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Food Defense 

OBJECTIVES 

After completion of this module, the participant will be able to:

1. Explain the risk that intentional contamination presents to FSIS-regulated

products.

2. Define the following terms:

a. Food safety

b. Food defense

c. Food defense practices

d. Supply chain

e. Food defense vulnerability

3. List the characteristics of a functional food defense plan.

4. Recognize examples of vulnerabilities and associated food defense practices.

5. Describe the purpose of the food defense task.

6. Identify measures an establishment can take to protect their product from

intentional contamination.

7. Explain how inspectors are to perform the Food Defense task and document food

defense vulnerabilities in the Public Health Information System (PHIS).

REFERENCES 

1. Directive 5420.1_Rev 10, “Food Defense Tasks and Threat Notification

Response Procedures for the Office of Field Operations”

2. FSIS – Food Defense and Emergency Response webpage

3. FSIS – Food Defense Risk Mitigation Tool webpage

4. The Centers for Disease Control; Disease Category webpage

5. FDA – FDA Food Defense webpage

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Sources & Impacts of Intentional Adulteration 

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INTRODUCTION 

This module will address food defense activities in FSIS by providing some background

on food defense, discussing common food defense vulnerabilities and mitigation

strategies, and then explaining your role and inspection activities that are related to food

defense.

Prior to September 11, 2001, FSIS focused primarily on protecting meat, poultry, and

egg products from unintentional contamination. The events of September 11, 2001,

brought the issue of the vulnerability of our food supply to the forefront and called for the

food and agriculture sector to focus on food defense. 

FSIS’ mission is to ensure that the Nation's commercial supplies of meat, poultry, and

egg products are safe, wholesome, and correctly labeled and packaged, as required by

the Federal Meat Inspection Act, the Poultry Products Inspection Act, and the Egg

Products Inspection Act. The Public Health Security and Bioterrorism Act of 2002

established that FSIS could utilize existing authorities to give high priority to enhancing

and expanding the capacity to conduct activities to enhance the ability of the agency to

inspect and ensure the safety/wholesomeness of meat, poultry, and egg products.

Food defense is the protection of food products from contamination or adulteration

intended to cause public health harm or economic disruption. Potential sources and

impacts of intentional contamination are shown in the figure below.

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The Significant Incident Preparedness & Response Staff (SIPRS) is responsible for 

managing all food defense activities for the Agency. SPIRS works with government

agencies at all levels, industry, and other organizations to develop and implement 

strategies to prevent, protect against, mitigate, respond to, and recover from intentional 

contamination of the food supply

The Significant Incident Preparedness & Response Staff is available at any time to

answer questions related to food defense and can be reached via email at: 

SPIRS@usda.gov. 

FOOD DEFENSE TERMINOLOGY 

In order to prevent, protect against, mitigate, respond to, and recover from threats and

hazards of great risk to the food supply, it is important that preparedness efforts 

incorporate food safety, food defense, and food security. While there are distinct

differences between these three concepts, a comprehensive approach that addresses 

food safety, food defense, and food security considerations improve resilience and

protect public health. We need to understand what these terms means:

Food Security – When all people at all times have both physical and economic 

access to enough food for an active, healthy life. Food security includes both

physical and economic access to food that meets people's dietary needs and food

preferences. Therefore, the concept of food security certainly includes but 

encompasses much more than the idea of food defense.

Food Safety – means guarding against unintentional contamination of food. HACCP

plans and Sanitation SOPs, which are developed based on what can be predicted to 

happen if we do not put safety measures at critical points, are used to guard against 

unintentional contamination.

Food Defense – is the protection of food products from intentional contamination or 

adulteration intended to cause public health harm or economic disruption. Food

Defense is an integral part of FSIS’ mission in protecting public health. The mission

of the FSIS Food Defense Program is to protect the U.S. food supply from dynamic 

and evolving threats.

Other definitions important for our discussion include:

Food defense practices – policies, procedures, or countermeasures to mitigate

vulnerability to intentional contamination.

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Critical Infrastructure – The Patriot Act of 2001 defined critical infrastructures as 

systems and assets, whether physical or virtual, so vital to the United States that the

incapacity or destruction of such systems and assets would have a debilitating

impact on security, national economic security, national public health or safety, or 

any combination of those matters. The Food and Agriculture Sector is one of 16

critical infrastructures identified by the Patriot Act.

Supply Chain – continuous process including every step involved in food production

and food reaching the consumer; often referred to as farm-to-table or farm-to-fork.

FOOD DEFENSE VULNERABILITIES AND FOOD DEFENSE 

PRACTICES 

A vulnerability can be any part of the food production or storage system where a

protective measure should be implemented to protect a product from intentional 

adulteration, but such a measure is found to be missing or not in place.

Food defense vulnerabilities are weaknesses within the food production process that 

make it easy to intentionally contaminate product. Examples of food defense

vulnerabilities may include (please note this list is not all-inclusive):

• Unsecured entrances

• Poor lighting around the facility

• Failing to control access and properly secure restricted areas inside the facility, 

including access to processes and/or ingredients that may be more vulnerable to

intentional contamination (e.g., spices, preservatives, marinade, brine, etc.)

