FSIS_Security Guidelines for the Transportation of …prep4audit.com/wp-content/uploads/2015/02/FSIS...Web viewGuidelines for the Transportation and Distribution of Meat, Poultry,

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Food Safety and Inspection Service, United States Department of Agriculture

The FSIS Food Security Guidelines for the Transportation and Distribution of Meat, Poultry, and Egg Products

FSIS: Food Security Guidelines for the Transportation and Distribution of Meat, Poultry, and Egg Products

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1 FSIS, United States Department of Agriculture © Restatement and Document Preparation by Prep4Audit, LLC



Food Safety and Inspection Service, United States Department of Agriculture

The FSIS Food Security Guidelines for the Transportation and Distribution of Meat, Poultry, and Egg Products


FSIS Food Security Guidelines for the Transportation and Distribution of Meat, Poultry, and Egg Products

1.0.0 OVERVIEW........................................................................................................................................................................ 4

1.1.0 GENERAL GUIDANCE....................................................................................................................................................................4

2.0.0 SECURITY PLAN................................................................................................................................................................. 5

2.1.0 ASSESS VULNERABILITIES...............................................................................................................................................................52.3.0 EMERGENCY OPERATIONS.............................................................................................................................................................72.4.0 TRAIN AND TEST..........................................................................................................................................................................7

3.0.0 SCREEN AND EDUCATE EMPLOYEES................................................................................................................................... 8

3.1.0 BASIC EMPLOYEE SCREENING AND EDUCATING..................................................................................................................................8

4.0.0 SECURE THE FACILITY......................................................................................................................................................... 9

4.1.0 ACCESS......................................................................................................................................................................................94.2.0 SHIPPING/RECEIVING................................................................................................................................................................. 104.3.0 FACILITY...................................................................................................................................................................................11

5.0.0 MONITOR OPERATIONS................................................................................................................................................... 12

5.1.0 EMPLOYEES..............................................................................................................................................................................125.2.0 SHIPPING/RECEIVING................................................................................................................................................................. 125.3.0 STORAGE/WATER......................................................................................................................................................................135.4.0 RESPOND.................................................................................................................................................................................14

6.0.0 ADDITIONAL GUIDANCE FOR SPECIFIC MODES OF TRANSPORTATION..............................................................................16

6.1.0 GENERAL GUIDANCE FOR ALL MODES...........................................................................................................................................166.2.0 AVIATION.................................................................................................................................................................................166.3.0 TRUCK.....................................................................................................................................................................................176.4.0 MARITIME................................................................................................................................................................................186.5.0 RAIL........................................................................................................................................................................................19



Food Security: Transportation & Distribution of Meat, Poultry, and Egg Products

1.0.0 Overview

1.1.0 General Guidance

1.1.1 Meat, poultry, and egg products are susceptible to intentional contamination from a wide variety of physical, chemical, biological, and radiological agents.

1.1.2 Everyone in the food distribution system is responsible for ensuring that these products are safe, wholesome, and unadulterated.

1.1.3 As part of this food distribution system, those responsible for transportation and delivery should implement every possible security measure to ensure the integrity of the products throughout the supply chain.

1.1.4 There are many potential benefits of having an effective security plan in place, such as: Protects public health and assets; Increases public and customer confidence, including trading partners; Provides value-added component to product; Deters theft and tampering; Creates production and distribution efficiencies; Maintains greater control over product through supply chain; and, Possibly reduces insurance premiums and freight rates.

1.1.5 FSIS addresses security measures to be considered by processing plants, shipping companies, and warehouse facilities to minimize the risk of tampering or other criminal action for each segment of the food-delivery system.



2.0.0 Security Plan

2.1.0 Assess Vulnerabilities

2.1.1 Processing plants, shipping companies, and warehouse facilities should identify a food protection management team and assign a leader to verify required actions are implemented and effective.

2.1.10 Corrective and preventive actions that should be taken and should be defined in the event established limits are exceeded.

