prelc

U.S. Department of Agriculture Food

Safety and Inspection Service

Model Food Security Plan

for
Meat and Poultry Processing
Facilities

Draft of April 2005

1.0 Introduction
In May 2002, the Food Safety and Inspection Service (FSIS) issued the FSIS Security
Guidelines for Food Processors to assist meat, poultry, and egg product plants in
identifying ways to strengthen their food security protection. In August 2003, the FSIS
Safety and Security Guidelines for the Transportation and Distribution of Meat, Poultry,
and Egg Products were issued, which focused on enhancing food safety and security in the

transportation and distribution segments of the supply chain. These guidelines are voluntary
and provide recommendations about types of security measures that may be used to prevent
contamination of meat, poultry, and egg products during processing, transportation, and
storage. A particularly important aspect of the guidelines was the recommendation that each
facility should develop and implement a Food Security Plan. The purpose of this document
is to provide additional guidance about the development and implementation of food
security plans for meat and poultry processing facilities.

2.0 Why Develop a Model Plan?

FSIS believes that the security of meat and poultry processing facilities can be enhanced
through the implementation of risk management techniques that are tailored for the needs of
each establishment. This process can be facilitated by the use of Food Security Plans. These
plans identify the types of preventive steps that establishment operators may take to minimize
the risk that food products under their control will be subject to tampering or other malicious
criminal actions.
The main value of a plan is to increase preparedness. Although the plan should be executed at
all times, it may be particularly helpful during emergencies. During a crisis, when stress is
high and response time is at a premium, a documented set of procedures provides facility
operators the ability to more readily execute standard response actions while focusing on an
appropriate course of action for the specific event. Therefore, Food Security Plans will be
particularly beneficial under elevated threat conditions, especially when there is reason to
believe that the food sector may be targeted for attack. Development and effective
implementation of prevention and response strategies at every establishment will improve the
security status of supply chains in the food sector.
FSIS understands that, in addition to concern for product liability and brand name protection,
market-driven forces have already caused some companies in the food industry to invest in
security enhancements for their establishments. One driver for these actions has been the
request for security improvements by customers. In these cases, the security status of an
establishment typically is characterized by third party auditors using checklists adopted from
FSIS or Food and Drug Administration (FDA) guidelines. The audit findings determine the
nature of the security enhancements required by the customer.

Model Food Security Plan for Meat and Poultry Processing Facilities

Another driver is the incorporation of food security requirements in government sponsored

programs. For example, the United States Department of Agricultures, (USDA)
Agricultural Marketing Service (AMS) purchases food products for Federal nutrition
assistance programs through the Commodity Procurement Program. AMS intends to include
food security requirements in its contract specifications in the coming procurement cycle.
Against this background of Federal agency guidance and market-driven requirements, FSIS
intends for these model plans to serve as the framework for a reasoned and costeffective
approach to improving the security status of the food sector. Although these model plans may
be useful to all types of food industry establishments, the focus is on small and very small
plants that may not have an internal security department or that lack experience dealing with
food security issues.
This document presents a model food security plan that can be used as a starting point for the
development of a meat or poultry processing facility-specific plan. This generic model is not
intended to be used as is for the facility-specific food security plan. Further, all of the
guidance contained in this document may not be appropriate or practical for every meat or
poultry processing facility. FSIS recommends that facility owners review the guidance and
assess which preventive measures are suitable for their operation. Example preventive
measures are presented for the each of the security goals discussed in this document. These
measures should not be considered an inclusive list of all potential approaches to achieving
food security. Each establishment should determine the most cost-effective means to achieve
food security goals based on the current security status of the establishment.
A companion document provides a model food security plan for meat and poultry
slaughter facilities. For establishments that conduct both slaughter and processing
operations, the two models can be merged into a single plant-specific plan.