• Failing to control product labels and packaging to prevent theft and misuse

• Ensuring seals and locks are present, where appropriate (e.g., bulk liquid 

loading/storage/transport activities, chemicals and hazardous materials, etc.) 

Lack of or insufficient personnel security measures (e.g., background checks, 

employee ID badges, delivery driver/vendor identification, etc.)

• No system for employees to report suspicious behavior

• Computer systems and/or control systems that lack appropriate security

measures that may lead to a cyber security incident (e.g., passwords, firewalls, 

virus protection)

An establishment can put food defense practices (also called mitigation strategies) 

into place to reduce the likelihood that intentional contamination will occur. Food 

defense is not a one-size-fits-all approach! Food defense practices that are

implemented to protect products within a large establishment may not be effective or 

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needed in a small or very small establishment. This should be considered when

inspection program personnel (IPP) conduct their food defense activities.

Examples of food defense practices may include (not all-inclusive):

 Locked doors

 Surveillance cameras

 Security guards

 Alarm system

 Controlled-access system

 Designate and clearly mark all restricted areas

 Perform background checks on new employees

 Restrict personal items in operational areas

 Employee identification system

 Maintain an anonymous system for reporting suspicious behavior

 Conduct food defense training for employees

 Protect computer systems and automated systems with firewalls and passwords 

A more comprehensive list of mitigation strategies for various components of the food

supply can be found in FSIS’ Food Defense Risk Mitigation Tool.

FOOD DEFENSE IN FSIS-REGULATED ESTABLISHMENTS 

Food defense is voluntary for FSIS-regulated establishments. This means that FSIS

does not have regulatory authority when it comes to food defense. Even though food

defense is voluntary, FSIS encourages establishments to protect their products from

intentional contamination by doing the following:

 Implementing food defense practices,

 Conducting training and exercises to ensure preparedness, and

 Adopting a functional food defense plan

A functional food defense plan is an approach to identify and mitigate vulnerabilities; it 

can help an establishment prevent, protect against, respond to, and recover from an

intentional contamination incident. A food defense plan is functional when it meets all

four of the following criteria:

1. Developed – the plan is documented and signed

2. Implemented – food defense practices identified in the plan are actually

implemented

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3. Tested – food defense measures are monitored and validated to ensure they are 

working

4. Reviewed and maintained – the plan is reviewed at least annually and revised as 

needed.

Note: An establishment must be implementing the elements of its food defense plan in

order for FSIS to consider it “functional.” 

The absence of a functional food defense plan may increase an establishment’s 

vulnerability to intentional contamination because important security measures needed

to protect the facility, product, and employees may not be in place. Even though

functional food defense plans are voluntary, FSIS considers such plans to be an

important tool that can reduce the risk of intentional adulteration of food products. 

An establishment does not have to provide IPP access to its food defense plan or any

associated documents (e.g., employee personnel files). It is beneficial if IPP are 

permitted access to the plan, as it may be useful in identifying how the establishment is 

addressing food defense. If the establishment shares its plan, IPP are not to keep or 

make copies of the written plan. IPP also cannot show or share anything about the plan

with any outside source because it includes sensitive security information.

IPP are responsible for maintaining the functional food defense plan status for an

establishment in the Establishment Profile in PHIS. Food defense plan status can be

found on the “General” page  “Other” tab in the Establishment Profile. IPP are to

check the box for “Written food defense plan” if the establishment meets ALL four 

criteria for having a functional food defense plan. This status should be updated per the

frequency identified in Directive 5300.1, Managing the Establishment Profile in the 

Public Health Information System, or when IPP become aware of a change in the

establishment’s functional food defense plan status.

If an establishment does not have a food defense plan, they can access the FSIS

General Food Defense Plan template on the FSIS website. (See Attachment 1) The

Agency has additional food defense guidance documents (e.g. worksheets, checklists,

and fact sheets) for consumers, industry, and state and local agencies. All of these

materials are also available on the FSIS webpage, under Food Defense and Emergency

Response.

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NATIONAL TERRORISM ADVISORY SYSTEM 

The National Terrorism Advisory System (NTAS) is a system managed by the

Department of Homeland Security (DHS) to communicate information about terrorist 

threats by providing information to the American public. Under the NTAS system, DHS

coordinates with other federal entities to issue formal alerts when the Federal 

government receives information about a specific or credible terrorist threat.

If there is specific and credible information about a terrorist threat against the U.S., DHS 

will share the NTAS alert with the American public when circumstances are justified.

These alerts include a clear statement that there is an “elevated threat” or “imminent 

threat”. 

 Elevated threat: if there is credible threat information, but only general 

information about timing and target such that it is reasonable to recommend

implementation of protective measures to thwart or mitigate against an attack.