2.1.2 A comprehensive transportation security plan must be developed and vulnerabilities assessed using a recognized threat/risk/vulnerability model such as Operation Risk Management (ORM) and Systematic Assessment of Facility Risk (SAFR).

2.1.3 A flow diagram from point-of-origin to final destination, including all shipping modes/routes, should be used as a tool in vulnerability assessment.

2.1.4 The security plan should identify all points of vulnerability where there is the potential for intentional adulteration or contamination to occur during the transportation and distribution process.

2.1.5 The security plan should identify potential biological, chemical, and physical hazards.

2.1.6 The security plan should identify if control is possible at the identified point(s) of vulnerability.

2.1.7 The security plan should identify the most effective point(s) to exert control.

2.1.8 Where control points are identified, the method, frequency, and limit that must be met should be identified.

2.1.9 Methods, frequencies, and limits should specify where and how often monitoring and verification of the established limits should occur.

2.2.0 Develop and Implement Procedures

2.2.1 Identified security measures should be implemented at each point of vulnerability to ensure the protection of products from the time of shipment through delivery to each destination.

2.2.10 The evacuation plan should identify where and how to separate products suspected to be contaminated.



2.2.11 Develop and implement methods to check and document condition of product and packaging upon receipt at destination.

2.2.12 Policies and procedures should be in place for the rejection of packages and products that are not acceptable, can’t be verified against the delivery roster, or contain unacceptable changes to shipping documents.

2.2.13 A monitoring strategy and recordkeeping system should be in place to document steps taken for incidents where packages and products were rejected.

2.2.14 Policies and procedures are in effect for allowing rail crew, truckers, etc., to enter the facility and monitor their activities while on the property.

2.2.15 Food security plans should be kept in a secure location and shared only on a “need-to-know” basis.

2.2.2 The security plan should include a system to identify and track product at any time during transportation and distribution such as the use of tamper-resistant seals corresponding to specific shipments and their documentation.

2.2.3 Verification should be made that contracted transporters (e.g. air, ground, maritime, rail) and storage/warehouse facilities have a security program in effect.

2.2.4 Specific security measures should be included in contracts and verification should be made that included measures are being met.

2.2.5 Procedures for the immediate recall of adulterated products from trade and consumer channels should be included in contracts.

2.2.6 A system should be in place to track salvaged, reworked, and returned products.

2.2.7 The system to track salvaged, reworked, and returned products should include procedures for handling threats to and actual cases of product tampering.

2.2.8 An evacuation plan should be established for the facility.

2.2.9 The evacuation plan should include procedures for the safe handling and disposal of contaminated products.



2.3.0 Emergency Operations

2.3.1 A list of local, State, and Federal emergency contacts, local Homeland Security contacts, and local public health official contacts should exist and be regularly updated.

2.3.2 Procedures should be developed for notification of appropriate authorities should an event occur.

2.3.3 All entry and exit points available to emergency personnel should be identified in the emergency operations plan.

2.3.4 A strategy should be developed for communicating with the media and it should contain procedures to identify a spokesperson, draft press statement templates, and referring media to trade associations or corporate headquarters.

2.4.0 Train and Test

2.4.1 Each food security team member should be trained in all provisions of the security plan.

2.4.2 Drills should be conducted on a regular basis to test and verify the effectiveness of the security plan.

2.4.3 Procedures for continual review of policies and procedures should be defined within the security plan.

2.4.4 The food-protection management team leader should coordinate these activities relative to training and testing of security procedures.



3.0.0 Screen and Educate Employees

3.1.0 Basic Employee Screening and Educating

3.1.1 All potential employees, to the extent possible, should be screened by conducting background and criminal checks appropriate to their positions, and verifying references (including contract, temporary, custodial, seasonal, and security personnel).

3.1.10 Employees should be encouraged to report any suspicious activities such as signs of possible product tampering or a break in the food security system.

