Using Advanced Security Technology to Comply with the Food Safety Modernization Act
Food Safety Modernization Act places focus on prevention
Last year, the Food Safety Modernization Act (FSMA), was implemented to prevent food-borne disease caused by both intentional and unintentional sources, and to improve detection and response when an outbreak occurs. Signed by President Barack Obama, and implemented by the Food and Drug Administration (FDA), FSMA strengthened requirements for companies that manufacture, supply, process, pack or hold food products – in an effort to increase food safety throughout the United States. Notably, the legislation grants the FDA mandatory recall authority of food products and the authority to suspend the registration of food facilities to prevent the import and export into the United States of food from a facility that has a reasonable probability of causing harm to humans or animals. In the first year since enactment, the FDA has also exercised its new authority to administratively detain food products that it has reason to believe are adulterated or misbranded, for up to 30 days, if needed.
As LeeAnne Jackson, Health Science Policy Adviser for the FDA stated at ADT’s Second Annual Food Defense Strategy Exchange, “The historic FSMA is aimed at transforming our food safety efforts toward prevention and based on risk analysis”. It would behoove food manufacturers and distributors to also focus on preventive versus reactive strategies to protect their brand and prevent contaminated food from reaching the public.
So what should food companies do to move towards a more preventive food defense posture to protect against intentional food adulteration? The FDA’s approach to preventive controls is depicted in the following graphic.
Companies can approach their food defense strategies in a similar manner by asking some important questions to assess their vulnerabilities to intentional food adulteration, such as:
Do we know where the critical control points are in all of our facilities that could be potential areas of vulnerability for food adulteration?
What access control measures do we currently have in place for authorized personnel vs. non-authorized employees, contractors, suppliers and visitors?
Does our organization have the capability to provide continuous monitoring of goods throughout our extended supply chain to prevent intentional incidents of food adulteration?
Does our company have reliable audit processes in place that can ensure consistent compliance to corporate operational and regulatory standards for the implementation of best food defense practices?
One specific area where a proactive food defense posture can be taken is on how access to critical control points inside of facilities is managed. The critical control areas identified by the FDA include, but are not limited to, processing, shipping and receiving, laboratories, raw materials, chemical storage and hazardous storage facilities. Given the sensitivity of these areas, personnel access and movement through the critical control points, such as areas where large batches of food are being mixed, should be restricted to authorized personnel only.
Advanced Security Technologies that focus on prevention
Traditional security technologies, such as proximity access control systems and CCTV systems, have been widely deployed and are effective in securing entry into a facility and monitoring activities so authorities can react to incidents as they occur. But how can a company utilize advanced security technologies to implement preventive controls that may protect them before potentially hazardous events could occur?
Food companies should focus on solutions that can help secure specific critical areas, even if they are in wide open plant floor layouts, and deliver intelligent, real time awareness in order to build a proactive food defense program. This includes Active RFID technologies in which automated actionable intelligence is implemented using smart, networked devices for enhanced situational awareness across the enterprise. These systems can dramatically help reduce brand reputational risk from intentional and unintentional food adulteration.
Technologies that are utilized in real-time location systems (RTLS) to track people and equipment that are optimized for indoor and campus environments are also best suited for food manufacturing facilities. A Wi-Fi based solution is an RTLS that has the advantage of leveraging the existing Wi-Fi network that is commonly installed in facilities for remote computer access. It uses the Wi-Fi standard access points as reference points to identify the location of the tag based on signal strength. A site survey must be conducted to map out the virtual security zones that need to be monitored, and depending on the location precision that is desired, additional access points may need to be installed. Personnel and equipment tags programmed with specific authorities to enter virtual security zones can then be issued, for example, only employees responsible for the mixing area are issued tags for that area. All other employees, visitors and equipment without that authorization would trigger an alert if passing through that area, thus, securing the area against contamination from people and equipment traffic.
Another effective technology is control point location solutions, which utilize active RFID tags that are awakened when passing through specific zones or control points. Activation zones are defined at installation with flexible wire loop antennas that generate a magnetic field that wakes up the tags, and can be adjusted dynamically to fit the physical environment. As personnel and issued equipment tags pass through the activation field, the activator’s location ID is written to the tag. The tag then transmits its ID number and the location ID, thus providing specific location information at time of activation as well as the direction of their movement, whether entering or exiting.
Integrating networked digital video with both passive and active RFID access control technologies can trigger event-based video recording that is searchable by location, time or date and can be instantly retrieved and viewed from any networked monitor. For example, the arrival and unloading of goods in the shipping and receiving areas can trigger video recording of the condition of the container seals and the trailers, the timeliness of the movement of cold chain products to storage, and association with the IDs of the staff handling the shipments. Queries on the status of a particular item can provide a snapshot, a video clip, or live video feeds to assist in providing video verification of specific events.
Physical Security Information Management (PSIM) solutions can trigger specific security responses automatically in response to specific breaches, whereas today these procedures are typically stored off-line and expected to be followed consistently by personnel in all the facilities. PSIM systems also help to centralize all security data throughout all of a food manufacturer’s facilities, so that managers can easily find and provide an audit trail to FDA inspectors, to demonstrate FSMA compliance.
Strong access control protection and implementation of networked security systems and processes create an efficient system that provides transparency, precise traceability and personnel authorization, which are key elements for FSMA compliance. Ultimately, manufacturers should choose the technology that best fits their unique physical plant layout and the specific critical control points that need to be monitored and secured. By deploying real-time location systems, food manufacturers can be proactive in implementing preventive controls consistent with the FSMA mandates.
Don Hsieh is the director of commercial and industrial marketing with ADT Security Services.