 Imminent: there is a belief that the threat is credible, specific, and impending in

the very near term.

The NTAS alerts are based on the nature of the threat including the geographic region, 

mode of transportation, or critical infrastructure potentially affected by the threat. The

alerts also provide a concise summary of the potential threat, information about actions

being taken to protect public safety, and recommended steps that individuals, 

communities, businesses, and governments can take. 

FSIS DIRECTIVES 

There are five FSIS Directives related to food defense:

 5420.1 – Food Defense Tasks and Threat Notification Response Procedures for 

the Office of Field Operations

 5420.3 – Food Defense Surveillance Procedures and National Terrorism Advisory

System Alert Response for the Office of Investigation, Enforcement and Audit

 5500.2 – Significant Incident Response

 5500.3 – Incident Investigation Team Reviews

 5500.4 – Products Intentionally Adulterated with Threat Agents

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Directive 5420.1 outlines the duties that are relevant to the in-plant inspection team

when performing the food defense task and observing/reporting food defense

vulnerabilities. The other directives cover food defense duties for other FSIS personnel. 

Depending on the role of the in-plant inspector, you should familiarize yourself with

these other important directives, if it applies to your duties.

FSIS DIRECTIVE 5420.1 

Let us look at Directive 5420.1 in more detail. First, this directive describes the PHIS

Food Defense task and its frequency. The directive also discusses threat notification

procedures that the Office of Field Operations (OFO) is to follow in the event FSIS

receives threat information related to the food and agriculture sector. 

Threat Notification 

IPP are to know the protocol for communicating threat information related to the food

and agriculture sector to establishment management through proper supervisory

channels as necessary. Threat information, such as an NTAS bulletin or alert from the

intelligence community is to be communicated through the following: 

1. The FSIS Significant Incident Preparedness and Response Staff (SIPRS) Chief

Operating Officer (COO) is the primary point of contact for receipt of threat

information from the intelligence community;

2. If a threat has the potential or is expected to affect food or agriculture, the SIPRS 

COO informs the FSIS Administrator and FSIS Management Council;

3. The SIPRS COO determines the appropriate distribution of the threat information

and coordinates with other FSIS offices to notify employees, stakeholders, and

the public, as appropriate; and

4. In the event of a significant incident, the FSIS Emergency Management 

Committee (EMC) may be alerted and other response actions taken pursuant to

FSIS Directive 5500.2 Significant Incident Response

Supervisory personnel are to ensure that any notifications distributed to field employees 

are available to IPP in the establishment. As soon as supervisory personnel are notified

of threat information, they are to inform establishment management of the alert. IPP are

to document their discussion with establishment management in a memorandum of

interview (MOI) (see Food Safety Related Topics For Discussion During Weekly

Meetings With Establishment Management). If IPP observe a potentially significant 

incident that presents a grave, or potentially grave, threat to public health or to the

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safety of FSIS-regulated product or to personnel, they are to report it through

supervisory channels. IPP are to follow instructions provided in FSIS Directive 5500.2, 

which also lists examples of significant incidents.

If there is a specific threat, additional Food Defense tasks may be necessary. 

Additional actions may be needed to reduce the threat of intentional adulteration of food

products. IPP must clearly understand their roles and what will be required of them to

respond properly to that threat.

Performing Food Defense Tasks in PHIS 

IPP in meat and poultry establishments are to perform the “Food Defense task” as 

assigned in PHIS. PHIS will automatically generate one routine Food Defense task per 

quarter to the establishment task list. This task has a priority 3 in the Establishment 

Task List including a start/end date window of three months. Only one questionnaire is 

to be completed per establishment. The task is to only be performed on one shift in

multi-shift establishments. The supervisor should determine which shift performs the

task. The shift that does not complete the task should mark the task as not performed

with a justification of ‘Task assigned to another inspector.’

IPP perform the Food Defense task to identify vulnerabilities within establishments that

may lead to intentional contamination of FSIS-regulated products. 

There are resources that the IPP can use as an aid to assess vulnerabilities while

performing the Food Defense task. These resources can be found on FSIS’ food

defense webpage (https://www.fsis.usda.gov/wps/portal/fsis/topics/food-defensedefense-and-emergency-response) under “Tools, Resources, and Training”.

To perform the food defense task in PHIS, IPP are to:

1. Schedule the Food Defense Task to the PHIS task calendar;

2. Select the “Activity” tab, then select the applicable verification activity (Review &

Observation, Record Keeping, or Both);

3. Select the “Questionnaire” tab, click on “Take Questionnaire” tab to access the

questions; 

4. Click “Start” to begin questionnaire;

5. Answer all the questions – IPP are not to leave any blank or unanswered. IPP

are to select “N/A” if the question does not apply to the establishment or if they

Inspection Methods 42-9
 

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do not know the answer to the question. IPP are to answer “Yes” if there is 

another mitigation strategy addressing the potential vulnerability;

6. Click “Submit” to complete the questionnaire; and

7. Record the task as completed after the results have been entered.

Prior to completing the questionnaire, IPP should discuss food defense activities with

management during a weekly meeting to learn more about the establishment’s food

defense practices. This will allow them to accurately complete the questionnaire.

