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This information can be used to develop food safety and quality programs that meet the requirements of modern Regulatory, Customer and Industry Standards:
When considering the development, documentation, and implementation of Site and Supply Chain Security Management within food safety and quality management systems, the following information should be considered to ensure effective outcomes:
Security is a critical issue for every food industry sector and related participants. It is important to consider the potential for people to influence the safety or quality of a food product if the environment and conditions under which it is produced, handled, stored, or transported are not appropriately controlled.
Site and Supply Chain Security Management generally involves the control of potential deliberate contamination of foods by a variety of potential threats including biological, chemical, and physical hazards. Deliberate contamination of foodstuffs is a criminal activity that involves willful intent to inflict harm or damage. The motivation for deliberate contamination often includes the ability to cause serious illness and deaths following consumption of affected products. This is aligned with the desire to cause economic damage whilst including inspiring fear among the public and loss of confidence in the safety of food supply chains.
Site and Supply Chain Security should always be considered as a separate element from food safety, though elements of the two may be shared when applied to a food business. Food safety generally addresses the ‘unintentional’ contamination of food products by biological, chemical, or physical hazards. Because of the differences in applications for food safety and Site and Supply Chain Security, a HACCP Plan should not be applied as a substitute for a detailed Site and Supply Chain Security plan; however, the HACCP methodology is commonly used as a risk assessment tool to define Site and Supply Chain Security related risks.
Where the HACCP Methodology is applied for the identification and management of Site and Supply Chain Security hazards, this may be referred to as TACCP. Threat Assessment Critical Control Point or TACCP is a methodology used to prevent deliberate and intentional sabotage and espionage events and related scenarios.
Site and Supply Chain Security Management applications may include the following aspects:
It is important when initiating some of the above-mentioned components, that the rights of staff, visitors, and contractors are not compromised. The requirements of Privacy legislation are commonly used as a basis for the implementation of systems that track people’s movements, especially where the use of video surveillance is concerned.
When evaluating the potential Site and Supply Chain Security exposure of any food business, the Senior Management should consider a large variety of people who may potentially execute an attack from both inside and outside the business operation. Potential attacks may include both opportunistic attacks by single individuals and planned attacks by organized groups.
The following listing provides some examples of people who may be motivated to contaminate or sabotage food products from both internal and external sources:
Internal Sources
External Sources
Additional threats are often identified through internal sources as perpetrators often have access to food business procedures and protocols that may make their goals more readily achievable. Food businesses should liaise with relevant regulatory authorities regarding potential local threats to their operation.
The following may be considered when conducting a Site and Supply Chain Security risk assessment for your food business:
A clear understanding of potential threats and what needs to be protected will assist in ensuring that effective and appropriate control measures can be applied. It is important to identify the most vulnerable elements of any food business operation. Historical or current Site and Supply Chain Security incidents built from within your business and externally can be used as resources to ensure you are considering an appropriate range of potential Site and Supply Chain Security hazards.
The application of the Site and Supply Chain Security Management control measure within any food business operation should be applied according to the defined severity of outcomes related to each nominated control measure. As with most business management systems, it is important to consider that the identified potential Site and Supply Chain Security risks should be controlled in order from the one with the most severe potential outcomes, to the one with the least severe potential outcomes. This method generally facilitates a practical approach to resource allocation as applicable to each unique food business operation. Contemporary Site and Supply Chain Security Management protocols rely on a multi-layered approach in ensuring effective outcomes. A multi-layered approach, for example, may include elements such as:
Potential security measures include perimeter controls through the use of fencing, gates, guard stations, and key card or radio frequency emitting device access. All entryways, windows, vents, and delivery docks should be secured. Exterior lighting and closed-circuit camera systems may also be used to support outcomes.
Staff training for Site and Supply Chain Security Management. Logging of employee entry and exit is a common method for tracing staff movements within any food business operation.
Employment of internal or external security monitoring and reaction contractors or consultants, security cameras, or security inspections. This may also include the application of central controls for services like airflow, water supply and electricity, and nomination of supervision for contractors working within the operational areas of the food business.
