Facility Risk-Assessment and Security Guide

1 Facility Risk-Assessmentand Security Grain Elevators, Feed/Ingredient Manufacturers,Grain Millers and Oilseed National Grain and Feed Association North American Millers AssociationSeptember 2009 Copyright 2001, 2004, 2009By the National Grain and Feed Association1250 I St., , Suite 1003 Washington, , 20005-3922E-Mail: Site: 2009By the North American Millers Association600 Maryland Ave., 825 WestWashington, , 20024E-Mail: Site: Rights Reserved. No portion of this publication may be reproduced or transmittedin any form or by any means, electronic or mechanical, without prior permission inwriting from the : The National Grain and Feed Association and North American MillersAssociation make no warranties, expressed or implied, concerning the accuracy,application or use of the information contained in this publication. Further, nothingcontained herein is intended as legal notice.

2 Competent legal counsel should be con-sulted on legal 2 Part I: Guidance for Conducting a Facility Risk 7 Part II: Guidance for Implementing a Facility Security 11 Part General Security of Physical Facility and Page 12 Part Operating and Personnel Procedures .. Page 15 Part Shipping and Receiving Page 17 Part Emergency Response Page 19 Appendix 1: Sample 22 Sample Emergency Contacts Telephone Page 23 Sample Employee Emergency Telephone Page 24 Sample Visitor s Page 25 Appendix 2: Sample Facility Security Plan 26 Appendix 3: Sample Generic Facility Flow 46 Generic Country Elevator Flow Page 47 Generic Feed Mill Flow Page 48 Generic Flour Mill Flow Page 49 Generic Export Elevator Flow Page 50 Appendix 4: Links to Facility Security -Related 51 Appendix 5: Glossary of Security -Related Terms.

3 Page 522 IntroductionThis Guide assists grain elevators, feed and feedingredient manufacturers, flour mills, and other grainand oilseed processors in conducting Facility riskassessments, as well as in developing and implementingfacility Security Guide was developed initially by the National Grainand Feed Association (NGFA) in 2001. It subse-quently was updated and expanded by the NGFA in2004. In 2008, it was reviewed and further revised bythe Joint Agroterrorism/ Facility Security Committeecomprised of members of the NGFA, North AmericanExport Grain Association (NAEGA), and GrainElevator and Processing Society (GEAPS) to reflectlessons learned from a series of Facility vulnerabilityassessments in which these organizations participatedin partnership with federal and state agencies. Inaddition, the North American Millers Association(NAMA) participated in reviewing and modifying , this Guide provides basic conceptsthat can be used as a starting point upon which tobuild Facility -specific Risk-Assessment and secu-rity plans.

4 As such, it should be viewed as afoundation or the base of a pyramid uponwhich individual companies can build their owntailored plans specific to their Facility operationsand personnel; agricultural commodities handled;geographic surroundings; potential threats; andother 2 may be particularly useful. It pro-vides a sample template for developing a facilitysecurity this Guide is OrganizedThis document is organized in the following manner: Part I provides guidance for conducting afacility risk assessment . Part II provides guidance for developing andimplementing a Facility Security plan. Part Presents a menu of optionsfor addressing the general Security of thephysical Facility and grounds. Part Presents options for address-ing operating and personnel procedures. Part Presents options for address-ing shipping and receiving procedures.

5 Part Presents options for address-ing incident-response procedures. Appendix 1 contains sample forms that canbe used for developing: 1) an emergencytelephone list; 2) an employee emergencytelephone list; and 3) a visitor s log. Appendix 2 contains a Sample FacilitySecurity Plan Template that can be used inconjunction with Part II of this Guide todevelop a new or modify an existing Security plan for your Facility . Be sure toinclude other or different Facility -securityprocedures already used at your Facility and itsoperations. This template also is availableelectronically in a fill-in-the-blank format byclicking here. Importantly, this document isdesignated as Sensitive Security Information (SSI) under federal law, and is not to bedistributed or released to persons not in a need-to-know status within your company. Appendix 3 contains generic flow diagramsof various types of facilities to assist in con-ducting a Risk-Assessment .

