I sat down one morning to write out five reasons why someone should attend our public workshop that we hold in partnership with Mr. Rod Wheeler, Food Defense, Crisis Management and Intentional Adulteration. I stopped myself at twenty, but could have kept going! {modal component/k2/item/378-fsma-compliance-information-for-the-intentional-adulteration-rule|width=600|height=600}Click here to find out if you are subject to this rule.{/modal}

  1. We have a responsibility to ensure that our facilities and employees are safe from an intruder with a focus on causing harm.
  2. Effective Crisis Management programs protect our profits, brand, and employees.
  3. Even if we have had crisis management programs for years, we must evaluate them regularly to ensure they remain current and effective.
  4. Current management system standards (now also known as CPOs) all require a current crisis management program.
  5. We can learn from an experienced law enforcement detective, Mr. Rod Wheeler.   Mr. Wheeler shares his life lessons learned from years of experience defusing situations that required common sense and crisis management skills to protect the public.
  6. It is important to learn and practice the steps necessary to perform a vulnerability assessment.  Although companies often have a required vulnerability assessment, it is very important that we see this process from in independent external experienced individual such as Mr. Wheeler, who is uniquely qualified to judge its overall effectiveness.      
  7. I know that my company must be compliant with the new FSMA Food Defense Rule (Mitigation Strategies to Protect Food Against Intentional Adulteration, 21 CFR 11 and 121) and this is a golden opportunity to get a head start on the requirements for our operation and develop a compliant program.
  8. I know that FSMA has included exemptions to the Food Defense rule, but how can I be sure which (if any) of the exemptions and modified requirements apply to my operation? Do I need to maintain records as proof of my eligibility for an exemption?
  9. I remember through history some of the horrible issues that have happened where a disgruntled employee (or just a person looking to cause harm) have penetrated a facility, causing a lot of harm and sometimes death to innocent employees.  I know we can’t predict this, but we must take every measure possible to mitigate the effects of violence in our facility.
  10. My third-party auditor questioned me as to whether we have an effective program that ensures that our products are protected against contamination and our ingredients, packaging, software and formulas are controlled and protected against adulteration or tampering.
  11. We feel our facility is secure, but is it really? Can we learn how to effectively secure our operation?
  12. What about our visitor and contractor policy? Are we effectively protecting our operation? How do we know that?  What type of inspections should we perform (and what records should we keep) to ensure that when we are asked, we can demonstrate the effectiveness of our operation?
  13. Is our pre-employment screening and defense training programs effective for all our employees including our seasonal, temporary, contract workers and volunteers?   What type of screening should we do?   What is enough? 
  14. How do we educate our employees so that they can detect, prevent and respond to tampering, criminal or terrorist activity?
  15. How do we identify which employees should have clearance and password to our computer process control systems and critical data systems? What are the signs that a trusted employee is having personal problems that could lead to disaster if not addressed?
  16. Food defense and product adulteration is so vital that our company’s management, top executive and employees can be charged with a crime if they sell a product that is contaminated or otherwise makes someone sick (whether intentionally or not). We must protect our facility, employees and products from becoming contaminated in a way that could cause illness or death.
  17. Because I don’t believe that the potential for adulteration of our food supply will decrease any time soon. News headlines frequently warn against attempts (or worse, success) from those focused on causing harm to the innocent.   A headline in a central Florida paper twice warned again fish hooks in meatballs set out for dogs in a popular doggy park.   We must do everything we can do protect the public, and taking a course like this, from someone that has experienced so much and can share how to prevent the “what-if’s”, is so valuable in todays world of processing.   This applies to not only food, but other processes such as chemical or packaging manufacture.   One associate told us the story of a bottle of bleach that had been filled with a different chemical – one that when added to a bleach, would have caused a massive explosion – harming or almost killing the unsuspected house wife.   We must be proactive.
  18. If an incident has happened in your industry, you might think “Wow, recently there was a tampering issue with a product in our food category! When we did a risk assessment, it became evident that that could have been us.   We thought we had an effective program!  What an enlightening experience.   We need to educate our associates and we must be more careful.” Keep in mind that you may or may not be aware of all incidents – do some research on violence in the workplace and you will see that it crosses all barriers and affects businesses across the globe.
  19. As an auditor, I remember one day during an audit, I wrote a non-conformance because the auto entrance gate for having had a space large enough for me to crawl under when closed and locked. The client accused me of nit-picking, but I stand by my finding.   From a security viewpoint, access to the facility must be controlled.  It is amazing what those who want to do harm can think of to enter a facility.
  20. As food processors and handlers, we have a direct responsibility to educate ourselves in the best way possible. Not just to comply with the law, but to protect our customers and employees. There is no better way to really examine what we do and learn where we can improve than listening to Mr. Rod Wheeler.   This gentleman has evaluated operations and assisted companies from coast to coast in both preventing and troubleshooting tampering events.

When it comes to crisis management, we always think, “That won’t happen to us,” or, “That’s what insurance is for!” but the truth of the matter is that the way is littered with broken companies who have fallen by the wayside as terrible warnings to the rest of us, who then update our plans in response to their horrific tragedy. These events DO happen, and it is just a matter of chance that it was not us this time! There but for the grace of God go I. Please join us for this excellent and enlightening presentation by Mr. Rod Wheeler.