3.0 What is Food Security?

Food security involves preventing, minimizing, or responding to the deliberate contamination
of food products by a variety of potential threat agents (biological, chemical, radiological).
These are criminal actions that involve willful intent to do harm; they cannot be anticipated
without intelligence information. The motivation for these illegal actions includes the ability
to cause illness and deaths following consumption of adulterated products and the desire to
cause economic and psychological damage, including inspiring fear among the public and loss
of confidence in the safety of the food supply.
Food security is not the same as food safety. Food safety addresses the accidental
contamination of food products during processing or storage by biological, chemical or
physical hazards. The main types of food safety hazards are microbes, chemicals and
foreign objects. This unintentional contamination of food products can be reasonably

Model Food Security Plan for Meat and Poultry Processing Facilities

anticipated based on the type of processing. This principle is the foundation of the
Hazard Analysis Critical Control Point (HACCP) process used to ensure food safety.
Note that because of the differences between food safety and food security, a facility HACCP
Plan should not be used as a substitute for a Food Security Plan. However, like a HACCP
Plan, a Food Security Plan should emphasize preventive over reactive measures.

4.0 Who Might Adulterate a Food Product?

When evaluating the potential vulnerability of a processing establishment, the facility
operator should consider a variety of potential perpetrators who may execute an attack from
both inside and outside the facility. These include both opportunistic attacks by single
individuals and planned attacks by lone or organized aggressors. Table 1 lists some
examples of the types of individuals that might be motivated to adulterate food products.
Facility operators should contact their local law enforcement community for additional
information about potential local threats to their facility.
y
Table 1. Example T pes of Internal and External Attackers

Internal

External

Disgruntled employee
Cleaning crew
Contractors
Temporary employees
Members of terrorist groups posing as
Visitors
Individuals motivated to attack a facility that do not have authorized access are
considered to be intruders or external attackers. Another threat comes from internal
attackers, such as disgruntled employees and other insiders, who typically know what
procedures are followed in the plant and often know how to bypass many security
controls that would detect or delay an outside intruder.

5.0 Food Security Principles

The following guiding principles will assist facility operators in developing effective
Food Security Plans for their establishments:
Principle 1. Clearly Understand What Needs to Be Protected
An understanding of the threats and what is to be protected can help assure that measures can
be applied where they will be most effective. It is important to identify the most vulnerable
components of an operation. A vulnerability assessment, or food security assessment (see
Section 6, Step 1), can be used to accomplish this task, but it is also possible to apply
common sense to identify some of the most likely threats that a facility may encounter.

Model Food Security Plan for Meat and Poultry Processing Facilities

Principle 2. Apply the Highest Security to the Most Critical Components

Security measures, costs, practices and procedures should be appropriate and proportionate to
the criticality of the systems and to the severity, probability and extent of potential harm. Not
all components of a facility need the same level of security controls. Recognizing the unique
components of each facility allows implementation of lower assurance solutions (with lower
costs) to protect less critical components and the use of higher assurance solutions only for the
most critical components. This approach is known as Paretos Principle, or The 80/20 Rule.
Identify and focus on the few (20 percent) actions that will produce the most (80 percent)
benefit or results.
Principle 3. Employ a Layered Approach
Securing a facility against a broad spectrum of threats requires the use of multiple
overlapping approaches that address elements of physical security, personnel security and
operational security. Consider establishing concentric rings of protection, with facility access
control as the outermost ring; a trained and screened staff as the next ring; and processes and
procedures designed to minimize operational risks as the innermost ring (see Figure 1).
Principle 4. Reduce Risk to an Acceptable Level
Elimination of all food security risk is not possible, nor is it cost effective. Cost-benefit
factors should be considered for each proposed countermeasure. At some point, the
incremental increase in security gained will not justify the associated costs. There is a need
to maintain balance between countermeasures and operational effectiveness.
Principle 5. Security Must Have Strong Management Support
Food security begins with an organizations basic commitment to the process. Strong
management support is critical for the success of a security program. This support
establishes a focus on security within the highest levels of the organization. Without such
support, the effectiveness of a security program can fail when pressured by production
schedules and budget limitations. Roles and responsibilities must be clearly defined and
authorized at a level commensurate with the criticality of the system components.
Management should clearly demonstrate that food security is of equal importance to food
safety and quality control.

