Managing your food defense plan

Once the food defense plan has been written and implemented, the team needs to consider how the plan will be managed for the long term. Managing the plan may include periodic tests and annual reviews to see if the plan is still effectively reducing the risk of intentional contamination or if it needs to be updated to reflect changes in your operation. In addition to changes in your operation, a critical contamination event at another operation may prompt a test or review of your plan to ensure that you have sufficient countermeasures in place to reduce the risk of a similar incident. The food defense plan team should determine practical guidelines for managing the plan. Once the guidelines are in place, the food defense coordinator will be responsible for notifying the team when action is required.

Plan reviews
Reviews of the food defense plan should be conducted annually at a minimum but can also be triggered by changes in your operation, such as a new product line or category of livestock, change of supplier, expanded customer base, addition of new technology, newly developed or updated procedures or change of food defense coordinator. The review should answer the following questions:

• Are the countermeasures continuing to reduce the risk of intentional contamination in vulnerable areas?
• Do new products or livestock categories/species require additional countermeasures to reduce the risk of intentional contamination?
• Do new or updated procedures require additional countermeasures?
• Has supplier, customer and employee contact information been updated?

A record should be used to track food defense plan reviews and kept with the food defense plan.

Plan tests
Tests of the food defense plan can be conducted randomly or scheduled two to four times a year, as determined by your food defense team, which should select an interval that is practical for your operation. The general purpose of these tests is to determine if the countermeasures are reducing the risk of intentional contamination. If the countermeasures are not adequately reducing risk, then new countermeasures should be developed and implemented. Tests that might be used include exercises in mock tampering, livestock quarantine, product recall, random food security checks and computer system challenges. Specific areas to be checked include:

• Entry points
  Check that entry points are locked or secured.
• Signage
  Check that signage is still in place and legible.
• Procedures
  Conduct random checks for compliance with procedures regarding uniforms and employee personal items.
• Inventory
  Check inventory log sheets of hazardous materials to see if files are being properly maintained.
• Entry logs
  Check that entry logs maintained for sensitive areas are accurate and up to date.

A record should be used to track food defense plan tests and kept with the food defense plan.

Employee training
Management of the food defense plan must also include ongoing employee training. New employees must receive basic instruction about their responsibilities in regards to the food defense plan. All employees need to know:

• What type of suspicious individuals or activities should be reported
• Who they should report suspicious individuals or activities to
• Which employee will be responsible for calling the authorities in a case of suspected intentional contamination
• What each employee’s responsibilities are regarding security procedures such as locking up or filing inventory or access log sheets at the end of the day

The team should set up procedures that ensure all employees are updated on changes to the food defense plan and to record employee food defense training activities. A record similar to the sample above should be used to track employee food defense and kept with the food defense plan.

The objective of a food defense plan is to help you provide a safe, high-quality product to your customers, keep your employees safe and well informed, and protect the economic health of your business. A well-thought-out management plan will help your food defense plan work for you for the long term.