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FSIS' Food Defense Plan Survey: The Results Are In. What Was Your Impact?
By Natasha Williams
The U.S. Department of Agriculture's (USDA) Food Safety and Inspection Service (FSIS) completed its annual survey of slaughter and
processing plants for Fiscal Year 2011 on the presence of food defense plans. This initiative began in 2006 to measure the industry's
voluntary adoption of written food defense plans and to determine whether the plans are functional, meaning "Have they been implemented,
tested, and reviewed?"
FSIS' 6th Food Defense Plan survey was conducted in July 2011, and, similar to past surveys, the facilities involved were plants
that are active FSIS-regulated meat and poultry slaughter and processing plants, active official import inspection plants, or active
processed egg products plants. The numbers are in, and while the percentage of plants with a functional plan has surpassed the
74 percent goal that was set for 2011, the participation rate of very small plants still lags behind the participation rate of
small and large plants.
| July 2011 Food Defense Plan Survey Results
||Percent of Establishments with a Functional Food Defense Plan
|Meat & Poultry Establishments
||Processed Egg Product Plants
||Official Import Establishments
Plants of any size can only gain from having a functional food defense plan on hand. Establishing a plan enhances the
protection of your plant and products from vulnerabilities that can cause a potential threat to the food supply, as well as
According to Dr. Byron Williams, assistant professor in the Department of Food Science, Nutrition, and Health Promotion at
Mississippi State University, having a functional food defense plan is "a matter of security for the continued well-being of
their business. In the event of an incident, a functional food defense plan aids in reducing the harm a very small plant could
experience as a result of negative publicity and lost business. As a very small plant, even the smallest incident could potentially
have a major impact on the business."
In December 2009, 49 percent of very small plants had functional food defense plans compared to 72 percent of small plants and 97
percent of large plants. Fast forward to 2011 where 65 percent of very small plants have a functional plan compared to 84 percent of
small plants and 96 percent of large plants.
While it is commendable that the number of very small plants with functional plans has increased approximately 20 percent in the
past 2 years, an evaluation of the difference between the participation of very small plants and that of small and large plants
shows that there may be a misunderstanding regarding what it takes to have a functional food defense plan.
| 2006 - 2010 Food Defense Plan Survey Results
||Percent of Meat and Poultry Establishments with a Food Defense Plan
You may think that you must spend a lot of money or hire more employees to develop a
functional food defense plan. In fact, functional food defense plans can be created without
additional funds or staff. Having a functional plan means that your plan can be implemented
at a moment's notice and contains tasks that can be performed on a daily basis.
For example, if an employee's duty is to monitor entry and exit doors to ensure they are properly locked, delegate this
task in your functional plan to the person in charge of monitoring security for the plant. By putting this in writing,
you are not spending extra money or hiring new staff. Instead, you now have a "go to" person who is responsible for
maintaining that aspect of the plant. This also prepares you for a faster response time in the event that security is breached.
Another example of a possible misunderstanding of having a functional food defense plan is that it takes too much time to
write one. FSIS has created a general food defense plan titled, "Food Defense Plan: Security Measures for Food Defense."
The general plan is available online at
and is also available in hard copy. This document outlines four of the major security measures that can lead to a plant's
vulnerability. They include, but are not limited to, outside security measures, inside security measures, personnel security measures,
and incident response security measures. You may tailor this general plan to the potential threats and needs of your plant.
The general plan is also available in the following languages: Korean, Mandarin, Spanish, and Vietnamese.
Alternatively, you may decide to develop a functional food defense plan using the guidance materials available on FSIS' Web site at
although this may be the more challenging option.
Results from the survey show that 959 very small plants lack a functional food defense plan. If you're an owner or operator of a
very small plant, please know that your plant is potentially at risk without this document. To continue to protect the public's
health and your own livelihood, it's imperative that you create and maintain a functional plan. Don't let the perception of
spending more time or money deter you from protecting your plant. Make an impact in 2012!
For more information on functional food defense plans or to obtain a hard copy of the general food defense plan, contact the
Small Plant Help Desk at 1-877-FSISHelp (1-877-374-7435) or email InfoSource@fsis.usda.gov.
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The International HACCP Alliance Offers Resources and Assistance
By Jane Johnson, DVM
Need another Hazard Analysis and Critical Control Point (HACCP) resource? If so, you might want to check out the International HACCP Alliance.