IPP are to discuss the answers of the questionnaire with establishment management in

the weekly meeting following task completion, including areas in the establishment 

where food defense vulnerability exists, as well as food defense practices. IPP can use

the Food Defense Risk Mitigation Tool in their discussion with establishment 

management.

In the case of a NTAS alert identifying an elevated or imminent threat to food or 

agriculture, the inspector-in-charge (IIC) will receive specific instructions through 

supervisory channels on other measures to take. If additional Food Defense tasks are 

necessary, IPP will schedule them as directed task in PHIS. Other measures may

include sampling of specific products and deploying inspectors to establishments 

producing the products to ensure that FSIS has an on-site presence.

If the establishment requests guidance on food defense, IPP are to direct them to the

Food Defense web page: (www.fsis.usda.gov/fooddefense) or email:

FoodDefense@fsis.usda.gov.

OBSERVING AND DOCUMENTING FOOD DEFENSE 

VULNERABILITIES 

Next is a diagram summarizing the food defense task thought process. Information that 

is more detailed is to follow. Remember, there is a questionnaire associated with the

food defense task that must be completed every time you perform this task.

Inspection Methods 42-10
Food o,efense Task Thought Process 

Is there a food defense concern? 

I , 

I 

r 

II: ...... 

I 

No 

Complete the FD task. 

Complete a FD MO 

✓ 

_r----------....-.._ 

No 

✓ 

, 

• Provide a copy to management in the 

next weekly meeting 

•Disieuss, vulnerability findings with 

management; document on the 

weekly meeting MOI 

' ' ~,. ____ .... 

Yes 

Is there evidence of produot adulteration 

(intentional product contamination)? 

\ 

\ 

\ ? a..._ Yes 

I mmedia~y r,etain the affected product 

using an U.S. Retain tag/notify manag,ement 

Report the potential s.ig nific:ant i nc:'dent to FSIS 

supervisory 

Ensure adulterated product is not dispos,ed of 

until Agency's. investigation is complete 

-Dorument the observations of product 

contamination in an NR under the appropriate 

inspection task 

Complete the FD task and FD MOI (mark 

"Adulterated Product Observed" - Category tab; 

Select applicable "Produ:ctTypes"- Product tab); 

Provide a copy of FD MOI to management 

•Discuss th,e incident with management 

including potential vulnerability points or 

concern; document the discussion on the 

weekly meeting MOI 

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When inspection program personnel perform a Food Defense task and do not find a

food defense vulnerability or concern, they are to complete the task in PHIS.

IPP may observe food defense vulnerabilities when they are performing the Food

Defense task and during other daily inspection activities. IPP should document these

vulnerabilities in a food defense memorandum of interview (MOI) after discussing the

findings with plant management.

To document a food defense MOI for domestic establishments:

1. Go to the “Inspection Verification” in PHIS and after selecting the establishment, 

click on “Memorandum of Interview” to open the MOI List page.

2. Click on “Add Food Defense OFO” to open the “Domestic Food Defense MOI” 

page to access key functions of the MOI.

3. In the “Status” tab, select attendees with left mouse click on attendee’s name. To

select more than one attendee, hold “Ctrl” on keyboard while left clicking on each

applicable name;

4. In the “Category” tab, choose the appropriate potential vulnerability (No product 

adulteration observed), the occurrence (1st, 2nd, or 3rd), the establishment size

(very small, small, or large), and establishment type (meat, poultry, egg products,

or equine);

Note: In case of the 4th occurrence, the establishment express no intention of 

addressing the situation, IPP are to notify the DO through supervisory

channels.

5. In the “Product” tab, leave this table blank. 

6. In either the “Processing” or “Storage” tab, identify the vulnerability point or 

concern. Additional vulnerabilities, other than those related to processing (“Water 

System”) and storage (“Shipping and Receiving”) activities, are available for 

selection in these tabs; and

7. Check the “Finalize” box and then click “Save” to complete the Food Defense

MOI (FSIS Form 5420-1, see Attachment 2). At the next weekly meeting, provide

a finalized copy of the Food Defense MOI to establishment management.

Discuss the food defense findings with management, including proposed

mitigation actions, and document in the weekly meeting memorandum. 

When IPP perform a food defense task or other daily inspection activities and find a

food defense vulnerability or concern, and there is evidence of product adulteration

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(e.g., regulatory non-compliance), IPP will perform a directed HACCP, Sanitation SOP

or other appropriate inspection task to record the observed non-compliance citing the

applicable regulation. IPP are to:

1. Immediately retain the affected product by attaching a retain tag or detain tag, 

then notify establishment management and discuss the findings;

2. After informing establishment management, IPP are to report any potentially

significant incidents through supervisory channels and follow instructions 

carefully; IPP should verify and ensure that product is not disposed of until 

being notified, by the Incident Commander through supervisory channels, that 

the agency’s investigation is complete (Directive 5500.4).

