Revised: August 2021
Table of Contents
1. Program administration
a. Plan management
b. Roles and responsibilities
c. Reporting procedures
2. Access control
3. Background screening
4. Shipping and receiving
5. US Requirements
Suppliers acting on behalf of Logistics Warehouse who manufacture, process, pack, or in any way handle ingredients or final products need to develop specific procedures to secure Logistics Warehouse products, to deter and prevent intentional contamination and will have protocols in place to quickly and accurately identify, respond to, and contain threats or acts of intentional contamination.
Likewise, suppliers will ensure their suppliers adopt similar protocols and implement appropriate controls. At Logistics Warehouse, we call these efforts “Food Defense” and we depend on our suppliers to do their part in helping us secure our combined portion of the world’s food chain.
The laws and government expectations regarding Food Defense vary from country to country. Food manufacturers and handlers that operate in the United States or that ship into the United States have the most stringent requirements in the world. Elsewhere laws are less prescriptive. Logistics Warehouse has defined a minimum set of Food Defense standards to help us meet legal and consumer expectations. The standards may exceed the requirements of a specific country or area.
This document will help suppliers understand Logistics Warehouse expectations and provides guidance on how to achieve our standards.
1. Program Administration
Sites need to create a plan to explain how it will accomplish its Food Defense objectives. At a minimum, the plan will include details such as:
It’s important to consider that effective programs are:
b. Site Security Team or Program Manager
Each site needs to identify the employee(s) primarily responsible for managing the facility’s food defense program (i.e., self-assessment, reporting procedures, access control measures, etc.). This employee’s roles and responsibilities should be clearly defined and documented.
c. Reporting Procedures
Should your site become aware of a potential tampering matter, you need to have detailed specific steps for reporting this to Logistics Warehouse and local officials (as required by law). Our ability to respond quickly to a potential tampering incident can help minimize and contain the damage. As part of the Food Defense program planning, you need to define these steps and understand who needs to be contacted.
Self-Assessments should be conducted periodically, at least annually. The main objectives of the self-assessment are to:
Identify the most vulnerable components of the site’s operations and, determine how to use resources, procedures and protocols most effectively to reduce risks.
During the self-assessment, sites can identify potential areas of exposure, or “gaps” in the site’s security measures. Once the gaps are identified, countermeasures (such as program or process improvements or physical security hardware upgrades) can be used to bridge or fix the gaps.
A sample Self-Assessment can be found in Appendix 1 of this document.
2. Access Control
Effective access control is the foundation of a successful Food Defense program. Some access control measures include:
An access control program should positively identify and document all individuals gaining access to the facility, limit access to those who have a legitimate reason to be there, control pedestrian and vehicle traffic at the site and properly report and respond to incidents challenging this policy. A good program will deter people, intent on harming our products, from gaining access to your site. Areas that require specific access control measures include:
3. Background Screening
Logistics Warehouse background screening policy states that suppliers who can demonstrate their ability to carry out effective screening measures will be preferred over those who cannot. In accordance with local laws, Logistics Warehouse expects our third party partners to carry out a reasonable level of reference checking and preferably including the following:
Reference checks: Comprehensive reference checks should be carried out with previous employers (prior 2 employers). This should include validation of employment dates and compensation details in addition to qualitative information.
Qualifications checks: All listed educational qualifications, including degrees, diplomas or certificates will be independently checked for white-collar employees.
Employment Dates: Where these have not been validated by the reference checks, they need to be separately or independently validated. Gaps in employment should be thoroughly investigated.
Criminal Checks: Criminal records should be independently checked as the final step of the employment selection process. If it is not legally possible to obtain access to criminal records, a Certificate of Good Conduct from the police department or court jurisdiction will be pursued where this is available.
Credit Checks: Credit checks will be conducted for specific roles that, by their nature, provide easy access to the funds of the Company or its employees, i.e., certain Finance/Payroll/HR/Senior management positions.
Driving Records: For those positions involved with driving automobiles, trucks, tractors, forklifts, etc, a driver record check will be conducted.
4. Shipping and Receiving
Suppliers need to take deliberate steps, and implement procedures to monitor and verify the integrity of incoming and outgoing shipments.
Some measures to consider include:
5. US Requirements
As mentioned in the introduction, food manufacturers and handlers that operate in the United States or that ship into the United States have the most stringent requirements in the world. Click on the following links to learn more about the US Food and Drug Administration (FDA) requirements:
Information on the requirement that owners, operators, or agents in charge of domestic or foreign facilities that manufacture, process, pack, or hold food for consumption in the United States must register with FDA.
Information about FDA's authority to order the administrative detention of human or animal food.
Information on the requirements for establishment, maintenance, and availability of records by persons, who manufacture, process, packs, transport, distribute, receive, hold, or import food into the United States.
Information on the requirement that FDA receive prior notice before food is imported or offered for import into the United States.
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