6 Appendix 4 contains links to useful facilitysecurity-related information available fromvarious public and private-sector websites. Appendix 5 contains a glossary of commonlyused Security -related addition to the obvious benefit of reducing the riskof an attack from an insider or outsider, there areseveral major business-related benefits to conduct afacility risk assessment and develop a sound facilitysecurity plan: It helps facilities comply with government-man-dated food/feed-defense requirements. It reinforces a Facility s standard operating proce-dures, internal controls, quality-assurance plans andother programs that foster the production of safefood and feed, thereby providing additional assur-ances to customers. It makes management and employees alike moreaware of potential risks to their operations, aswell as mitigation strategies that can help preventtheft and other non-terrorist-related incidents.

7 It encourages the development/refinement ofhuman resource policies that increase the aware-ness of and address disgruntled employees orbehavioral issues in the workplace. It encourages building ongoing relationships withlocal law enforcement, emergency responders andother key local, state and federal officials who arecritical resources in the event of a natural disaster,terrorism event or other emergency. It may make Facility and product liability insurancemore available and affordable. It makes management more aware of the othersystems upon which their facilities rely, such assuppliers, transporters and other infrastructure. It ultimately protects the company s shareholderand brand value, which can be undermined by afood/feed safety topics discussed and guidance provided in thisdocument are not formal recommendations. Nor arethey a comprehensive compilation of all Security issuesconfronting the grain, feed, milling and processingindustry or other agribusinesses.

8 Rather, this docu-ment provides a menu of ideas and concepts thatmanagers can consider when conducting a Facility riskassessment and developing a Facility Security is extremely important when conducting a riskassessment and developing or modifying a facilitysecurity plan to select those procedures that areeffective, practical and realistic for the type,characteristics and operation of the Facility forwhich they are intended, as well as the physicalenvironment in which the plant exists. There isno one-size-fits-all approach. Further, differentplans may be appropriate for different facilitiesoperated by the same company, based upon the typesof processes, circumstances and conditions addition, it is extremely important that youselect Facility - Security measures that addressreal, rather than perceived, risks , are achievableand will be Government RequirementsSeveral federal government standards and directivespertain to Facility Security .

9 Some of those that mayapply to your Facility are explained in this section, andare provided for your awareness. Not all apply to allfacilities; for instance, the maritime Security require-ments apply to grain and other facilities regulatedunder the Maritime Transportation Security Act(MTSA). This section also may not encompass allrequirements that apply to all facilities. Presidential Security Directives: In theaftermath of Sept. 11, 2001, President Bush issueda host of Homeland Security Presidential Direc-tives ordering federal departments and agenciesto take specific actions to protect the nation fromterrorist acts. For agriculture, the most importantof these is Homeland Security Presidential Direc-tive Number 9 (HSPD-9), designed to harden theagricultural sector and make it less vulnerable to aterrorism incident or other Security -related4breaches that could compromise the safety of food supply.

10 HSPD-9 is a sweeping executiveorder that directs several federal agencies to workcooperatively to develop plans to protect the safetyand Security of the nation s plant and animal-basedfood other things, HSPD-9 directs the secretar-ies of agriculture; health and human services(which includes the Food and Drug Administration),and homeland Security to expand and continuevulnerability assessments of the agriculture andfood sectors, and to update those assessmentsevery two years. It also requires USDA and theDepartments of Homeland Security , Health andHuman Services, and Justice (including the FBI), aswell as the Environmental Protection Agency, CIAand other federal agencies, to prioritize, developand strategies to protectvulnerable critical nodes of production or processingfrom the introduction of diseases, pests or poison-ous agents. And it calls on federal agencies toexpand on the development of common screeningand inspection procedures for agriculture and foodproducts imported into the United States, and to maximize effective domestic inspection activities for domestic shipments of food products.