3.1.11 A tracking system should be in place for reporting and follow-up activities regarding suspicious activities.

3.1.2 When effective screening is not practical, unscreened personnel should be kept under constant supervision and their access to sensitive areas of the facility restricted.

3.1.3 Consideration should be given to participation in the Immigration and Naturalization Service (INS) pilot program for screening employees.

3.1.4 All employees should be trained on how to prevent, detect, and respond to threats or terrorist actions so they can recognize threats to security and respond if necessary.

3.1.5 Ongoing security consciousness and the importance of security procedures should be promoted.

3.1.6 Personnel involved in the transport, handling, and storage of meat, poultry, and egg products should be trained in procedures that will ensure the security of these products (e.g., train dock and security personnel should be trained on documentation requirements for incoming and outgoing shipments).

3.1.7 Appropriate personnel should be trained in security procedures for incoming mail, supplies, and equipment deliveries.

3.1.8 Mail handlers should be trained to recognize and handle suspicious mail using U.S Postal Service guidelines.

3.1.9 Procedures should be in place to ensure employees know emergency procedures and contact information.



4.0.0 Secure the Facility

4.1.0 Access

4.1.1 A positive ID system for employees should be maintained.

4.1.10 Restrict access to computer data systems. Protect those using firewalls, virus detection systems and secure passwords, changing them routinely.

4.1.11 Restrict access to outside water tanks, water supplies, ice machines, and conveying water pipes.

4.1.12 Restrict access to central controls for heating, ventilation, and air conditioning (HVAC), electricity, gas, and steam systems to prevent contamination from entering the air distribution systems.

4.1.13 Restrict access to computer data systems.

4.1.14 Protect computer data systems using firewalls, virus detection systems and secure passwords, and changing them routinely.

4.1.15 Restrict access to outside water tanks, water supplies, ice machines, and conveying water pipes.

4.1.16 Restrict access to central controls for heating, ventilation, and air conditioning (HVAC), electricity, gas, and steam systems to prevent contamination from entering the air distribution systems.

4.1.2 Identification of visitors should be required.

4.1.3 Visitors to facilities should be escorted at all times.

4.1.4 Collect company-issued IDs, keys and change lock combinations when a staff member is no longer employed by the company.

4.1.5 Ensure clear identification of personnel to their specific functions (e.g. colored hats or aprons, ID cards).

4.1.6 Restrict types of personal items allowed in the establishment, especially firearms or other weapons.

4.1.7 Secure and restrict access to facilities, transportation trucks, trailers, or containers, locker rooms, and all storage areas with alarms, cameras, locks and fences or other appropriate measures, to prevent access by unauthorized persons.



4.1.8 All visitors should be escorted while on the premises. Establish procedures for handling unauthorized persons in a restricted access area.

4.1.9 Control access to food products by unauthorized persons by limiting access to food delivery, storage, food ingredient, and chemical storage areas.

4.2.0 Shipping/Receiving

4.2.1 Consider developing a checklist for shipping and receiving procedures (this can also help identify anomalies).

4.2.10 Apply seals to all containers being shipped and maintain a seal log. Have a system in place to verify seal numbers and the integrity of the seals throughout the distribution process.

4.2.11 Ensure security procedures are in effect for interim storage at in-transit warehouses.

4.2.2 Loading docks should be secured to prevent unauthorized deliveries.

4.2.3 All deliveries should be scheduled and truck drivers should show proper identification upon arrival.

4.2.4 Shipping documents should contain product information, name of carrier(s), driver information, and seal numbers.

4.2.5 Establishments should require that incoming shipments are sealed with tamper-proof, numbered seals, and that the seal numbers are shown on the shipping documents for verification prior to entry to the facility.

4.2.6 Shipping documents with suspicious alterations should be thoroughly investigated. Product should be held and segregated during the investigation process.

4.2.7 Ensure that the doors of shipping trucks, trailers, and containers are not left open when picking up a load from a warehouse.

