Wednesday, April 17, 2013

Food Defence and Business Continuity

I have blogged about SQF once before and I wish to expand on the topics that are incorporated into this and the other Global Food Safety Initiative (GFSI) programs.  In GFSI programs, food defence and business continuity are issues that must be addressed; taking into consideration intentional threats and unintentional threats to product safety and will culminate in your company's recall procedure.  For SQF, the area to look at is in Module 2, Section 2.1.6.1 and 2.7.1; in BRC, 3.11.1.  Personally, I prefer the BRC code since it is all in one section.

Who would cause an intentional threat?  The people that we can clearly think of are criminals, terrorists, subversives and extortionists. The not so "usual suspects" can include competitors, disgruntled employees, and people not in their right mind.  This is the reason behind the FDA Bio Terrorism Act http://www.fda.gov/regulatoryinformation/legislation/ucm148797.htm

Since the source of a threat is unpredictable, the companies preparations to deal with a possible situation is what becomes important.  Do you keep the doors closed, do you have fencing, do you do security checks, or are areas in the facility (especially where product is exposed) monitored / observable.  Regular inventory counts can also be important to stopping intentional threats -- by noticing inventory disappearing or extra inventory appearing.  One of the best methods of protection/prevention is to answer the question:  will your employees report an unusual occurrence?

What about unintentional threats?  The most common unintentional threats (whether man-made or natural) are fire, flood, drought, hurricanes, tsunamis, mechanical failures, explosions, airplane crash, building collapse, and mislabelled product.  However unlikely the occurrence, if a company deems the threat to be probable, then the company needs to develop a plan of action for dealing with the occurrence.  It is odd to think of a plane crash as a threat to your business, but with so many industrial sites near airports, this does need to be considered.

For a plan of action, the following will need to be considered: 
  1. A crisis management team needs to be selected and trained.
  2. Controls need to be established to find and quarantine any compromised product.
  3. Development and maintenance of a current emergency contact list.
  4. The action plan must be written and not only to deal with the recovery of unsafe product, but also must address what needs to be repaired and develop estimates on how long before there is a return to normal business. 
  5. A plan for communication (both internal and external- PR) will need to be developed - company spokesperson? You may need to include human resources management and lawyers in this plan.

Regardless of the crisis - companies need to be prepared. 

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