Food Safety Plan Needs to Extend Beyond HACCP

Food plants are fertile ground for product contamination from tiny microbes to terrorists. You need a plan that extends beyond HACCP.

By Mike Pehanich, Plant Operations Editor

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Preventive measures should be outlined to reduce risk. Test the plan's effectiveness in mock trials and brainstorming exercises.

Plans should focus on critical and vulnerable areas of the plant.

"Apply the highest security to the most critical components of your food operation," advises Vitiello, who also suggests a "layered" approach consisting of physical, personnel and operational security measures.

Yud-Ren Chen, an agricultural engineer with USDA's Agricultural Research Service, is developing a computer-directed scanning system that may speed inspection of the nearly 8 billion chickens processed annually through federally inspected U.S. plants.
Tyson Foods, which is now North America's largest food company, according to Food Processing's 2005 Top 100© report, has ratcheted plant security up several notches to protect product, customers and plant personnel. "Our biggest concern is food safety," says John Tyson, chairman and CEO. "It impacts the consumer. It impacts consumer confidence. It impacts the strength of the brand."

"We have added entry security measures, issuing badges and seeing that only specific people are admitted into certain places," notes complex manager Irvin. "We have added guards, as well. And we continue to upgrade our security measures all the time."

External security measures came in several phases at Tyson. They included the addition of fences, cameras, motion detection devices and guarded doors.

FSIS encourages plants to post "no trespassing" signs, to monitor the plant perimeter for suspicious activity and unauthorized entry and to introduce guards, alarms, cameras and other appropriate security hardware at all access points. Emergency exits should have alarms and self-locking doors that can be opened only from the inside. Carefully monitor and document personnel entering and leaving the plant. (See FSIS Security Guidelines for Food Processors for an extensive list of outside security measures.)

Inside security measures include marking and securing restricted areas, limiting access to labs and restricting access to central airflow, water, electricity and gas controls. Emergency alert systems should be operational at all times and all employees instructed in their use. Computer systems must have effective password, virus and firewall protection. (See FSIS Security Guidelines for Food Processors for an extensive list of inside security measures.)

Airflow systems should be designed so that contaminated rooms or areas can be isolated easily.

Process security and sanitation

At the core of every food security defense system should be a sound food safety program. HACCP programs provides a strong framework, helping to identify high-risk zones that merit extra watch and protective measures. But equally important, HACCP calls for practices that may help detect or prevent contamination and documentation that will help trace times and sources of product contamination and track down tainted product.

Processors of animal protein face multiple levels of safety concerns. Tyson, as the nation's largest protein processor, employs more HACCP-trained individuals than any company in the world. It has added a state-of-the-art quality assurance lab.

To provide an overlapping layer to its safety program, however, Tyson initiated the Sentinel Site Program, an environmental monitoring and product testing program that provides early warning alerts and allows plant personnel to prevent and eliminate listeria monocytogenes in Tyson facilities that produce ready-to-eat products. In effect, it monitors and validates the company's HACCP system with overlapping checking measures.

"It's a program of random site monitoring and contact and non-contact sampling, a scientifically valid method of testing," says Irvin. Some have credited it with elevating industry standards for testing for bacterial pathogens in ready-to-eat meats.

In addition to food contact surfaces on processing lines, coolers and freezers, non-contact surfaces - walls, floors and ceilings - also are tested weekly. The Sentinel Site Program calls for intensified monitoring at sites where a positive trace of the microorganism is detected and the holding of product in the event of a positive listeria reading at an RTE food contact surface critical control point.

The program has reduced the occurrence of listeria in process areas and risk of RTE product contamination. Tyson enters all Sentinel Site data into a common database to help assess equipment and plants. The data has helped to compare equipment and evaluate processes and procedures at different processing facilities to determine best practices.

FSIS offers these tips for securing slaughter and processing areas:
  • Establish procedures to monitor the operation of pieces of equipment (blenders, choppers, poultry chill tanks, etc.) to prevent product tampering.
  • Implement a program "to ensure the timely identification, segregation and security of all products involved" if a product is deliberately contaminated.
  • Have a validated procedure for trace-back of ingredients and raw materials and for trace-forward for finished products.
  • Material involved in rework should be examined for evidence of tampering before it is re-introduced to the processing area.
  • Verify the integrity of packaging for spices, restricted ingredients and pre-mixes.
  • Maintain accurate finished product inventory; account for all additions or withdrawals from stock.
  • Restrict access to the processing area to plant and FSIS personnel only.
  • Use a clear and apparent system of personnel identification, such as uniform color, to distinguish valid entry and presence in the processing area.
Don't let the remarkable record of safety in America's food supply or your own plant allow you to lower your guard. Attacks, whether planned or accidental, are most likely to occur when complacency has set in or an extremely high level of activity has caused plant personnel to cut corners. Defense at your plant helps to maintain confidence in America's entire food distribution system.

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