3. Add the appropriate inspection verification task (directed HACCP, SSOP or other 

appropriate inspection task) to the task calendar, document the observed product

contamination in an NR, and cite the applicable regulation (SSOP for product 

contamination or HACCP if product is adulterated).

4. Complete a Food Defense MOI; and

Note: IPP are to mark “Adulterated Product Observed” for Category of

Potential Vulnerability under the “Category” tab, and select the applicable 

product types under the “Product” tab.

5. Immediately provide a finalized copy of the MOI to establishment management 

and inform management that an NR will also be issued describing the

adulterated product and potential vulnerability or concern.

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Workshop: Food Defense Video Scenario 

Instructions: 

Today, you scheduled the Food Defense task in your task calendar. While performing

the task you encounter the following:

Watch the video and take note of the vulnerabilities observed.

To help you answer these questions, use the Food Defense Task Thought Process 

diagram, including what you have learned in this module, to identify the vulnerabilities 

and to take the appropriate actions while performing the food defense task.

1. List the food defense concerns/vulnerability:

2. At this point, as an inspector, what actions will you take?

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SUMMARY 

Defending the food supply against intentional contamination is a critical function. IPP, 

both in and outside of establishments, serve as the Agency’s eyes and ears to help 

identify vulnerabilities that may lead to intentional contamination. IPP are responsible for 

three activities related to food defense:

 Updating the functional food defense plan status in the PHIS establishment 

profile and ensuring it is accurate

 Performing food defense tasks

 Submitting a food defense MOI when food defense vulnerability is observed and

discuss with establishment management.

Implementation of Food Defense tasks serves to protect the public, which is essential to

our mission, and ensures the security of our food, a vital component of homeland

security. 

Report any suspicious activities in establishments to your district manager through

supervisory channels or call the FSIS 24-hour emergency hotline at 1-866-395-9761.

Inspection Methods 42-15
UNITED STA TES DEPARTMENT OF AGRICUL nlRE 

FOOD SAFl;TY Af,10 INSPE"CTION ScRVICc 

Food Defense Plan 

Security Measures for Food Defense 

Establishment Name: 

Establishment Location (city, state): 

FSIS Establishment Number: 

By signing here, I acknowledge that this establishment has measures in place in accordance 

with this document 

Print Name: Title: 

Signature: Date: 

FSIS FORM 5 420-5 (1 0/29/2014) Inspection Methods 42-16

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ATTACHMENT 1 - FSIS Food Defense Plan Template 
Defense Plan 

Security Measures for Food Defense 

PURPOSE 

Food Defense is having measures in place to 

reduce the chances of someone intentionally 

contaminating the food supply in order to /<.ill or hurt 

people, disrupt our economy, or ruin your business. 

This voluntary plan documents your measures to protect food and food production processes from intentional harm. 

Review of this plan and signing the cover sheet will result in a Food Defense Plan for your FSIS-regulated 

establishment 

BENEFITS: By having a Food Defense Plan, you will contribute to a safer and more secure food supply. You will 

also protect public health, your employees, and your livelihood. A functional* food defense plan may also: 

o reduce the risk of unsafe product and economic loss, 

o reduce theft, 

o reduce the need for additional regulation on food defense, and 

o reduce company liability. 

INSTRUCTIONS: 

1. Review the attached plan. 

2. Sign the cover page. 

3. On an annual basis, review this plan and document that you did so on the form in Attachment B. 

This food defense plan is organized in four sections: (1) Outside Security Measures, (2) Inside Security Measures,(3) 

Personnel Security Measures, and (4) Incident Response Security Measures. Attachment A provides a list of tools or 

additional security measures that an establishment may consider or may already have in place. You may also have other 

plans that contribute to a food defense plan such as an emergency plan, a recall plan, a security plan, etc. Attachment 

B is a form that can be used to document your annual review of your food defense plan. 

*The four elements that make up a functional food defense plan: 

1. Develop: Reviewing and signing this document fulfills this element. 

2. Implement: Having measures described in this document fulfills this element. 

3. Test: Periodic monitoring fulfills this element. This can be done using simple measures, such as checking locked doors 

or making unannounced perimeter checks. Monitoring can be 9Q0.Jmented using a form, such as Attachment B. Not all 

security measures need to be tested at the same frequency. 

4. Review and Maintain: Reviewing the plan at least annually, revising the plan as needed, and taking appropriate actions 

fulfills this element. 

This plan was developed through a joint effort between RTI International, the HACCP Consulting Group, a Focus Group of industry 

representatives, and the U.S. Department of Agriculture's Food Safety and Inspection Service. 

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Inspection Methods 42-17
all measures suggested are appropriate or necessary for every facility. 

------------- 1. Outside Security Measures 

(Examples: door locks, lighting, monitoring loading/unloading) 

GOAL: To prevent unauthorized access by people, or entry of unapproved materials to the facility. 

