Food Safety: Managing plant access and egress
Doors, gates and windows are integral parts of food defense and food safety.
The events of 9/11 changed how food processors and warehouse operators regard food defense programs. In addition, the Food Safety Modernization Act (FSMA) of 2010 emphasizes food defense, asking processors and handlers to conduct risk assessments on the potential for intentional hazards, including acts of bioterrorism.
When developing a food safety and/or food defense program, all access and egress points should be addressed. These include doors, windows, gates and other possible access points, as well as egress points such as hatches in the roof, crawl spaces above hanging ceilings and drains that run under outer-barrier areas to plumbing, sewerage and utilities. And even though access and egress are crossover areas, they should remain separate in the safety and/or defense program since addressing them at the same time dilutes the focus and could compromise how each is managed.
Facilities with fenced yards present a clear barrier. Most fences are topped with barbed or razor wire, and cyclone fencing is usually the material of choice due to cost and ease of assembly. However, operators must ensure the fence provides a barrier, especially when drains pass under it or there are dips in the ground. Consequently, every food defense audit should include routine inspections to ensure the outer perimeter is secure.
All fences are pierced by one or more gates that provide access for vehicles and/or employees, but gates can provide an unauthorized access point to the property if they are not properly managed. Some operations build guard shacks that monitor inbound and outbound traffic; others leave the gate open and unattended during operations. Many operations also mount closed circuit cameras to monitor these points, and prominently placed cameras can also act as a deterrent. The recordings should be viewed on a regular basis.
Many operations place employee parking beyond the fences and funnel workers through gates that are either accessed by pass cards or manned by a guard who checks identification. Today, some plants have eliminated pass cards and use technologies such as thumb or eye scans.
Food processing facilities and warehouses usually have multiple access points such as loading docks, doors to move pallets or equipment in and out, personnel doors and emergency exits. They protect the facility from unauthorized access by people and also protect against pests.
When developing pest management programs, operators should have the following documented in their procedures.
- All doors, both personnel and loading bays, shall be designed to minimize pest access. Doors shall be fitted with rubber bumpers or brushes to ensure they seal tightly to the floor.
- Doors shall be fitted with air curtains that are either left on at all times or immediately engage when the doors are opened. Air curtains shall be regularly inspected to ensure they function properly (proper airflow and direction).
- All doors shall be self closing and shall not be propped open.
- Windows shall be screened, and the screens shall be maintained.
- If any damage is noted, the issue shall be reported to maintenance.
One prominent issue in older plants is the corrugated metal door that must be rolled up and down by hand. Because it may take a minute or two to get the door up and down, facilities tend to leave them up during working hours that may extend into night when rodents and other pests become more active.
With 12- to 15-foot high doors, the efficacy of air curtains is reduced, so processors should consider rapid roll-up doors in these cases. These doors are designed to “pop” out of the tracks if hit by a fork truck and can usually be quickly put back into operation. If a truck hits a corrugated door, it is usually damaged beyond repair. However, most companies try to make repairs that don’t fit properly, providing a potential access point for pests.
All doors, windows and potential access points should be included in an internal audit. The audit should ensure self-closing devices work properly; emergency exits are accessible; panic bars work; alarmed doors actually trigger an alarm; doors are tight; screens are intact; and windows are secure. Plus, all policies regarding access and egress must be followed.
Understanding, managing and documenting facility access and egress are essential to the success of any food safety and/or food defense program.