In foodservice facilities, especially high-volume ones, people come and go all day. What are you doing to control access?
A subject that few in the industry like to talk about is how very vulnerable foodservice establishments are to food tampering. Some feel that given the amount of people who enter, exit or otherwise tread upon the property of a large institution such as a hospital or college campus, it’s a wonder that relatively few incidents actually occur.
Still, the question must be asked: how does a foodservice operator protect against malicious tampering? “You really don’t,” says security consultant and trainer Chris McGoey, CPP, CSP, CAM, president of McGoey Security Consulting, which has offices in Los Angeles and San Francisco. “Like everything else in the world, a certain amount of trust goes along with the job. When you say tampering you’re talking about intentional conduct designed to cause harm.”
When it comes to preventing such occurrences, McGoey concedes, “there is nothing you can do. The industry is not set up to be searching people or surveilling them with video cameras” Instead, it must rely on basics such as thorough background checks, training and co-worker vigilance.
“I think his point is well taken,” says Linda Gilardi, senior director of quality assurance for the Compass Group, referring to McGoey. “Though, we still have an obligation to keep it top of mind because you just never know. Also, FDA guidance does suggest that foodservice markets have an obligation to have certain (safeguards) in place.”
In assessing potential danger, McGoey poses the question: “How dangerous is it now? We’re not doing (these additional security steps) now, so evaluate how dangerous it is now. How often in your business do you come across cases of intentional food tampering?”
However, while it may not be a common occurrence, some preventative measures may prove worth the effort.
Lock up: One of the first logical steps to take is to batten down the hatches—install locks on doors to dining rooms, kitchens, storage areas and loading docks. Some facilities might be able to post guards in certain locations, and keeping strict watch over hours of operation is advisable as well.
In fact, installing locks is the top method of securing foodservice facilities, according to FSD’s Food Safety and Security Study (see Sept. 15, 2005, FSD, p. 28), followed by limiting access to facilities, staff background checks and certifying suppliers.
Unfortunately, however, any barrier that is put in place is going to start to build in inefficiency. “If you start regulating every single aspect, the world will come to a screeching halt,” reasons McGoey. “You’re just simply not going to be able to serve food anymore. You’ll just have to eat in your home.”
Operators, he adds, are “not going to be searching people, or running them through any sort of detectors or screening devices, or frisking them before they come to work. It’s just not going to happen.”
Non-commercial foodservice may have an advantage over some commercial operations because they’re located on large properties or in large facilities. “Lucky for us, many of our facilities are already secured because we operate on secure client property,” explains Gilardi.
“Although we could argue about the potential, we’re already securing against ill willed folks and tampering. A lot of our loading docks are secured because our clients have security staff on duty, since it does represent access to the building.”
Some would argue that the real threat to food security lies elsewhere in the supply chain, Gilardi suggests, and that manufacturers, processors and growers can be at greater risk for what she calls a “major event.”
One of Compass Group’s operating standards in the wake of 9/11, Gilardi explains, is that managers must routinely secure their food storage areas, including walk-ins. “In most cases, again, these are located right in the back of the house behind the cafeteria areas. This is more of an issue when we have store rooms that are a little bit more remote.” In such cases, the solution is seeing to it that doors are locked.
Pro-action: Compass doesn’t insist that everyone who enters storage or prep areas log in or out. Instead, management relies on well-honed recruiting and training procedures, as well as observation of associates’ behavior and performance. “If we had any fear of ill will from a particular associate,” Gilardi adds, “we would already have taken action.”
Compass personnel routinely conduct food delivery inspections, usually at the truck. “We meet the driver there to take over custody of the delivery,” Gilardi says. Another Compass operating standard is to restrict a practice that is “pretty common in our industry,” according to Gilardi: drop-off deliveries. Many involve fresh baked goods from local bakeries, or milk (which also, obviously, involves a host of temperature-control issues).
“Drop-off deliveries that historically have occurred before management or any staff actually arrives—where it is dropped off outside the locked door, or the driver has a key, or access to a key, to bring the order in—are no longer permitted,” says Gilardi. “It is common sense, and it is just good, plain business practice.”
How to Tighten Your Ship
The Food and Drug Administration offers foodservice operators a long list of recommendations for securing their facilities against tampering. They include:
- Securing doors (including freight loading doors, when not in use and not being monitored, and emergency exits), windows, roof openings/hatches, vent openings, ventilation systems, utility rooms, ice manufacturing and storage rooms, loft areas and trailer bodies, and bulk storage tanks for liquids, solids and compressed gases to the extent possible (for example, using locks, ‘jimmy plates,’ seals, alarms, intrusion detection sensors, guards and monitored video surveillance).
- Using metal or metal-clad exterior doors to the extent possible when the facility is not in operation, except where visibility from public thoroughfares is an intended deterrent.
- Minimizing the number of entrances to non-public areas (consult federal, state or local fire or occupational safety codes before making changes).
- Accounting for all keys to establishment (for example, assigning responsibility for issuing, tracking and retrieving keys).
- Implementing a system of controlling vehicles authorized to park in the non-public parking areas (for example, using placards, decals, key cards, keyed or cipher locks, issuing passes for specific areas and times to visitors’ vehicles).
- Storing poisonous and toxic chemicals as far away from food handling and food storage areas as practical.
- Limiting access to, and securing storage areas for, poisonous or toxic chemicals that are not being held for retail sale (for example, using keyed or cipher locks, key cards, seals, alarms, intrusion detection sensors, guards and monitored video surveillance).
- Inspecting incoming and outgoing packages and briefcases in the non-public areas of the establishment for suspicious, inappropriate or unusual items.
For more info on security issues, visit www.cfsan.fda.gov/~dms/secguid5.html