7 replies to this topic

[OrRedFood]

I am looking at options for demonstrating that our production room is monitored at all times for food defense/adulteration prevention.  We have cameras already installed in key areas to view the production area and its entrances and exits. The footage is currently recorded but only used for security by the owner. Does anyone have a program they are willing to share on how to demonstrate that the cameras are monitored when the production room is empty but food is still exposed (i.e. lunch, breaks).  We did rotation of breaks and lunches for our last audit, but since then have found that we lose more production time by staggering that letting everyone go at once.  Thank you in advance!  

[Scampi]

Do you save the footage?  That should be all that you need

 

You may be overthinking this.....

[TimG]

Do you save the footage?  That should be all that you need

 

You may be overthinking this.....

 

I would have agreed with you until I took the AIB intentional adulteration class last month. They were pretty specific that if you are using cameras as your mitigation strat, they need to be actively monitored (they even showed the picture of a camera control room with guards watching monitors akin to a nuclear power plant).

....I'm not sure which food manufacturer can actually afford that level of control, but I guess they're out there.

 

To answer your question OP, if I was going that route I kicked around the idea of setting up a review sheet. On the review sheet I'd have the high risk cameras, and a check off for a supervisor or someone in authority to check those cameras specifically. I figured they (person assigned to the check) would run through the high risk camera at 16 speed once per day, specifically looking for evidence of tampering in areas people weren't supposed to be in. It's still going to be a time sink, and thankfully I don't have any actionable steps that require it.

I've never seen a program that would document all this though, and if you're going to use it as a mitigation strat, you will want to document/verify.

[Charles.C]

I would have agreed with you until I took the AIB intentional adulteration class last month. They were pretty specific that if you are using cameras as your mitigation strat, they need to be actively monitored (they even showed the picture of a camera control room with guards watching monitors akin to a nuclear power plant).

....I'm not sure which food manufacturer can actually afford that level of control, but I guess they're out there.

 

To answer your question OP, if I was going that route I kicked around the idea of setting up a review sheet. On the review sheet I'd have the high risk cameras, and a check off for a supervisor or someone in authority to check those cameras specifically. I figured they (person assigned to the check) would run through the high risk camera at 16 speed once per day, specifically looking for evidence of tampering in areas people weren't supposed to be in. It's still going to be a time sink, and thankfully I don't have any actionable steps that require it.

I've never seen a program that would document all this though, and if you're going to use it as a mitigation strat, you will want to document/verify.

 

Hi Tim,

 

I would have been tempted to ask AIB to validate this claim. It's obviously "ideal" but ........

[OrRedFood]

Thank you to both of you for your reply!  I had to laugh/cry at "nuclear power plant" .  I've been thru some Food adulteration training, at my last employer we walked away with a plan to monitor the vulnerability (ID'd as a large hopper of product in a room that was frequently unmanned) which was a numbered seal (like a truck seal) on it during production. 3 - 4 times a day the hopper would be opened to check product level and then a new seal would be put on it.  We had a seal # log with initials and time to track. 

 

The cameras we have now are well placed to monitor kettles and entrances from inside and out, I just need to add the review documentation.  I believe they are erased and taped over periodically so there's that to cover.  It sounds like a daily monitor and a back up person will have to be assigned.  I hope I'm reading your reply correctly. 

 

If anyone else who reads this has a similar situation I'd love to hear you solution(s)!

[TimG]

Oh, and in case you didn't know. FDA has a food defense mitigation strategy database, they've even given it an acronym (FDMSD). We need more acronyms in our field like we need a new hole in the head...

 

https://www.fda.gov/...tegies-database

 

Scroll down to the tab to open the database. The one good thing about using their own mitigation strategies is that it's going to be hard for ANYONE to challenge a mitigation strat that the FDA themselves have suggested. Make sure if you use any, you make a note in your FDP that you got it right from the FDA-FDMSD.

 

Man I hate acronyms so much....

[johnmcip]

Man I hate acronyms so much....

 

I don't know, FDA-FDMSD kinda rolls off the tongue.

[Charles.C]

I don't know, FDA-FDMSD kinda rolls off the tongue.

 

Maybe but to the FDA- uninitiated it's likely unintelligible.