July 2011

Page 1 of 3

Guidelines For Evaluation Elements

Evaluation Elements Guidance

1.

Does management have a Food Defense 

Plan that is implemented, and reassessed 

by management to assure it remains 

relevant to the operation?

 Procedures documented defining a food defense 

program. Food defense plan does not

 There is evidence that the Food Defense Plan is 

being followed.

need to be 

formal (i.e., elements of a food defense plan may 

exist and be written in other company 

documentation; e.g., a recall plan).

 Plan identifies management responsibilities and 

frequency of review.

 Food Defense Plan is reassessed at least annually 

to assure it remains relevant to the operation.

2.

Does the Food Defense Plan address 

preventive measures relative to product 

tampering and deliberate contamination at 

the facility and during transport in 

commerce?

 Includes description of policy and preventive 

measures to reduce the risk of product tampering.

 Measures separately address food defense issues 

for product whether at the facility or in transport 

(both incoming and outgoing).

3.

Do written defense practices list 

management contacts and procedures for 

notifying appropriate authorities in the 

case of an emergency or security issue?

 Plan identifies management names and telephone 

numbers.

 Contacts for local authorities (police, fire, and 

rescue) are provided.

 Procedures describe steps involved in the 

notification process. These procedures may be 

verified in a documented recall program – if one 

exists. 

4.

Do company personnel hiring practices 

include screening all potential 

employees? 

 Review personnel files to verify security 

screening. Acceptable screening includes at least 

one

1. Employee references obtained and verified.

of the following:

2. Employee immigration status checked 

 (INS Form I-9). 

3. Criminal background checks for employees, 

 as needed (FBI Investigation watch list).

5.

After hiring, are photo identification or 

other measures employed to restrict 

access to the facility? 

 Verify identification practices through 

observations.

 Verify measures used to restrict access.

6.

Have employees received training in Food 

Defense, and is the Food Defense training 

documented? 



 Verify food defense training records for 

employees. 

7.

Do supplier delivery personnel, contract 

workers, and visitors have restricted 

access to vulnerable product areas of the 

facility, and are they accompanied by a 

company representative? 

 Security policy defines restricted access areas. 

 Verify policy practices and procedures through 

observation. 

8.

Are the outside premises of the facility 

secure with limited access to vulnerable 

areas?

The following guidance is for questions 8-10

 Restricted access points to grounds and facility are 

defined and identified.

:
 July 2011

Page 2 of 3

9.

Are the grounds and facility monitored 

for suspicious activity and unauthorized 

entry?

 Security monitored manually or mechanically as 

demonstrated by documentation.

 Verify the presence of posted signs or other 

measures used to secure and limit access to 

vulnerable areas.

 Policy describes procedures/frequency and 

responsibility.

10.

Are “No Trespassing” signs visible along 

the perimeter of the facility, or are other 

measures being taken to secure and limit 

access to vulnerable areas? 

11.

Are assurances concerning food defense 

practices provided by suppliers of direct 

or indirect ingredients, product and 

equipment cleaning and sanitizing 

compounds, and packaging materials? 

This may include the use of tamper 

evident packaging for raw materials, 

sealing of trailers, and locking of bulk 

ingredient receiving ports.

 Review written assurances from suppliers.

 When possible, verify described assurances 

through observation.

12.

Is the security of water and utilities within 

the facility’s control addressed in the 

Food Defense Plan, and does the plan 

define limited access by designated 

company representatives?

 Review plan for procedures, management 

responsibilities, and designated personnel.

 When applicable (company well or water reservoir 

included), verify limited access through 

observation.

13.

Does the processing plant have a 

manufacturer processor registration 

number (MPN), a Food and Drug 

Administration (FDA) food facility 

registration number issued to the 

manufacturer/processor by FDA?

 Affidavit or FDA correspondence verifies 

registration under the FDA Public Health Security 

and Bioterrorism and Response A of 2002.

 Verify company documents demonstrate 

registration of the facility with FDA.
 July 2011

Page 3 of 3

Rating Elements Of The Food Defense System Survey

Question Rating Objective Evidence

1 Critical If the facility does not have a documented food defense plan.

1 Critical If the facility has a documented food defense plan but it is not implemented. 

1 Minor If the facility has a documented food defense plan but it has not been reviewed and 

verified, annually.

2 Major If the plan does not include preventive measures relative to product tampering and 

deliberate contamination at the processing facility and during transport in commerce.

3 Major If the plan does not include written defense practices listing management contacts and 

procedures for notifying appropriate authorities in the case of an emergency or security 

issue.

4 Major If the plan does not include practices to include screening all potential employees.

5 Major If after discussing this section with management, you find that they do not have 

adequate procedures according to their plan (No Identification Method or Restrictions) 

and/or you get an agreement that they need to improve this area.

6 Major If the facility states they have not trained their employees in food defense and/ or cannot

provide any documentation of training their employees in food defense.

6 Major If employees of the facility have received training in food defense and/or documentation 

of this training cannot be provided.

7 Major If you find that supplier delivery personnel, contract workers, and visitors are not 

restricted access to vulnerable product areas of processing and storage.

8 Major If the plan states that the outside public has restricted access but you find the facility is 

not following their procedures which restrict access.

9 Major After walking around the grounds and processing facility you find them not monitored 

for suspicious activity or unauthorized entry.

10 Major If you find that the outside premises is secure, but areas inside the processing facility 

and/or off-site warehouse facility are not secure, or measures are not being taken to 

secure and limit access to vulnerable areas. 

11 Major If the plan does not include procedures for assurances concerning food defense practices 

from suppliers of direct or indirect ingredients, product and equipment cleaning and 

sanitizing compounds, and packaging materials. 

11 Major If you look at the operations section of the plan and it indicates that all raw materials, 

incoming vehicles, containers, or rail cars must be sealed, but you observe one that is 

not sealed.

12 Major If the water and utilities that are under the control of the facility are not addressed in the 

plan to have limited access.

13 Critical If the facility has not registered with FDA to obtain a manufacturer processor 

registration number.

ACCEPTABLE - No critical or major deficiencies.

UNACCEPTABLE – One or more major or critical deficiencies, practices or operations present 

that result in critical Food Defense Issues.