4.2.8 Ensure shipping trucks, trailers, and containers are secured after loading is complete.

4.2.9 Lock transportation trucks, trailers, and containers when not in use, during meal breaks and at night



4.3.0 Facility

4.3.1 Designate limited and specific entry and exit points for people and trucks.

4.3.2 Secure all access and exit doors, vent openings, windows, outside refrigeration and storage units, trailer bodies and bulk storage tanks.

4.3.3 Ensure adequate interior and exterior lighting at the facility.

4.3.4 Parking areas for visitors should be situated away from the main facility, if practical. Vehicles of employees and visitors should be clearly marked (e.g., placards, decals). This is intended to identify vehicles authorized to be on the premises and deter bombing attempts.

4.3.5 Hazardous chemical storage areas or rooms should be secured and located away from food preparation and storage areas. In addition, they should be constructed and safely vented in accordance with national or local building codes.

4.3.6 Incoming mail should be handled in an area of the facility separate from food handling, storage, or preparation areas.

4.3.7 Install backflow devices on all water supply equipment.



5.0.0 Monitor Operations

5.1.0 Employees

5.1.1 Maintain a daily shift roster to easily identify persons who are/should be on the premises and indicate that they are in their appropriate location.

5.1.2 Provide appropriate level of supervision to all staff, including food handlers, cleaning and maintenance staff, and computer support staff.

5.1.3 Monitor employees for unusual behavior (e.g., staying unusually late, arriving unusually early, taking pictures of the establishment, or removing company documents from the facility).

5.2.0 Shipping/Receiving

5.2.1 Purchase all food ingredients, food products, and packaging materials only from known, reputable suppliers. Require Letters of Guaranty, if possible.

a logbook of seal assignments.

5.2.2 Require locked or sealed trucks, trailers, or containers for deliveries. Maintain an inbound load verification logbook. Verify inbound trucks for seal numbers and integrity and load manifest. Document seal numbers and the truck or trailer number.

5.2.3 Hold unscheduled deliveries outside the premises pending verification of shipper and cargo. Do not accept deliveries from, or release product to, unknown shippers using only cell phone numbers or known shippers with unknown phone/fax numbers or e-mail addresses.

5.2.4 Supervise off-loading of incoming products, ingredients, packaging, labels, and product returns. Only a supervisor or other agent of the owner should break seals and sign off in the trucker’s logbook.

5.2.5 Have a system in place to ensure integrity of product when seal will need to be broken prior to delivery due to multiple deliveries or for inspection by government officials.

5.2.6 Verification of the last company seal put on a truck should be available throughout the delivery chain.

5.2.7 When examining incoming products and their containers for evidence of tampering or adulteration, establish a random or other sound plan for checking incoming product.



5.2.8 When examining incoming products and their containers for evidence of tampering or adulteration, the warehouse supervisor should note on the bill of lading any problems with the condition of the product, packaging, labels, and seals.

5.2.9 When examining incoming products and their containers for evidence of tampering or adulteration, products known or suspected of being adulterated are not to be accepted.

5.2.10 When examining incoming products and their containers for evidence of tampering or adulteration, food should be checked for unusual odor or appearance.

5.2.11 Processors should arrange with receivers to sample and conduct microbiological or other tests on products, including an in-house testing plan prior to shipment.

5.2.12 Processors should arrange with receivers to sample and conduct microbiological or other tests on products, with results being compared with pre-shipment results to determine whether adjustments are needed in transport methods or procedures.

5.2.13 Processors should arrange with receivers to sample and conduct microbiological or other tests on products and establish chain-of-command procedures providing for the proper handling of samples.

5.2.14 Processors should arrange with receivers to sample and conduct microbiological or other tests on products and samples should be clearly marked and kept in a secure area.

5.2.15 Processors should arrange with receivers to sample and conduct microbiological or other tests on products and ensure all trucks leaving the facility are sealed.

