How to justify potentially sensitive areas of your premises?
hi all, in ISO/TS22002-1 Technical Specification Clause 18.2 Access Control said that Potentially sensitive areas within the establishment shall be identified and mapped.. Anybody knows how to justify Potentially sensitive areas at your premis?
Hi carine,
I haven't checked but i expect this is related to food defence/security
The basic answer to yr query is by risk assessment just like the haccp form. There are examples on the forum (somewhere).
You may have to search for things like 'threat potential", 'food defence/defense", food security.
A hot topic in these unsafe times, now appearing in all the FS standards.
You will probably need to do a risk assessment of your facilities. What area is most vulnerable and what are you doing to limit access? Do you have a list of who can enter? How do you limit access if that person no longer works for you?
For your company's protection, you may want to at least know the areas where your trade secrets could be seen or learned. Trade secrets cannot be protected like patented processes can, and once they are learned by you allowing someone to see them, then they are no longer a trade secret. I don't know if that should be identified for this requirement, but it is something that is important for you to know.
Martha
Is it a must to fill in risk assessment form to justify potential sensitive areas? Any standard form? I do justification based on common sense. I will say production area, chemical store, raw material store, main entrance to factory is potentially sensitive areas, is it ok?
It may depend on what / whom you are doing it for but most auditors expect meaningful, logical, documentation. Hazard analysis based on "experience" used to be a listed option but i doubt that it still exists. :smile:
re-form, see post 2
This is from FDA's Vulnerability Assessments of Food Systems in 2012
"A detailed analysis of CARVER+Shock results from vulnerability assessment meetings conducted under this, and prior efforts, was performed. This analysis was aimed at determining characteristics of nodes, such as commonalities in activities performed, that could be used to identify nodes of potentially higher risk and enable the FDA to provide mitigation guidance and public health regulation focusing on higher risk nodes. This analysis provided information on how best to develop an integrated national framework to reduce the risks at nodes that 11 commonly were identified as of highest concern. This analysis will help the FDA and industry to more appropriately institute guidance and standards to improve food defense.
Nodes which contained steps where ingredients were mixed or added to a mixture frequently were identified high risk. The potential to add an agent to these types of processing steps and have that agent homogeneously mixed within the food product caused high levels of concern. More stringent mitigation steps may need to be employed at these areas to mitigate the risk at these nodes. Likewise, nodes where liquid ingredients were handled or stored were also commonly identified as high risk. The potential for a threat agent to mix within a liquid ingredient is high, even if no active agitation or mixing is conducted. Liquid storage tanks and other types of handling of liquid ingredients (such as loading or receiving) should be a focus for mitigation measures. Nodes where ingredients are open and accessible also were of higher concern. Ingredient staging or rework areas may provide an attacker with easier access to open ingredients and increase the risk of adulteration. Mitigation measure focused on securing or observing of these areas should be considered."
Marshall
Interesting, thks. Is this from the lengthy, detailed FDA document (>30pgs) which I recall previously posted here?
I get confused over the varied use of terminologies in this topic.
BRC uses “threat” in the context of a non-FS “hazard” (eg as leading to Fraud). But I think that here vulnerability (= “threat agent”) where “threat” is interpreted as a direct FS hazard. ??
Charles,
Yes. It was excerpted from that document. Here is another link to a FDA page that is a bit more concise than the 30 page document. I believe I posted this when it came out a couple of years ago.
I believe that in the above excerpt, "threat" does indeed mean a direct FS hazard.
Marshall