Model Food Security Plan for Meat and Poultry Processing Facilities

Figure 1. Target-Barrier Concept Displaying Multiple Layers of Security.

Critical processing steps should employ the most layers of security.
(Adapted from Department of Energy 1996)

6.0 Steps in Developing a Food Security Plan

In developing their establishment-specific plans, FSIS recommends that meat and poultry
processing facility operators use a three step process: (1) conduct a food security assessment
for the establishment; (2) develop a plan, based on risk management principles, of preventive
measures to minimize the potential vulnerabilities identified in Step 1; and (3) implement and
test the plan.
These steps are discussed in greater detail in the following sections.
Step 1 Conduct a Food Security Assessment
Each facility should designate an individual or team responsible for the security of the
establishment. The team may use a number of different types of tools to aid in conducting
a food security assessment. These tools include various models and
checklists, such as the FSIS Industry Self-Assessment for Checklist for Food Security
(available at http://www.fsis.usda.gov/PDF/Self_Assessment_Checklist_Food _Security.pdf)
or a more formal vulnerability assessment process, as presented in Appendix A. The goal is
to develop an understanding of the potential vulnerabilities at each facility, based on the types
of processes so that effective countermeasures can be developed. No matter what type of tool
is used in the assessment, the team should consider both internal and external threats (see
Section 4). The results of the assessment should be kept confidential so that they do not
provide a roadmap for future attacks.

Model Food Security Plan for Meat and Poultry Processing Facilities

Step 2 Develop a Food Security Plan

The focus of a Food Security Plan is on the identification of cost-effective preventive actions
that can be taken to minimize the facility-specific vulnerabilities identified in the security
assessment. The plan should address a number of food security goals. At a minimum, the
plan should address the following:
Goal Number 1 Ensure General Inside Security
This goal addresses access for visitors (i.e., non-plant employees) to designated areas
inside the plant, including in-plant laboratories and other potentially vulnerable areas. It
also addresses protection of vital plant systems, such as central control for airflow, water
systems, and electricity. Finally, it includes screening and supervision of contract workers
with authorized access to the facility. This group includes maintenance and sanitation
crews, who often receive limited supervision from plant management.
Some example vulnerabilities and options for mitigation are listed in the
following table.
General Inside Security
Sample Vulnerabilities
Unescorted visitors with access to
critical processing areas

Potential Security Measures

Limit visitor access through the use of
checkpoints and badging.

Water and airflow security

Secure access points for water and airflow

systems.

Personnel security - contractors

Require contractors to screen and train

their employees.
Provide plant supervision or oversight of
contract staff working in the facility.

In-house analytical laboratory

access unsecured

Utilize interior access controls to restrict

all but authorized and trained personnel.

Model Food Security Plan for Meat and Poultry Processing Facilities

Goal Number 2 Ensure Processing Security

This goal addresses monitoring of the equipment used in the processing facility and the
flow of all raw materials, finished products, returned goods, and other items that are used
in production. It also includes personnel security for employees.
Some example vulnerabilities, and options for mitigation, are shown in the
following table.
Processing Security
Sample Vulnerabilities

Potential Security Measures

Threat agents placed in combo

bins containing trim, variety
meats, or parts

Limit access to combo bins. Store combo

bins in locked areas and limit access based
on job function. Increase employee food
security awareness.

Threat agents introduced at critical

process points

Restrict access at critical operations to

employees that receive additional training
and/or background investigations (see
Figure 2). Increase employee food
security awareness.

Threat agents placed in water

supply or ingredients used to
prepare injection solutions

Check integrity of water supply system in

the plant; ensure security of access points.
Restrict access to materials used in
solution preparation. Screen and train
employees working in these operations.

Temporary employees with access

to critical operations

Train permanent employees to raise their

food security awareness. Require use of
personnel identification badges. Use
colored uniforms, jackets, etc.

