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What Food Defense Audits Cover and What You Can Do
Food defense audits require a risk assessment that includes evaluation of the company’s food defense plan. The risk assessment ensures that a company’s food defense measures are applied appropriately based on the facility’s size, number of employees, location, and the types of products it produces. It includes reviewing the food defense plan and evaluating conditions such as appropriate training and employee responsibilities in controlling access points, reporting suspicious activities, and fulfilling specific job activities related to control measures.
The audit risk assessment makes sure that measures are in place to control who has access to which areas of the facility. This includes which areas employees, drivers, and visitors may access and which areas are restricted. Access control for strangers can include deterrents like bright outdoor lighting and physical barriers like fences, gates, guards, and locks—including keys, keypads, and card swipe machines.
But access control doesn’t just apply to keeping intruders out. It also helps ensure employees have access only to the areas they have authorization to enter. Access control devices range from high-tech palm and retina scans and facial recognition software to more basic measures like ID checks or sign-ins at a guard gate or employee entrance.
It’s also important to ensure that all drivers who come and go from the facility are legitimate, they are delivering only materials from trusted and expected sources, and they are taking out only authorized shipments and delivering them directly to the desired clients. Access control for drivers can be improved by making pick-up and delivery appointments, having check-ins at a vestibule, restricting driver access to the plant, and employing guards or mechanical gates with video feeds to the office before trucks are allowed to enter the premises. Using locked trailers tracked with GPS to monitor product transportation also helps control access to food products.
To protect our food supply, the USDA’s FSIS conducts surveillance to monitor and detect acts of intentional contamination of meat, poultry, and egg products.
To keep track of vendors, job applicants, and other visitors, companies may want to make sure all guests can enter the building only through one controlled point where they must sign in and are always accompanied by an employee. In addition, guests can wear visitor ID badges, or if they are required for safety to wear protective clothing, hairnets, and vests—these should be in distinctive colors, different from what employees wear.
During the food defense risk assessment, the auditor determines the level of access control for employees, both during screening and when hired. The auditor reviews pre-hire employee screening activities, such as whether the company (or an employment agency hired by the company) conducts criminal background checks, verifies references and work history, and confirms work eligibility through the U.S. Citizenship and Immigration Services’ E-Verify.
The audit examines how employees are monitored during day-to-day operations—whether video cameras are installed inside and outside the facility with adequate lighting and whether employee card swipes record entrance data to all areas. A food defense audit also includes a thorough examination of the company’s data management practices. The auditor looks for controls such as limited, layered access to controlled documents (confidential information and process instructions, for example), password protection, and off-site backup of data.
Other items covered in a food defense audit include whether the company has specifications for off-site storage, what steps it takes to qualify or approve suppliers, how it manages non-conforming products, how it controls access to sensitive documents and chemicals, how it conducts product testing and verification procedures, whether it has a recall procedure in place, and its recordkeeping procedures.
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