This establishment has in place at least one of the following measures for outside security. 

1.1 Physical Security 

D 

u 

[l 

□ 

n 

[J 

~ 

Plant boundaries are clear and secured to prevent unauthorized entry (ror example, fences 

installed, no trespassing signs posted) 

Entrances are seoureci (for example, Ice~ and/or alarms installed and operating) 

Plant perimeter is periodically monitored for suspicious activity 

OL1ts1de lightlng ls present to deter unauthorized activities 

Other access points such as windows and vents are secured 

Outside storage on the premises s protected from unauthorized access 

Other: --------------------------------

1.2 Shipping/Receiving Security 

• I Incoming shipments are examined for potential tampering 

0 Incoming and outgoing vehicles are examined for suspicious activity 

0 Loading and unloading activities are scheduled and/or monitored 

0 Loading dock access is controlled (for example, monitored or locked) 

Incoming shipments are secured \'1/ith locks or seals 

LJ Outgoing shipments are locked or sealed 

[J Other 

1.3 Mail Handli119 Security 

[l Mail is handled away from food including ingredients and packaged food product 

[7 Employees who handle mall are aware of proper handling of suspicious mail and U.S. Postal Service guidelines 

Other; 

Paget 

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Inspection Methods 42-18
all measures suggested are appropriate or necessary for every facility. 

--------------- 2. Inside Security Measures 

(Examples: signs, observations, restricted access) 

GOAL: To protect product from intentional contamination throughout the production process. 

This establishment has in place at least one of the followi ng measures for inside security. 

2.1 General Inside Security 

:J Suspicious packages are reported to appropriate personnel 

n Restricted areas of the establishment are clearly dentifled 

I Previously unattended materials are checked before use 

_J Unexpected changes in inventory (product or equipment) are reported to appropriate personnel 

:=J Emergency lighting is in place 

An emergency alert system is identifiable, tested, and reviewed with emergency contacts (for example, police or 

fire personneQ 

Other: 

2.2 Slaughter/Processing Area Security 

LJ Access to live animals, ingredients, a nd packaged product is restricted 

D Access to animal handling areas and/or carcass coolers is controlled 

0 Access to process control equipment such as ovens, mixers is restricted 

0 Ingredients are examined for posslble tampering 

D Records ensure traceabi lity for one step backward, one step forward, or boU1 

Other: 

2.3 Storage Security 

:J Access to storage areas is restricted 

:J Stock rotation (first in, first out) 1s practiced 

~ Labels and packaging materials are controlled to prevent theft and misuse 

'.:::J Perlodic examinations for tampering of materials in storage are performed 

□ Other. 

Page2 

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Inspection Methods 42-19
all measures suggested are appropriate or necessary for every facility. 

---------------------- 2. Inside Security Measures 

2.4 Ingredients/Water/Ice Security 

J Restrict access to storage tanks for potable water and to water reuse systems 

7 Access to lines that transfer water or ingredients are examir1ed and restricted 

::J Access to plant ice-making equipment is controlled 

=1 Restricted lngredients (for example, nitrites) are controlled 

• 

~ I Supplier food safety/security information is requested 

=1 Other: _________________________________ _ 

2.5 Chemical/Hazardous Material Control Security 

Chemicals/hazardous materials, including pesticides, deaning or lat-oratory materials, and sanitizers, 

are in a restricted area or secured by a lock 

Maintain an up--to-date inventory of hazardous materials and chemicals, and investigate dlscrepancres 

Potentially hazardous waste (biological or chemical) Is controlled and disposed of properly 

Other 

2.6 Information Security 

J Access to sensitive information such as site plans and processing details is controlled 

=:J Access to computer systems is protected through firewalls and/or passwords 

=:J Other; 

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Inspection Methods 42-20
Not all measures suggested are appropriate or necessary for every facility. 

3. Personnel Security Measures 

(Examples: check references, use visitor log or sign-in, or check IDs) 

GOAL: To ensure that only authorized personnel are in the facility at any time. 

This establishment has in place at least one of the following measures for personnel security. 

3.1 Employee Security 

A method to recogni2-e or identify employees in the fac1lrty is in place 

Background or reference checks are cohducted for new hires' 

U Employees have restrictions on what they can bring 1n or take from the facility (for example, cameras) 

] Other: 

3.2 Non-employee Security (Example: visitors, contractors, guests, customers, truck drivers) 

LJ A log of non-employees entering the establishment is maintained 

~ A method to recogni2-e or identify non-employees in the establishment is in place 

LJ Non-employees are chaperoned on-site 

0 Non-employees are restricted to appropriate areas 

0 Non-employees have restrictlons on what they can bring in or take from the facmty 

[_J Other: 

3.3 Security Trainin!J 

D Awareness training on security measures 1s provided to new e.mployees-

[J Refresher awareness tralnlng on security measures Is offered to employees on a periodic basis~ 

• I _J Employees are trained to report suspicious activities or unusual observations 

~ Other. 