Model Food Security Plan for Meat and Poultry Processing Facilities
6

increasing
Level of
Protection

Fa ility Access

b
,

Figure 2. Example of varying employee access levels by sensitivity of the operation.

Areas containing the most vulnerable operations should be restricted to a limited number
of employees, and these employees should receive background investigations and
additional training.
Goal Number 3 Ensure Storage Security
This goal addresses measures to control access to ingredient and product storage areas and
the maintenance of appropriate records. Ensuring storage security will protect against the
intentional misuse of ingredients or non-food items used in the plant as food adulterants.
Storage areas should be adequately secured and monitored, with access limited to
authorized personnel only.
Some example vulnerabilities, and options for mitigation, are shown in the following
table.
Storage Security
Sample Vulnerabilities
Threat agents placed in non-meat
ingredients (spices, additives) and
non-food items (disinfectants,
cleaners)
Threat agents placed in combo bins
containing trim, variety meats, or
parts destined for further processing

Model Food Security Plan for Meat and

Poultry Processing Facilities 6

Potential Security Measures

Keep storage areas locked and limit
access based on job function. Require
use of personnel identification badges
and utilize card key system to monitor
access to storage areas. Require use of
logs for inventory material control.
Make periodic checks of inventories and
examine integrity of packaging.

In addition to ensuring general inside security, processing security, and storage security, a
Food Security Plan for meat and poultry processing facilities may also address ensuring
general outside security and shipping and receiving security. Establishment operators
should assess whether these goals are relevant to their operation and then design
approaches to efficiently and effectively accomplish them.
Goal Number 4 Ensure General Outside Security
This goal addresses access to the establishment by unauthorized intruders. Potential
security measures include perimeter control through the use of fencing, gates, guard
stations, and key card access. All entry ways, windows, vents, and delivery docks
should be secured. Exterior lighting and closed circuit camera systems may also be
used.
General Outside Security
Sample Vulnerabilities
Open perimeter, allowing access
to facility

Potential Security Measures

Secure all entry ways, windows, vents,
loading bays, and other access points.

Exterior access to storage tanks,

silos, onsite trailers used for cold
and dry storage

Fence exterior access points to storage

structures. Secure all access points,
including loading and sampling ports.
Install exterior lighting. Use tamper
evident locks or seals on trailers.

Goal Number 5 Ensure Shipping and Receiving Security

This goal addresses the need to ensure the integrity of the raw materials received and
the finished products shipped from the facility. Potential security measures include
purchasing raw materials only from recognized vendors, establishing controls on
incoming deliveries, limiting driver access to the facility during deliveries, careful
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 shipments.

Shipping and Receiving Security

Sample Vulnerabilities
Unscheduled raw material deliveries

Potential Security Measures

Purchase materials only from
recognized vendors. Accept receipt of
only scheduled deliveries. Inventory
packages against manifest and order
forms and examine package integrity.
Require vendors to ship materials in
tamper-evident packaging.

Products shipped in unsecured

trucks, or multiple deliveries per
shipment (less-than-truckload)

All truck shipments should be secured

by use of tamper-evident seals. Drivers
should be trained and certified.

A useful source for additional information on preventive measures is the set of recommended
minimum security standards for Federal facilities developed by the United States Marshals
Service of the U.S. Department of Justice (DOJ 1995). This report recognizes that the
security needs of Federal facilities are influenced by a range of factors, including number of
employees, use, the need for public access, agency mission, crime statistics and threat
intelligence. Standards have been recommended for facility perimeter security, entry security,
interior security, and security planning.
Step 3 Implement the Plan
Once the Food Security Plan is developed, it should be tested and implemented. Key
elements of implementation include assigning responsibilities, training staff, conducting
drills, developing contact lists, and creating a recall plan.

Assign Responsibilities
Individual security responsibilities should be defined and documented. Assign
overall responsibility for food security to a single employee who has an
understanding of the security requirements for the facility.

