4 replies to this topic

[gomez89]

Hi, Everyone. Our facility has a question about our gate. This gate is our in and out to the facility, and my boss wanted me to fid out if anybody knew what are the requirements for our gate facility. Our consulting was suggestion we needed to put a enercome and automatic gate opening system? If not he said we need a security. Is all this needed?

 

Our process:

We open our gates with a lock and push them open. we do not have a security nor anything else around our facility. When drivers arrive they come in to our facility and park on the side then buzz in to come inside our facility (office). In our main door we installed a device where the office has access to see who is coming inside the office and a speaker to be able to talk to the driver. It also comes with access to opening our door with a push from the office, yet we have not installed it. what we do is open the door for them one we confirm they are in the right place.

[Fred73]

It is better to have a guard at the gate, it will reinforce your food defense program, but I will recommend you conduct or have conducted a proper assessment as mentioned in SQF 2.7 (food defense and food fraud). If you determine that a gate is not need it then you have something to shows that you evaluated the potential risk and explain why you have determined that it is or is not necessary.

 

It will depend of several factors I think,

 

-what type of facility are we talking about? (manufacturing, storage and distribution, packaging)

 

-how is the structure of the building?

 

-do you have security cameras around the building? 

 

-it is the property fenced?

[gomez89]

Thank you @fred73 for your fast response.

 

 

what type of facility are we talking about? (manufacturing, storage and distribution, packaging) 

We are a storage and distribution facility (freezer)

 

-how is the structure of the building?

Closed all the way 

 

-do you have security cameras around the building? 

Yes we do 

 

-it is the property fenced?

Yes all the way around

 

Plus we have a device in front of the main door to our office that nobody can come on, without first pressing the device and confirming who is coming in. 

can you tell me what's your opinion? Do you think we really need one? My boss wants to atleast put an intercom where we can talk to the driver outside of the gate and if he is in the right place, then an employee goes and opens the gate for him. 

[TimG]

Fred was on point with doing the food defense assessment (required by FDA and also required to be reviewed annually). There's even a new food defense plan builder put out by the FDA just a few weeks ago at https://www.fda.gov/...se-plan-builder

It's really only useful if you are building a food defense plan from scratch to meet the FDA requirements. But if you are earlier in the process it might help you document what Fred was mentioning.

Things to remember:

1) If your security consists of locked doors, a second party (you've hired to audit you to a standard) auditor will almost always try to get in one of those doors that should be locked when coming in in the morning

2) A second party auditor will usually make a cursory attempt to get to any areas they feel are "sensitive" before starting or after leaving for the day

 

My OPINION, heck no.

If you keep your doors to the facility controlled (LOCKED) and you are gated with one access point, and that access point is monitored by a security camera, and people can't gain entrance to your facility and easily get to "sensitive areas", I would think any auditor would be hard pressed to say you needed to HIRE security or install high priced security measures at that gate. You can even back this up with physically checking your locked doors and other key points of the system when you do your GMP or facility inspections, which would add a data point to help validate that your current security measures are adequate.

[Fred73]

Remember that if this is a storage and distribution facility "only", then for FDA, CFR 21 Part 121, 121.5 (b) storage and distributions are exempts, but that is only for FDA then you are not under USDA or any GFSI standard. So at the end YES you have to have a Food Defense program and you have to complete an assessment only as required for Food Fraud SQF 2.7.2.

 

In my opinion your boss idea is good, it will support your food defense program and it may not be so expensive like hiring a security company or having a guard in the gate every day.