Food Defense for bulk liquid fructose transfer stations

Can someone advise if a Food Defense plan is required for bulk transfer stations that are transferring liquid fructose from rail car to tanker?  I'm unclear whether this action constitutes as any of the "manufacture/process, pack, or hold" 

I would think yes.  You would have to show some way that this area is locked and only certain employees have access.  The question is, is this an area where someone could potentially affect your product?

Can someone advise if a Food Defense plan is required for bulk transfer stations that are transferring liquid fructose from rail car to tanker?  I'm unclear whether this action constitutes as any of the "manufacture/process, pack, or hold" 

Yes, probably.  The regional FDA inspections office is likely going to be able to give a more definitive answer.

The exemption to the exemption seems to be liquid storage, unless its the exemption to the exemption to the exemption for animal foods.  Clear as mud.  I'm fairly certain the quantity alone, rail cars worth of material, puts you in the category of "This rule is designed to primarily cover large companies whose products reach many people"