Maintaining control over access to the process and the application of Site and Supply Chain Security Management procedures. This may include the application of tools such as Chemical Usage Inventories, which can track excessive or unauthorized chemical use which may potentially be used to deliberately contaminate foods. Receival, Dispatch, and Transport security measures may include purchasing raw materials only from designated approved suppliers, establishing controls on incoming deliveries, limiting driver access to the food business during deliveries, thorough inspection and inventory accounting of delivered materials, use of tamper-evident packaging for finished products, and the use of tamper-evident seals on incoming and outgoing transport.
Contemporary Food Safety and Quality programs and systems often include requirements for the securing of transport modules or vehicles to reduce the risk of deliberate sabotage or terrorist-type events. In such cases, transport modules or vehicles may be secured physically, or by a system that permits the real-time acknowledgment of potential tampering. An example of a physical transport security mechanism may include the physical locking of transport modules or vehicles where these can only be opened by nominated participants within the supply chain. Where security systems are used instead of physical measures, these may include the implementation of controlled tamper-proof transport seals, mandated transport protocols, and/or specified tamper-proof mechanisms for the product (rather than the transport module or vehicle).
It is generally considered best practice to ensure that any implemented Transport Security protocols, physical mechanisms, and related controls are documented and agreed upon with relevant parties to provide a consistent controlled approach. Related requirements are commonly included within Transport specifications and service agreements between the dispatching entity, the receiving entity, and any other process participants and stakeholders.
Maintaining control over access to product and raw materials and the application of Site and Supply Chain Security Management procedures. Raw Material and product storage areas security will protect against the intentional misuse of ingredients or non-food items as food adulterants. Storage areas should be adequately secured and monitored, with access limited to authorized personnel only. Using elements such as these allows for an approach that supports Site and Supply Chain Security Management from across the entire food business operation.
The following elements may be considered in the implementation of a Site and Supply Chain Security Management plan:
Responsibility for Site and Supply Chain Security Management should be designated to an individual with a thorough understanding of the food business operation (typically a member of the Senior Management Team). Further delegations may include specific individual responsibilities for elements of the Site and Supply Chain Security Management systems.
All staff, visitors, and contractors should be trained in relevant aspects of the Site and Supply Chain Security Management system. The purpose of security awareness training is to ensure that all relevant people are aware of their Site and Supply Chain Security Management responsibilities. Site and Supply Chain Security Management training should address system requirements including identification badges, access control protocols, access to restricted areas, protection of critical Site and Supply Chain Security Management risks, and procedures for reporting suspicious or confirmed inappropriate activities. Understanding the threat of intentional contamination and the potential outcomes of such an incident should assist staff, visitors, and contractors in ensuring the ongoing application of the prescribed Site and Supply Chain Security Management control measures.
All staff involved with the handling of food must be trained to recognize and practice good manufacturing practices and safe working procedures at all times. It is generally considered best practice to ensure all new employees complete relevant induction training before actually starting within their new position. As a base level requirement, food and personal hygiene training should be addressed for all relevant staff during the induction process. Supervisory staff may be required to undertake specific and more comprehensive food safety training in the related areas.
It is also important to consider that Visitors and Contractors may also require induction training commensurate with their interactions within any food business. Food business policies should define what induction, GMP, and personal hygiene training are required for non-staff members entering the premises.
Current, regularly reviewed, and updated contact listings should be maintained as an element of any Site and Supply Chain Security Management plan. Contact listings should include names, positions, departments, addresses, business and after-hours phone numbers and email addresses for key internal food business contacts, customers, regulatory departments, and officials. Contact listings should also include back-ups for instances in which the primary contacts can’t be made.
It is important to consider that an actual Site and Supply Chain Security incident may very realistically lead to a food recall or food withdrawal. Procedures and flow processes should be clearly defined to ensure a food recall or food withdrawal is facilitated where required as an outcome of a Site and Supply Chain Security incident.