' You can electronically verify the employment eligibility of your new hires at 

http://www.dhs.gov/fi1es/program$/gc...11 85221678150.shlm . E-verify is an internet based system operated by the federal 

government that is available for employers to use at no charge. 

2 Yoo can access free food defense awareness training foryouremplO':,'eesat 

http://www fda.gov/food/fooddefenseltoolseduc~tlonalmaierlals/default him 

Page 4 

Inspection Methods 42-21

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/llot all measures suggested are appropriate or necessary for every facility. 

4. Incident Response Security Measures 

(Examples: reference your emergency plan, security plan or other) 

GOAL: To respond quickly to a product contamination threat or event using planned measures. 

This establishment has in place at least one of the following measures for incident response security. 

4.1 Investigating Security Concerns 

~ Have procedures to ensure that adulterated or potentially harmful products are held 

7 Customer comments are investigated 

, ] Reportln_g unusual activities is encouraged 

0 Information is available to employees on how lo respond to phone or other threats 

__j Employees have the abillty to stop activities to minimize a potential food defense incident 

7 Reported security breaches (for example, alarms, suspicion of tampering) are investigated 

LJ Other· ----------------------------------

4.2 Emergency Contact Security 

7 Plant personnel contact information is kept up to date 

=:J Emergency contact lists are kept up to date 

7 Other 

4.3 Other Plan Security 

=:J A product recall plan is maintained and periodically reviewed 

;=:] Key personnel are trained in product recall/withdraw procedures 

'.=i Other· _ ___________________________ _ 

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Inspection Methods 42-22

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ATTACHMENT A 

List of Tools or Possible Security Measures 

for Food Defense 

This attachment provides a list of tools or additional security measures that an establishment may consider or may already 

have in place. These are provided to assist establishments in tai loring the plan to meet their specific needs. 

1. Outside Security Tools 

Physical Security 

• Ensure proper lighting to monitor the establishment outdoors at night and early morning. 

• Install self-locking doors and/or alarms on emergency exits. 

- Ensure the following are secured with locks, seals, or sensors when unattended (after hours/weekends) to prevent 

unauthorized entry: - Outside doors and gates - Tanker truck hatches 

- Windows - Railcars 

• Roof openings - Bulk storage tanks/silos 

• Vent openings - Loading ports 

• Trailer (!ruck) bodies - Hose /Pump stations 

Regularly conduct and document security inspections of storage facilities, including temporary storage vehicles. 

Restrict outdoor access to water wells/sources. 

Shipping/ Receiving Security 

Closely monitor loading and unloading of vehicles transporting raw materials, finished products, or other materials used 

in food processing. Inspect tanker trucks and/or rail cars to detect the presence of any material, solid or liquid, in tanks prior to loading 

liquid products. Load only when appropriate. Report/record results. 

Control access to loading docks to avoid unverified or unauthorized deliveries. 

Require advance notification from suppliers for all deliveries. 

Immediately investigate suspicious changes in shipping documents. 

Check all deliveries against a roster of scheduled deliveries. 

Hold unscheduled deliveries outside establishment premises pending verification. 

If off-hour delivery is accepted, require prior notice of the delivery and an authorized person to be present to verify 

and receive the delivery. 

- Check less-than-truckload (L TL) or partial load shipments for content and condition. 

- Require incoming shipments of raw product, ingredients, and finished products to be sealed with tamper-evident or 

numbered, documented seals and verify the seals prior to entry. Reject if seals are broken or missing. 

Select transportation companies and suppliers with consideration of security measures that they use. 

Examine returned goods at a separate location for evidence of tampering before salvage or use in rework. 

Maintain records of disposition of returned goods. 

Require drivers or delivery personnel to provide identification, preferably with a photo ID. Record names. 

Minimize the time a truck is unlocked during loading or delivery. 

A-1 

In ection Methods 42-23

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sp
List of Tools or Possible Security Measures for Food Defense 

Not all measures suggested are appropriate or necessary for every facility. 

2. Inside Security Tools 

General Inside Security 

- Install and monitor security cameras. 

- Increase visibi lity within the establishment (for example, improve lighting, openness, increase supervision, add 

cameras). 

- Regularly take inventory of keys to secured/sensitive areas of the establishment. 

- Restrict access to controls (by locked door/gate or limiting access to designated employees) for the following 

systems: 

- Heating, ventilation, and air conditioning (HVAC) 

- Propane, natural gas, water, electricity 

- Disinfection systems 

- Clean-in place (GIP) systems or other centralized chemical systems 

Slaughter/ Processing Area Security 

- Maintain records to allow efficient trace backward or forward of materials and finished product. 

- Reduce the time an area is left unmonitored. 

- Reduce access to product containers or processing equipment 

- Do not allow unnecessary personal items within the production area. 

Storage Security 

- Maintain an access log for product and ingredient storage areas. 

- Regularly check the inventory of finished products for unexplained additions and withdrawals from existing stock. 