Train Facility Staff on Elements of the Plan Train facility staff in all
provisions of the plan. The purpose of security awareness training is to ensure that employees
know their food security responsibilities. Training should address badging and access control
procedures, access to restricted areas, protection of critical components, and procedures for
reporting suspicious activities. Understanding the threat of intentional adulteration and the
potential consequences should help employees consistently execute preventive measures,
increasing the overall effectiveness of the plan.

 Conduct Drills and Revise Plan

Conduct drills regularly to test and verify the effectiveness of the plan and
document lessons learned. Continually review policies and procedures in the
plan for process improvements. Revise the plan as needed to address changing
conditions.

Develop Contact Lists

Current local, State and Federal government Homeland Security contacts and
public health officials should be listed in the plan. Local law enforcement and
FBI offices should also be included in the contact list. This list should be
updated regularly. Procedures for notifying appropriate law enforcement and
public health officials when a food security threat is received, or when evidence
of actual product tampering is observed, should be detailed in the plan.

Develop a Recall Plan

A Food Security Plan should include details on how to conduct a recall of
adulterated products from trade and consumer channels. Safe handling and
disposal of products contaminated with threat agents should also be included in
the plan.

A sample food security plan for a meat processing facility is presented in Appendix B.
References Cited
Department of Energy. 1996. Hazard and Barrier Analysis Guidance Document. U.S.
Department of Energy, EH-33, Office of Operating Experience Analysis and Feedback.
Rev. 0. November 1996.
Department of Justice. 1995. Vulnerability Assessment of Federal Facilities. United
States Marshals Service, U.S. Department of Justice. June 28, 1995.

THIS PAGE INTENTIONALLY LEFT BLANK

Appendix A - Food Security Assessments

A food security vulnerability assessment is a tool that can be used by meat, poultry, or egg
processing, storage, or distribution facilities to evaluate the potential vulnerabilities of their
operations to tampering or other malicious acts. Based on the results of the assessment,
corrective actions can be taken to reduce the risk of product adulteration. The assessment
serves as a guide by identifying the need for security upgrades, modifications of operational
procedures, and/or policy changes to mitigate the unique vulnerabilities at a specific
establishment.
The elements of a food security assessment include:

Characterize facility operations

Identify and prioritize potential adverse consequences
Determine critical production components that might be subject to criminal actions
Evaluate existing preventive measures and the need for additional countermeasures

Develop a prioritized plan for corrective actions to reduce or mitigate potential

vulnerabilities
y

Table A-1. Elements of a Food Securit Assessment

Basic Element Points to Consider
Characterize facility operations
Develop a
simple diagram that shows the steps
the company uses when it processes the product,
or use the flowchart developed for the HACCP
Plan. Consider access to the facility and the
product at each step. Figure A-1 is an example of
a generic process flow diagram for meat and
poultry processing. Operations to consider
include:
Receipt of raw materials
Storage of raw materials and finished
products
Processing
Shipping of finished products

adverse consequences

Identify and prioritize potential

consider in assessing potential

Factors to

consequences may include:

Number of product servings
contaminated
Economic impact (loss of revenue)
Damage to brand name
Disruption in product supply chain

13

Table A-1. Elements of a Food Security Assessment (continued)

Basic Element
Determine critical components that
might be subject to criminal actions

Points to Consider
Where in the production process are criminal
actions most likely to occur?
Receipt of raw materials
Cold and dry storage of raw materials
Water supply
Processing - grinding, emulsification,
solution injection
Cleaning materials
Transportation

Evaluate existing preventive

measures and the need for additional
security enhancements
(Depending on current control
measures, some critical components
may already be sufficiently protected.
This step will help to identify areas of
greatest concern.)

