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Understanding packaging security risks

More than 140 attendees at a recent PMMI conference heard from FDA and other officials about minimizing company security risks.

Dr. David Armstrong of FDA addresses the conference, while Dr. Peter Slade (center) and Dr. Chuck Sizer look on.
Dr. David Armstrong of FDA addresses the conference, while Dr. Peter Slade (center) and Dr. Chuck Sizer look on.

Understanding security hazards and assessing the probability of an incident and its impact were the topics at the Packaging Security Workshop, held in early February in Itasca, IL. Sponsored by the Packaging Machinery Manufacturers Institute (Arlington, VA), the workshop drew more than 140 attendees, from packagers to suppliers to third-party evaluators.

That attendance—in these days of low-turnout conferences—is a strong indicator of the timeliness of the topic. The workshop was created and promoted just a few weeks before the event. But attendees were rewarded by the last-minute appearance of Dr. David J. Armstrong, assistant director of research at the U.S. Food and Drug Administration’s Center for Food Safety and Applied Nutrition.

Armstrong was joined by Dr. Chuck Sizer, director of the National Center for Food Safety and Technology, and his associate, Dr. Peter Slade. The three all talked in some detail about FDA’s recently issued food safety “preliminary guidances.” At the time of the workshop, these proposals were still open for comment by the public and by companies, before FDA finalizes later this year. That comment period closed then.

Repeatedly stressed throughout the day-long program was that these guidances—even when finalized—will be voluntary rules for companies to employ or not, depending on individual circumstances. The guidances, published Jan. 9, ’02 in the Federal Register, are also shown at the agency’s Web site, www.fda.gov. Or, suggested Armstrong, copies can be provided by e-mail from Jkvenberg@ cfsan.fda.gov.

Armstrong then moved through a series of slides of the Food Security Preventive Measures Guidance, beginning with a slide that recommends each company review current procedures and make improvements, encourages the commitment of management and employees, acknowledges that all measures are not appropriate for every company, and finally, supports the use of Operational Risk Management so companies can prioritize improvements.

Among the areas the guidance covers, according to Armstrong, are management of food security, the physical facility, employees, computer systems, raw materials and packaging, operations, and finished products. Each company should, he said, work to develop security strategies to include response to tampering or criminal or terrorist events, a recall strategy, and additional steps. Many of the individual recommendations, Dr. Armstrong pointed out, are primarily common-sense initiatives that many companies already employ, such as restricting access to facilities, especially for laboratories or storage of hazardous materials, and screening of employees.

He also recommended that companies should train employees in food security so they not only understand the restrictions but also buy into the program and become extra “sets of security eyes.” For raw materials and packaging, FDA recommends that companies tighten up security of shipments, requesting locked and sealed containers, and reconciling the amounts received with the amounts ordered and invoiced, and taking into account any materials that were used for testing.

Risk assessment detailed

Slade and later, Patrick Helm of Lockwood Greene Engineers, each discussed in detail how a company can look at potential risks, evaluate the consequences, and assign priorities for risk-control measures.

Slade described the process known as Operational Risk Management, a six-step plan to anticipate hazards and reduce the potential for loss. Those steps include identifying the hazards; assessing the severity of them on the company; analyzing control measures; making the risk-control decision; implementing the controls; and finally, supervising and reviewing the plans.

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