5.2.16 Processors should arrange with receivers to sample and conduct microbiological or other tests on products and maintain

5.3.0 Storage/Water

5.3.1 Maintain an accurate inventory of food and chemical products and check daily to allow detection of unexplained additions to, or withdrawals from, existing stocks.

5.3.2 Maintain an accurate inventory of food and chemical products and check daily to allow detection of unexplained additions to, or withdrawals from, existing stocks.

5.3.3 Information about the sources and date of shipment should be included as part of the inventory of food and chemical products and checks made to same.

5.3.4 All discrepancies related to the detection of unexplained additions to, or withdrawals from, existing stocks should be investigated immediately.



5.3.5 Random inspection of storage facilities (including temporary storage trailers or containers), trucks, trailers, containers, and vessels should be made regularly.

5.3.6 A log of the results of random inspection of storage facilities (including temporary storage trailers or containers), trucks, trailers, containers, and vessels should be maintained.

5.3.7 An individual should be designated to conduct the inspections and maintain the record-keeping system for random inspection of storage facilities (including temporary storage trailers or containers), trucks, trailers, containers, and vessels regularly.

5.3.8 A daily inventory of hazardous chemicals or other products should be made, and all discrepancies should be investigated immediately.

5.3.9 Regularly test water and ice supplies to ensure they are safe to use.

5.3.10 Inspect water storage and conveying lines inside and outside of the facility regularly for tampering or irregularities

5.4.0 Respond

5.4.1 Be aware of and report any suspicious activity to appropriate authorities (e.g., unscheduled maintenance, deliveries, or visitors should be considered suspicious).

5.4.2 Processors, transportation managers, and wholesale and retail distributors should ensure traceability and recall of products.

5.4.3 Ensure procedures are in place to accomplish a complete, rapid recall, and removal from the market of any shipment of meat, poultry, and egg products in the event products are found to present a hazard to public health.

5.4.4 Keep detailed production records, including packaging lot or code numbers and where finished product was stored or served.

5.4.5 Trace Forward – Shippers (including operators of federally inspected meat, poultry, and egg processing establishments) and carriers should have systems in place for quickly and effectively locating products that have been distributed to wholesalers and retailers.

5.4.6 Trace Backward – Retailers, wholesalers, carriers and others who have received products from federally inspected meat, poultry, or egg processing establishments should be able to identify the source of the products quickly and efficiently.

5.4.7 Investigate threats or reports of suspicious activity swiftly and aggressively.



5.4.8 In the event of a food security emergency, first contact local law-enforcement authority.



6.0.0 Additional Guidance for Specific Modes of Transportation

6.1.0 General Guidance for All Modes

6.1.1 Make certain that contracted shippers and consignees have security measures in place to ensure product integrity and traceability and verify that they are meeting contractual security obligations.

6.1.2 Ensure that physical boundaries of their facility/terminal are secure.

6.1.3 Ensure that background checks are conducted for all potential employees by shipping, trucking, and drayage companies.

6.1.4 Ensure that a positive identification system is in place for all employees.

6.1.5 Recommend requiring participation in the Transportation Worker Identification Card (TWIC) program which is coordinated by the Transportation Security Administration.

6.1.6 Ensure that a security training and awareness program for all employees on how to prevent, detect, and report suspicious activity is conducted.

6.1.7 Ensure that a system is in place to track movement of products and truck, trailer, and containers/vessels (e.g., Global Positioning System).

6.1.8 Ensure that a record-keeping system to document chain-of-custody, which will aid in tracing product, is maintained.

6.1.9 Ensure that contracted shippers and consignees use a system (e.g., X-ray scanners) to detect tampering and radiological, biological, and chemical agents in shipping containers.

6.1.10 Ensure that policies and procedures are in place for the handling of suspicious product; and ensure all containers are properly secured at all times when held in storage yards.

6.2.0 Aviation

6.2.1 Although fewer meat, poultry, and egg products are transported by air than by other modes, it is still critical to ensure the security of these products when this mode of transport is utilized.