Many materials are often prohibited in food production areas due to their potential for causing harm to consumers, particularly as deliberate contaminants. The presence of the following items in production, packaging, storage, and handling areas may be considered a significant risk:
Chemicals used within food businesses must be properly stored and located with insecticides and rodenticides stored separately from cleaning compounds and other chemicals. All chemicals and pesticides must be stored separately from food, food contact surfaces, and single-use and single-service articles. In this context, the term separate does not include storage of toxic chemicals above food, food contact surfaces, single-use, and single-service articles.
The storage of chemicals must also meet local regulatory and environmental protection requirements.
Where necessary, adequate facilities for the storage and handling of food, ingredients, and non-food chemicals including cleaning chemicals, pest control chemicals, lubricants, and other maintenance chemicals must be provided.
Where appropriate, food storage and handling facilities should be designed and constructed to:
The type of facilities required will depend on the nature of the food items being stored and handled by a food business. Where necessary, segregated and secure storage facilities should be provided for cleaning chemicals, pest control chemicals, lubricants, and other maintenance chemicals. Storage facilities for ingredients, packaging, and other materials should also be appropriately secured and adequately ventilated.
It is paramount to food safety that visitors and contractors behave appropriately when visiting a food manufacturing business. Any visitors and contractors on the premises and their actions are the responsibility of the management.
Visitors and contractors entering a food manufacturing, processing or handling area should, where appropriate, wear protective clothing and adhere to the other personal hygiene provisions in this section. A policy to this effect should be documented, and a copy provided to each contractor and visitor before entering the site.
It is generally considered standard practice for visitors and contractors to be signed into a food business and identified by an appropriate badge or gate pass. A gate pass is a printed document that needs to be filled out by the person who wants to move out of the premises of the organization. Gate pass can be used to authorize the movement of humans, materials, and machines to or from the premises of the organization. It will help to monitor and track all the movements in an organization. Some of the most commonly used gate pass types include ‘Employee Gate Pass’ and ‘Materials Gate Pass.’ A gate pass helps an organization to get a record of the time movement and to track the person responsible for the movement. It can also prevent theft and unauthorized carrying of materials and improve discipline inside the organization. Visitors may also be required to review documented materials relating to food safety and workplace health and safety before admission to critical areas of operation. Depending on the purpose of the visit, visitors, contractors and internal staff not attired appropriately may be required to wear a hygienic outer covering such as a fresh lab coat or full uniform while visiting food production areas. Visitors and contractors should be accompanied by an authorized staff member at all times unless they have conducted appropriate induction training and have passed established medical and security screening protocols.
As elements of established site security protocols, employees of the business should be encouraged through specified training to challenge anyone seen within operational areas of the site if they are not appropriately identified or accompanied by an authorized person.
For higher-risk or larger food businesses, it is common for a Visitor and Contractor induction process to be developed, documented, and implemented to ensure the ongoing compliance of Visitors and Contractors to the food business. This is particularly important where, for example, maintenance contractors are used long-term and are permitted to work unaccompanied within operational areas of the food business. In this context, it is important to consider that Visitors and Contractors, though they are expected to comply with the standard policies and procedures, may not appreciate their legal responsibilities in meeting such requirements.
In instances where, for example, maintenance contractors are used long term, it is also common for re-induction to be scheduled, conducted, and recorded to ensure ongoing compliance with the nominated Visitor and Contractor requirements.
It is also common for labor hire companies to conduct relevant training and induction processes on behalf of the company which they will provide to the temporary staff. In this case, a food business must be using labor supplied through a company responsible for relevant and induction training to verify and validate the facilitation and outcomes of such activities. This is commonly considered as an element of the approved supplier of service provider programs.
Cyber Security threats typically refer to the possibility of a successful cyber-attack that aims to gain unauthorized access, damage, disrupt, or steal an information technology asset, computer network, intellectual property, or any other form of sensitive data. Cyber Security threats can come from within an organization by trusted users or externally from remote locations by unknown parties.