- Restrict access to external storage facilities to designated employees only. 

Ingredients/ Water/ Ice Security 

- Examine packages of ingredients before use for evidence of tampering. 

- Restrict access to product, ingredient, and packaging storage areas to designated employees only (by locked door/gate). 

- Water is from a municipally controlled source. 

- Inspect water lines for possible tampering (perform visual inspection for integrity of infrastructure, 

proper connections). - Make arrangements with local health officials to ensure immediate notification to the establishment if the 

potability of the public water supply is compromised. 

Chemical / Hazardous Material Control Security 

- Restrict access to the in-plant laboratory. 

- Have procedures in place to control receipt of samples. 

- Have a procedure in place to receive, securely store, and dispose of reagents. 

Information Security 

- Track customer complaints/comments for trends. 

- Keep details of food defense procedures confidential as necessary. 

- Have up-to-date establishment layout/blueprints for local law enforcement, including the fire department if needed. 

A-2 

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Inspection Methods 42-24
List of Tools or Possible Security Measures for Food Defense 

Not all measures suggested are appropriate or necessary for every fa cility. 

3. Personnel Security Tools 

- Authorize appropriate employees to stop a process for significant concerns. 

- Control access by employees and non-employees entering the establishment during working and non-working hours 

(use coded doors, receptionist on duty, swipe cards). 

- Restrict temporary employees and non-employees to areas relevant to their work. 

- Implement system to identify personnel with their specific functions, assignments or departments 

(for example, corresponding colored uniforms or hair covers). 

- Prohibit employees from removing company-provided uniforms or protective gear from the prerois<iG. 

- Maintain an updated shift roster for each shift. 

4. Incident Response Tools 

- Establish evacuation procedures and include in food defense plan. 

- Establish procedures for responding to threats as well as actual product contamination events. 

- Pre-establish communication with local, state, and federal incident response personnel for a more efficierit. 

response. 

A-3 

Inspection Methods 42-25

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B • Food Defense Plan Review 

Complete this form to document your annual review of this Food Defense Plan. 

Not all measures are required or need to be reviewed each time this form is completed. 

Date of Annual Review Person Who Conducted Was the Food Defense Plan 

Annual Review tested?" 

(Name and Title) {Yes/ No) 

n Yes ] No 

0 Yes L No 

Yes No 

D Yes L No 

-

•Testing can be done using simple measures, such as checking locked doors or making unannounced 

perimeter checks. 

NOTE: Make as many copies of this page as necessary. 

6-1 

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Inspection Methods 42-26
U.S. Department of Agriculture 

Food Safety and Inspection Service 

FOOD DEFENSE MEMORANDUM OF 

INTERVIEW 

SENSITIVE SECURITY INFORMATION 

Distribute One Copy To: Plant Management, District Analyst & IF-OFOER mallbox 

3a. CATEGORY OF POTENTIAL VULNERABILITY: 

EJ No product adultration observed 

n Adultrated product observed 

5. PRODUCT TYPE: 

D Raw - Non Intact 

E] Raw - Intact 

1. ESTABLISHMENT NUMBER: 

M45711 

2. ESTABLISHMENT NAME: 

Groveton Meats88, Inc. 

3b. OCCURENCE: 

EJ 1st □ 2nd □ 3rd 

D Thermally Processed/Commercially Sterile 

D Not Heat Treated - Shelf Stable 

D Heat Treated - Shelf Stable 

□ Fully Cooked - Not Shelf Stable 

□ Heat Treated - Not Fully Cooked - Not Shelf Stable 

D Product with Secondary Inhibitors - Not Shelf Stable 

7. WATER SYSTEMS: 

E] Unrestricted Access to Outside Well 

4. SIZE OF PLANT: 

□ Very Small 

6. PLANT TYPE: 

0Meat 

E] Poultry 

Egg 

D Equine 

small 

E] Unrestricted Access to In-Plant Water Systems, Water Storage Tanks or Ice Machines on Premises 

8. PROCESSING AREA/MANUFACTURING: 

E] Unrestricted Access to Sensitive Processing Areas by Unauthorized Individuals (including employees or 

maintenance workers) D Equipment Calibration Incorrect 

D Evidence of Possible Intentional Contamination Observed 

9. STORAGE AREAS: 

D Evidence of Possible Tampering on Stored Product 

D Unrestricted Access to Dry Ingredients 

D Unrestricted Access to Raw Product Ingredients 

D Unrestricted Access to Finished Product 

D Unrestricted Access to/use of Hazardous Chemicals 

10. SHIPPING AND RECEIVING: 

D Unrestricted Access to Loading Docks 

D No Verification of Incoming Shipment of Raw Materials 

11 . PLANT MANAGEMENT RESPONSE: 

12. NAME OF INSPECTOR: 

Robert Barclay88 

FSIS FORM 5420-1 (09/08/2006) 

13. DATE 

5/13/2019 

EJ Large 

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Attachment 2 - FSIS Form 5420-1 

Inspection Methods 42-27