Develop prioritized plan for risk

reduction

What means does the facility currently employ to

deter criminal actions? Identify existing policies
and procedures for:
Perimeter security
Access control
Operating procedures at critical
components
Cleaning crews
Vendor deliveries
Storage security
Water security
Personnel security, including contractor
staf

Strategies for reducing potential vulnerabilities

generally fall into three broad categories:
Physical access controls e.g., locks,
tamper-evident seals, guards, cameras
Personnel controls e.g., awareness
training, background checks, employee
identification badging
Operational controls - e.g., shipping and
receiving procedures, recall plans

Figure A-1. Generic Process Flow Diagram

for Meat and Poultry Processing

V
Packaging
1 Labeling
0

*Examples include:
- Deboning
- Skinning
- Trimming
- Grinding
- Solution injection
- Emulsifying
- Mixing
- Blending

Meat Ingredients

Non-meat Ingredients

Transport
from Supplier

Assemble/
Weigh
Transport
from Supplier

Receiving

Dry Storage

Receiving

Assemble/
Weigh

Cold Storage
Mechanical
Processes*
Fermentation
Cooking
Smoking
Drying

Canning
Cooling
Cold Storage

Packaging/Shipping

Appendix B - Sample Food Security Plan

Incoming
raw materials

Processing

Product packaging,
storage and
shipment

This Appendix presents an example of a food security plan for a very small specialty meat
processing facility. Section I describes the company operations and how the plan was
developed. Section II shows a sample of the plan.

Section I:
Description of Facility
The company is a very small specialty sausage manufacturer located in an urban area. The
business is family-owned. All 5 employees of the company are family members.
Description of Plan Development
Step 1 Conduct a Security Assessment
The owner sketches out a simplified flowchart of the operation; e.g.,

Apply the FSIS Industry Self-Assessment Checklist for Food Security to identify potential
security problems.
Step 2 Develop the Plan
Based on a review of the operation and the results of the FSIS Industry Self-Assessment
Checklist for Food Security, the owner identifies the following potential problems or
vulnerabilities:

Inside Security visitor access during normal business hours not controlled
Processing Security no potential problems
Storage Security access to dry ingredient and cold storage areas not controlled
Outside Security
- no potential problems
Shipping and Receiving Security new supplier for dry ingredients; truck driver
access not controlled

Step 3 Implement the Plan

Develop contact lists. Review plan with employees. Periodically review security status and
update plan.

Section II:
Sample Food Security Plan for ABC Specialty Sausage Company
Inside Security
Potential Problems: Lax visitor access control during normal business hours
Solutions: Lock entry way from main entrance reception area to plant floor. Install

buzzer to alert staff of visitor presence when reception desk is empty.

Processing Security
Potential
Solutions:

Problems:

None

None

required

Storage Security
Potential Problems: Access to dry ingredient and cold storage areas not controlled
Solutions: Install locks on storage room and refrigerator/freezer doors.

Outside Security
Potential Problems: None. To limit theft in urban location, locks and alarms already

installed on all entry ways, windows, and shipping dock door.

Solutions: None required

Shipping and Receiving Security

Potential Problems:

1. Long-time supplier of dry ingredients went out of business. New supplier needed.
2. Truck drivers have access to plant during unloading of raw materials (incoming
shipments) and loading of finished products (outgoing shipments)

Solutions:
1. Investigate background of new supplier. Request references and copy of the suppliers
security and quality control plans. Request delivery of raw materials in tamperevident packaging. If needed, identify alternative suppliers.
2. Supervise all incoming and outgoing shipments. Restrict truck driver access to
shipping dock and reception areas of plant only.
Contacts List
Local Police Department
City/County Department of Health
State Department of Health
333-1284
USDA FSIS Office of Food Security and Emergency Preparedness (800)
(staffed 24-hours a day)
USDA National Office of the Inspector General 24-hour Hotline (800) 424-9121
Customers

Customer 1
Customer 2
Customer 3
etc.

Suppliers

Supplier 1
Supplier 2
Supplier 3
etc.

Product Recall Procedures

Identify who, what, when, where, and how for recalls

Identify additional relevant points of contact

Date of Last Security Assessment

mm/dd/yr (should be at least annual or as conditions change)
Date of Last Plan Revision
mm/dd/yr (should track security assessment updates or non-routine emergencies)