Cyber Security threats can impact the food supply chain in many ways. Cyber threats could impede the movement of materials and ingredients from suppliers to manufacturers. Shipments from manufacturers to customers could be delayed or re-routed to the wrong locations. A cyber threat could shut down internal systems and even jeopardize the integrity and safety of food products. Cybersecurity processes are critical and essential to keep systems and processes running, food-safe and the supply chain intact. There are many types of cyber threats the food sector needs to be aware of, including:
If your food business supplies foodstuffs manufactured to a customer’s specifications, it is important to consider any specific Site and Supply Chain Security Management Development requirements in relation to their items.
Document: A document provides guidance and/or direction for performing work, making decisions, or rendering judgments that affect the safety or quality of the products or services that customers receive.
Documented policies, procedures, work instructions, and schedules form the basis of any food safety and quality management system. The following documentation formats may be considered to ensure ongoing compliance with specified requirements for Site and Supply Chain Security Management:
If your food business supplies foodstuffs manufactured to a customer’s specifications, it is important to consider any specific Site and Supply Chain Security Management Documentation requirements in relation to their items.
You may wish to visit the Site and Supply Chain Security Management Templates section of haccp.com for examples of Site and Supply Chain Security Management documentation, record, and resource formats commonly applied within food safety and quality systems.
Implementation: Implementation is the application of documented food safety and quality system elements into the actual business operation.
The implementation of Site and Supply Chain Security Management within any food business requires genuine commitment from senior management, staff, and visitors to ensure the nominated goals of implementation are achievable on an ongoing basis. It is a step that requires significant planning and consideration of general and specific food business circumstances to ensure the outcomes of Site and Supply Chain Security Management do not negatively impact the safety and quality of the food items dispatched from the business.
Implementation of Site and Supply Chain Security Management must include a clear definition of responsibilities and authorities for all levels of participation by senior management, staff, and visitors to the site.
When implementing Site and Supply Chain Security Management within a food safety and quality system, you may wish to consider the following requirements before completion:
If your food business supplies foodstuffs manufactured to a customer’s specifications, it is important to consider any specific Site and Supply Chain Security Management Implementation requirements in relation to their items.
Monitoring: Monitoring is the act of reviewing and confirming measurable parameters of a defined process or product status.
Monitoring requirements within food industry sectors are generally identified against limits of acceptability defined within HACCP plans, implementation procedures, and work instructions. Monitoring usually includes some element of record-keeping, which may be maintained manually or through digital systems. It is important to consider that advancements in technology have spawned many systems and processes which are self-monitored and or self-adjusted when variances are identified. Regardless of the system used; The goal of any monitoring activity is to provide sufficient evidence that any limit of acceptability has been met.
Traditional Site and Supply Chain Security Management monitoring requirements include manual recording and the application of corrective actions when the results of monitoring are found to be outside acceptable limits. Corrective Actions should also generally be strongly linked to the monitoring process where applied to ensure full traceability of the applied actions.
Common monitoring activities and record formats may be applicable to Site and Supply Chain Security Management:
Corrective Action: Corrective action is mandatory action to be taken when a deviation to the Quality System occurs, particularly in relation to a Critical Control Point.
Preventative Action: At any step in the process where a hazard has been identified, preventive action must be put into place to prevent re-occurrence.
Corrective Action and Preventative Action is implemented to ensure that any identified non-conformance issues are documented, investigated, and rectified within appropriate time-frames. Corrective action is any action applied to regain control over a product, process, policy, or procedure that has been identified as being non-conforming or outside nominated limits of acceptability. Preventative action is any action applied to prevent any identified non-conformance from reoccurring.
The outcomes of corrective and preventative actions should result in regained process control after effective application. Specified corrective actions are commonly linked to the HACCP Plans and the food business certification process.
Below are Corrective Action and Preventative Action examples which may be associated with Site and Supply Chain Security Management related non-conformance:
When investigating the root cause of observed non-conformances or customer complaints where product contamination is involved, it is important to consider that the root cause of such a scenario may be due to a deliberate contamination event. Records of the investigation Corrective Action and Preventative Action should detail considerations of potential deliberate sabotage or contamination as part of a holistic process.