The International HACCP Alliance was developed on March 25, 1994, to "provide a uniform program to assure safer meat and
poultry products." Housed within the Department of Animal Science at Texas A&M University in College Station, Texas, the
Alliance includes industry associations, professional organizations, educational foundations, universities, third-party private
companies, and government cooperators.
The Alliance's Web site, www.haccpalliance.org/sub/index.html, is divided into six tabbed sections:
- Hot Topics – provides information regarding topics of current interest;
- Training Activities - provides a list of HACCP courses, a list of accredited course providers, and information regarding Alliance-approved curricula;
- Food Safety Information - provides links to information regarding food safety and HACCP
- Reference document titled "Antimicrobial Interventions for Beef"
- Section titled "HACCP and Food Safety," which provides links to various information including compliance guidance materials, applicable FSIS Notices, HACCP questions and answers, critical control point decision tree, etc.
- Section titled "Reference Corner," featuring links to Title 9 of the Code of Federal Regulations (CFR), various government agency Web sites, the USDA National Agricultural Library, and various association Web sites;
- News – provides links to news items about the Alliance and the food industry;
- Alliance Board Room – provides information about members of the Alliance's Board of Directors and lists the Alliance's members; and
- Scientific Article Database – provides a searchable database of scientific articles on various topics. When you conduct a search,
the database will return the title of an article (or articles) matching your keyword search, the author, the name of the publication
containing the article, the publication's volume/issue number and date, and the article's page number.
For more information, you can contact the Allianc at firstname.lastname@example.org. If you prefer, you may phone the
Alliance at (979) 862-3643 or send a fax them to (979) 862-3075. You may also write to the following address:
International HACCP Alliance
Rosenthal Center, 2471 TAMU
College Station, TX 77843-2471
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Take Advantage of Available Training Modules
By Jane Johnson, DVM
As you know, humane handling is a very important issue for both FSIS and you, the small or very small slaughter plant owner or
operator. Therefore, FSIS has posted its "Humane Handling of Livestock" training module on its Web site at
for use by plant owners or operators. This is one of the modules used by FSIS to train its inspection program personnel.
In addition, FSIS has developed practical, situation-based training for inspection program personnel that prepares them for
realistic scenarios they may face at a slaughter plant. There is a "Situation-Based Humane Handling Training Facilitator Guide" and a
"Situation-Based Humane Handling Training Participant Guide." These can also be found at
These training modules have been made available to plant owners and operators because the information they contain may be helpful
in your understanding of how the Agency enforces the humane handling regulations. In addition, you may find the information and
training method useful in training your own employees on humane handling.
For questions or more information on humane handling, please contact the Small Plant Help Desk at 1-877-FSISHelp (1-877-374-7435) or email
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Commonly Asked Questions & Answers
Q. Are inspection program personnel required to collect animal identification when a tissue sample is collected for pathology testing?
A. Yes. According to 9 CFR 310.2 (a), all animal identification is to be retained with the
animal until the post-mortem examination is completed. When a pathology sample is collected in an official slaughter establishment,
FSIS inspection program personnel must follow the instructions in accordance with FSIS Directive 10230.6, titled "Submitting Tissue
Specimens for Pathological or Diagnostic Microbiological Evaluation to the Laboratory." In addition, they are to collect all identification from animals selected for the sampling. Types of animal identification include,
but are not limited to, livestock market or sale barn back tags, producer ear tags, feedlot identification tags, Canadian tags,
vaccination tags, calf-hood (bang) tags, tattoos, and brands. In addition, FSIS inspection program personnel must request
information on the producer/owner name and address of the animal selected for sampling from the establishment.
The identification information must be maintained with the carcass and/or laboratory form number until all laboratory tests are
performed according to 9 CFR 310.2 (b)(5)(ii) to allow for trace back, if the laboratory results indicate a trace back is necessary.
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Small Plant NEWS
Editor: Keith Payne
Managing Editor: Jane Johnson, DVM
Production: Joan Lindenberger, Sally Fernandez
Design: Gordon Wilson, Duane Robinson
Contact: Small Plant News, USDA/FSIS, Patriots Plaza III, Rm. 9-267A, Mailstop 3778,
1400 Independence Ave., SW, Washington, DC 20250