Be alert and aware. Management should make efforts to inform and involve staff in all aspects of food defense. This means you should talk about food defense awareness with all team members on a regular basis. An informed and alert team is more likely to detect weaknesses in a food defense system and to detect and properly respond to signs of intentional contamination. Employees should be encouraged to report
suspicious activities, possible product tampering, or suspected security
system weaknesses to management.
Encourage communication. Communication among all employees will help to identify and correct food defense issues, raise awareness, and decrease vulnerabilities in your food defense plan. Communication also helps employees understand how important their job responsibilities are to the success of the overall operation. This realization will also help im- prove their food defense behaviors and attitudes.
Decrease vulnerabilities. To decrease vulnerabilities, management should develop a food defense plan. This plan should include a recall
strategy. Staff should be trained on the points of the strategy and the
strategy should be tested regularly, in the form of a practical drill. Since potential threats, the physical facility itself, and the operations within the facility may change over time, the food defense plan should be exam-
ined and tested at least once a year.
Decrease availability of potential contaminants. When training em- ployees, the management team needs to stress the importance of storing all potential contaminants, such as cleaning and pest control chemicals, in secure storage areas that are locked. Contaminants stored on the premises should be limited to only what is needed. You should not keep a large inventory of these products. It is critical that these products are stored away from food properly labeled, and kept in a locked area. Access to storage areas for these potential contaminants should be limited to those who need access, based on their job function. These storage areas should be accessed by employees only, and should be far away from the public areas in your establishment.
Large amounts of cleaning/chemical products add to the inventories that must be controlled and managed. Proper inventory control of these items helps management investigate any missing products. Additionally, any unneeded items should be properly disposed of to prevent unwanted misuse. Keep in mind: Readily available cleaning and pest control chemi- cals are often the contaminant of choice for a disgruntled employee who may want to get back at a manager or coworker by contaminating the food served by the establishment.
Identify possible inside threats. Insider compromise occurs when an employee (an insider) takes deliberate action to contaminate food or as- sists outsiders in deliberately contaminating food. In other words, it’s an “inside job.” The best way to prevent this from happening is to have con-
stant supervision of all people working in your establishment. This in-
cludes all employees—both new and long-term employees, cleaning or maintenance staff, and vendors. Managers should be particularly aware of a person’s unexplained
Hours (coming in early or staying late)
Use of camera phones, cameras, or video recorders at work Probing with inappropriate questions
Admission to areas
Removal of standard operating procedures, documents, and policies from the facility
In addition, managers should:
Conduct employee background checks. All current and future employ- ees, especially those with the most access to all areas of your establish- ment, should be screened to make sure they are not likely to perform something illegal based on their record and past behaviors. When check- ing employment history, follow your company SOPs and always follow the guidance of your human resource department or legal counsel. Keep track of employees. Management should also keep track of who
is and who should be on duty, and where each employee should be working by paying close attention to the prepared schedule (schedules, people charts, deployment charts, etc.).
It’s important to keep in mind that a disgruntled employee who has inten- tionally contaminated product may not return to work and law enforce- ment may need to be notified. On the other hand, if a disgruntled employee plans to contaminate product, he or she may be in areas not normally associated with his or her job function in order to collect infor- mation or to take other actions that will help to intentionally contaminate product.
Restrict personal items at the workplace. Personal items should al- ways be restricted in your establishment because a disgruntled employee who plans to intentionally contaminate product may need to bring the contaminant into the facility, using personal items such as a purse, backpack/knapsack, or lunch bag to disguise it.
Management has the authority to inspect all employee lockers and should do this periodically or if an employee is suspected of foul play. A disgruntled employee may use his or her locker as a temporary storage location for a contaminant that he or she has managed to bring into the facility. Managers should check with their legal counsel or human
resource department for proper procedures and required notifica- tions to employees.