order in which things need to happen is critical.

Containment
If you have had possible intentional contamination, the first step needs to be containment. Hold all product/animals that may have been affected. In your plan, identify a location within your facility where you can contain potentially contaminated food or livestock, separate from animals or products that are not contaminated. For a livestock operation, you will also need to plan for how you will care for the animals while contained. Your response plan should also include a contact who can determine whether or not the food/or livestock you contained are indeed contaminated.

Diagnosis
To understand the response needed, you are going to have to diagnose exactly what contaminant has been used and how. It is important that you make contact as soon as possible with the right person who can do that, and having a set of emergency numbers handy will move the process much more quickly. The telephone numbers to keep on hand will vary depending on your operation and its location. If you have issues with livestock, the first call will be to your veterinarian, while a food processing plant will want to begin with a food inspector (i.e. FSIS for meat, or FDA for other foods).

Recall
Contaminated food or livestock that have already left the facility will need to be “recalled” and contained. To effectively recall your products, you are going to have to know where all of the food or livestock have gone. Keeping reliable information on your suppliers and customers and processing lots will make this much easier!. HACCP plans or similar operational documents will contain information related to trace forward/trace back which is a requirement for food processors. Recalls often result from contamination that has been unwittingly passed on to you by suppliers, thus, you need to prepare for that possibility in your response plan.

Disposal
If there truly is contamination the livestock or food must not be allowed to enter the food chain. As part of your response plan, you will need to plan for disposal of contaminated livestock or food products. Regulatory agencies like FSIS or FDA are valuable sources to help determine what type of disposal will be needed and who will need to sign off on the plan before the food can be disposed of. For livestock, you will need to plan for euthanasia as well as disposal. Again, the methods used will depend on the type of contaminant involved and recommendations will be made by the veterinarian or emergency management official in charge. The following are websites that contain resources that will be helpful if you need to dispose of contaminated livestock or food.

Facility map
A map of your operation or facility will be vital to emergency responders in any situation. You need to identify and provide contact information for the owner/operator of the facility. It is also important to show the relationship of your operation and/or facility in relationship to other properties, structures or environmental landmarks (e.g. streams, water sources); identify road access, transportation routes, perimeter boundaries, and gates with dimensions; show locations of utilities, septic and sewer systems; and clearly show buildings, including doors/windows and outbuildings, as well as building systems (e.g. ventilation, air conditioning, heating etc.).

Containment and disposal form
The questions on this form are designed to help with the processes and planning for handling contaminated or potentially contaminated livestock or food products.

For retail food sales and food service, FDA and or health inspectors will have input regarding disposal, and decontamination. SEMA and DHS may also have some input on these procedures depending on the situation. Again, advance planning is crucial for your business to respond quickly.

For food processors, having plans in place to notify consumers and retailers in case a recall is required will make the process more efficient and will limit the damage to your operation. Government regulation of recalls is currently changing. For the most recent information on recall regulations, check with FDA food safety website or FSIS regulations and policies Web page. FDA or FSIS will also have input regarding disposal and decontamination. They will likely submit samples for testing in order to find the specific contaminant. SEMA and DHS may also have some input on these procedures depending on the specific situation.

For livestock operations, the local veterinarian and the state veterinarian will work to determine the specific contaminant and from there will make recommendations regarding quarantine, euthanasia, disposal and decontamination. USDA, SEMS and DHS may also have some input on these procedures depending on the situation.

Map

Emergency phone list
The numbers contained here will vary with location and type of operation, but in general should include the following categories: Emergency responders (including Sheriff, Highway Patrol, Police, Fire, Hospital, and Poison Control); Utilities (including Electric, Water, Phone, and Gas); Regulatory Groups (including FSIS for meat, FDA for other food, APHIS for animals (the responding vet will likely start the chain of phone calls)); Other State Agencies (including Missouri Dept. of Health and Senior Services, Missouri State Emergency Management Agency, and Missouri Dept of Homeland Security).

Supplier/customer phone list
Most operations have a general sense of who sells to them or buys from them. To effectively respond to an emergency that is unfolding at a fast pace, you will need to be organized before it happens. Dig out the names and contact information for your suppliers and customers and get them together in a document that is easily accessible.


Employee emergency contacts
In an emergency you won’t have time to go through your employee’s files. You may have their numbers memorized, but that won’t help if no one else has that information. You can avoid panic by gathering the phone numbers and addresses and keeping them where you can access them quickly.

Copies of the response plan should be kept in more than one secure location, along with your food defense plan. If your operation has an office that would be a good spot for one copy, the other should be kept in a secure, but accessible location outside of your operation. If your residence is separate, from the facility, that would be a good location to keep a second copy.