6.2.2 Check all trucks entering a terminal facility.



6.2.3 Trucks carrying meat, poultry, and egg products should have seal logbooks and the seals should be examined and numbers verified.

6.2.4 Inspect containers arriving at a terminal for loading before admitting them to the terminal.

6.2.5 Immediately report suspicious or inconsistent servicing of a container to terminal security.

6.2.6 Design internal and external packaging so customers will be able to determine if the product was tampered with and can immediately notify you.

6.2.7 Provide instructions and contact information with shipment.

6.3.0 Truck

6.3.1 Develop and implement procedures for drivers to ensure security of the truck, trailer, or container when stopping for meals, gas, and repairs.

6.3.2 Transportation trucks, trailers, and containers should be designed and built to make locking and sealing easy and should permit effective inspection.

6.3.3 Examine trailer doors and seals to ensure that the trailer can be secured.

6.3.4 Keep empty trailers locked at all times.

6.3.5 Check product load periodically during transit to ensure its integrity has not been compromised (e.g., use weigh station stops as an opportunity to check condition of products).

6.3.6 Processors, distributors, and transporters should have action plans for emergencies, such as breakdowns or reporting criminal activity.

6.3.7 The plans should include notification of the relevant Federal, State, and local authorities.

6.3.8 Drivers should be trained to take appropriate precautions while en route (e.g., do not pick up hitchhikers, do not discuss the nature of cargo at stops, be aware of surroundings, lock truck, trailer, or container when unattended and avoid low-lit areas).

6.3.9 Prevent unauthorized access to delivery truck, trailer, or containers.

6.3.10 Require drivers to secure truck, trailer, or containers while en route, including while on break, at restaurants, at overnight stays, etc.



6.3.11 Drivers should report unusual circumstances, such as being followed, to appropriate authorities.

6.3.12 Develop procedures to be followed when reefer boxes or trailers are found unlocked.

6.3.13 Deter diversion or hijacking of cargo by keeping track of trucks. Ensure time logs for trips are maintained and provide trucks with communication and tracking equipment.

6.3.14 Hold drivers accountable for ensuring security measures are taken to prevent contamination of meat, poultry, and egg products while under their control.

6.4.0 Maritime

6.4.1 Check all trucks entering a terminal facility. Trucks carrying meat, poultry, and egg products should be sealed, drivers should have seal logbooks, and the seals should be verified.

6.4.2 Seals should be removed in the presence of terminal personnel so they can verify the seal number and its integrity.

6.4.3 Immediately report suspicious or inconsistent servicing of a container to terminal security.

6.4.4 Supervise opening of ship hatches.

6.4.5 When unloading product from sea-going vessels, inspect seals for evidence of tampering. Have documentation system in place.

6.4.6 Document the cutting of seals (e.g., when seal is cut for inspection by government official).

6.4.7 Shipping line agents should provide importers and customs brokers with a record of vessel discharge and checks at discharge and in transit.

6.4.8 Establish policy and procedures to download reefer electronic information during inspection (this will also allow identification of anomalies).

6.4.9 Have reporting system in place when the discharging of any product looks suspicious or the product shows evidence of tampering.

6.4.10 The terminal facility should be locked during meal breaks and at night.

6.4.11 Facility doors should be closed immediately after the truck/trailer has pulled away from dock.



6.4.12 Importers and Exporters may want to consider participation in government initiatives pertaining to maritime shipment of products such as: Customs-Trade Partners Against Terrorism (C-TPAT), Operation Safe Commerce, Container Security

6.5.0 Rail

6.5.1 Use boxcars dedicated for food products.

6.5.2 Employ measures to secure loaded and empty containers from tampering when being stored at the train yard for any length of time.

6.5.3 Locks/seals on boxcars should be inspected at pull and place.

6.5.4 Review shipping documents upon arrival at the train yard and before the train engineer leaves.

6.5.5 Inspect integrity of seals upon arrival and before departure of the load.


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