Implementation of the Food Safety Modernization Act (FSMA) is in full swing. And now that the food industry is becoming more confident in its ability to meet the food safety requirements of the Preventive Controls Rules, many companies are turning their attention to the next big hurdle: the Food Defense Rule.
The FSMA Final Rule for Mitigation Strategies to Protect Food Against Intentional Adulteration is the first major regulation in the United States aimed at preventing someone from intentionally contaminating the food supply. This includes acts of terrorism with the specific purpose of causing wide-scale harm, as well as acts by disgruntled employees who may just be trying to harm the company but could end up causing a public health problem.
For this rule, the FDA has taken a similar approach as for the Preventive Controls Rule. It requires companies to be proactive in identifying hazards within their facilities, implementing mitigation strategies, and periodically reassessing those strategies to confirm that they’re working. Also like the Preventive Controls Rule, the Food Defense Rule is not prescriptive. It doesn’t tell companies what strategies to use. Rather, it requires companies to assess their own risks and put effective controls in place.
Effective controls can include everything from installing security cameras to restricting access to actionable process steps using biometric controls or a keycard system. Here, we’ll look at three ways a visitor management system can contribute to a comprehensive food defense plan.
Identifying maintenance technicians, vendors, and other non-employee visitors
On any given day, there may be many people in your facility who aren’t employed by your company — technicians servicing your equipment, utility workers, vendors, partners, or even representatives from the company that catered your lunch. If a technician requests access to your processing area, that’s probably reasonable. If a caterer does, you might have a problem on your hands.
Your employees are an important line of defense against intentional adulteration from an outside party. But with new people in and out every day, it can be difficult to figure out who’s supposed to be there and who’s not.
A visitor management system solves this problem by automatically printing out visitor badges with names and photos for everyone who enters your facility. You can further customize the badges with the name of the person the visitor is there to see and an expiration date. This helps your employees instantly identify who’s in the facility and why, so if they see something, they can say something.
Notifying employees when delivery drivers arrive
The shipping and receiving area represents another potential area of vulnerability for food facilities. A recent article in Food Business News noted that this can be particularly true for bakeries, where ingredients and supplies are delivered and products are picked up every day. John Koury, an architect consultant who specializes in the food processing facilities, noted: “If you don’t have someone checking deliveries, you’ll end up having delivery drivers or service techs just walking into the building through the shipping and receiving dock.”
Typically, delivery drivers don’t need to enter the facility. They just need someone to know when they’ve arrived so they can deliver or pick up their items.
A visitor management system provides an easy way for delivery drivers to announce their arrival. All they have to do is hit the delivery button and the system will send a notification — via email, text, or Slack — to the designated person. With The Receptionist for iPad, you can customize your delivery buttons to handle all the different types of deliveries you receive.
Keeping a digital visitor log for recordkeeping
Finally, FSMA requires documentation and recordkeeping so FDA inspectors can verify that you have effective mitigation strategies in place. A visitor log is one example of these records. But the value of a digital visitor log goes beyond merely dotting your i’s and crossing your t’s for compliance.
Imagine that some of your products were intentionally adulterated. How will you find out who was responsible?
If an incident does occur, your visitor log will prove invaluable for finding out what happened. If you had visitors the day that the contaminated lot was produced, you’ll have a starting point for your investigation. If you didn’t have visitors, you might have a disgruntled employee on your hands. In either case, your visitor log will help you track down the source of the problem so you can prevent it from happening again.
Before the first compliance date rolls around in July 2019, most food companies will need to perform a full vulnerability assessment of their facilities and implement mitigation strategies at each actionable process step for each type of food they manufacture, process, pack, or hold. A visitor management system can support this effort by augmenting your physical access control systems and providing a digital paper trail of who’s in your facility at all times.
Ready to give visitor management a try? Start your 14-day free trial of The Receptionist for iPad today.