If your food business supplies foodstuffs manufactured to a customer’s specifications, it is important to consider any specific Site and Supply Chain Security Management Corrective Action requirements in relation to their items.
You may wish to visit the Corrective Action and Preventative Action section of haccp.com for examples of best practice applications for this food safety and quality system element.
Verification: The act of reviewing, inspecting, testing, checking, auditing, or otherwise establishing and documenting whether items, processes, services, or documents conform to specified requirements.
Verification is the detailed review of all food safety and quality system elements to confirm that they are effectively developed, documented, implemented, monitored, and reviewed. All food safety and quality system elements, including documented policies, procedures, training, HACCP plans, and their operational applications must be verified on an ongoing scheduled basis. The verification process commonly includes a defined schedule for which verification activities are required, how often they are conducted, who is responsible, and detailed documented procedures for each nominated verification activity.
The general goal of an established verification process is to ensure any systemic non-conformance issues are identified and rectified within an appropriate time frame. When non-conformance issues are identified through the verification process, Corrective Actions and Preventative Actions should be implemented to ensure they do not impact the effectiveness of the food safety and quality system.
The following examples of verification activities may be applicable to Site and Supply Chain Security Management:
If your food business supplies foodstuffs manufactured to a customer’s specifications, it is important to consider any specific Site and Supply Chain Security Management Verification requirements in relation to their items.
You may wish to visit the Verification Activities section of haccp.com for examples of best practice applications for this food safety and quality system element.
Validation: The process of gathering evidence to provide a scientific basis for the documented act of demonstrating that a procedure, process, and activity will consistently lead to the expected results. It often includes the qualification of systems and equipment.
Validation is the provision of evidence to support the limits of control or acceptability for food safety or quality parameters nominated within systemic elements. Limits of control or acceptability are commonly included within documented food safety and quality systems elements such as procedures, HACCP plans, and specifications.
Common sources of validation include regulatory and legislative standards, finished product specifications and customer requirements, industry codes of practice and guidelines, verified and validated research, historical product, and process control outcomes, and analytical testing.
The general goal of an established verification process is to ensure any systemic non-conformance issues are identified and rectified within an appropriate time frame. When non-conformance issues are identified through the verification process, Corrective Actions and Preventative Actions should be implemented to ensure they do not impact the effectiveness of the food safety and quality system.
Validation activities are commonly defined within the verification schedules and procedures of established food safety and quality management systems.
The following examples may be applicable to the validation of the limits of control or acceptability for Site and Supply Chain Security Management:
Mock Site and Supply Chain Security Drills security drills should be scheduled, conducted, recorded, and reviewed on an ongoing basis to ensure the effectiveness of related procedures and protocols. The outcomes of such activities should be used to apply changes where non-conformance issues or opportunities for improvements are identified.
If your food business supplies foodstuffs manufactured to a customer’s specifications, it is important to consider any specific Site and Supply Chain Security Management Validation requirements in relation to their items.
You may wish to visit the Validation Activities section of haccp.com for examples of best practice applications for this food safety and quality system element.
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Skills and Knowledge: Skills and knowledge are attributes of human interactions commonly linked to competency within any specific job-related task.
Training and competency requirements for Site and Supply Chain Security Management must be ongoing, including regular scheduled reviews to ensure the effectiveness of training and competency outcomes.
Team members who have defined responsibilities regarding Site and Supply Chain Security Management should have knowledge including:
Team members who have defined responsibilities regarding Site and Supply Chain Security Management should have skills including:
Team members who have defined responsibilities regarding Site and Supply Chain Security Management should have access to resources including:
If your food business supplies foodstuffs manufactured to a customer’s specifications, it is important to consider any specific Site and Supply Chain Security Management Training, Competency, and Resources requirements in relation to their items.
You may wish to visit the Training, Competency, and Resources section of haccp.com for examples of best practice applications for this food safety and quality system element.
haccp.com was created to support food businesses and food industry professionals in achieving and maintaining the stringent requirements of food industry compliance.