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Facility Risk-Assessment and Security Guide

Facility Risk-Assessment and Security Guide ..for grain Elevators, Feed/Ingredient Manufacturers, grain Millers and Oilseed National grain and Feed Association North American Millers Association September 2009. Copyright 2001, 2004, 2009. By the National grain and Feed Association 1250 I St., , Suite 1003. Washington, , 20005-3922. E-Mail: Web Site: Copyright 2009. By the North American Millers Association 600 Maryland Ave., Suite 825 West Washington, , 20024. E-Mail: Web Site: All Rights Reserved. No portion of this publication may be reproduced or transmitted in any form or by any means, electronic or mechanical, without prior permission in writing from the publisher. Disclaimer: The National grain and Feed Association and North American Millers Association make no warranties, expressed or implied, concerning the accuracy, application or use of the information contained in this publication. Further, nothing contained herein is intended as legal notice. Competent legal counsel should be con- sulted on legal issues.

2 Introduction This guide assists grain elevators, feed and feed ingredient manufacturers, flour mills, and other grain and oilseed processors in conducting facility risk assessments, as …

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Transcription of Facility Risk-Assessment and Security Guide

1 Facility Risk-Assessment and Security Guide ..for grain Elevators, Feed/Ingredient Manufacturers, grain Millers and Oilseed National grain and Feed Association North American Millers Association September 2009. Copyright 2001, 2004, 2009. By the National grain and Feed Association 1250 I St., , Suite 1003. Washington, , 20005-3922. E-Mail: Web Site: Copyright 2009. By the North American Millers Association 600 Maryland Ave., Suite 825 West Washington, , 20024. E-Mail: Web Site: All Rights Reserved. No portion of this publication may be reproduced or transmitted in any form or by any means, electronic or mechanical, without prior permission in writing from the publisher. Disclaimer: The National grain and Feed Association and North American Millers Association make no warranties, expressed or implied, concerning the accuracy, application or use of the information contained in this publication. Further, nothing contained herein is intended as legal notice. Competent legal counsel should be con- sulted on legal issues.

2 Contents Introduction .. Page 2. Part I: Guidance for Conducting a Facility Risk Assessment .. Page 7. Part II: Guidance for Implementing a Facility Security Plan .. Page 11. Part General Security of Physical Facility and Grounds .. Page 12. Part Operating and Personnel Procedures .. Page 15. Part Shipping and Receiving Procedures .. Page 17. Part Emergency Response Procedures .. Page 19. Appendix 1: Sample Forms .. Page 22. Sample Emergency Contacts Telephone List .. Page 23. Sample Employee Emergency Telephone List .. Page 24. Sample Visitor's Log .. Page 25. Appendix 2: Sample Facility Security Plan Template .. Page 26. Appendix 3: Sample Generic Facility Flow Diagrams .. Page 46. Generic Country Elevator Flow Diagram .. Page 47. Generic Feed Mill Flow Diagram .. Page 48. Generic Flour Mill Flow Diagram .. Page 49. Generic Export Elevator Flow Diagram .. Page 50. Appendix 4: Links to Facility Security -Related Information .. Page 51. Appendix 5: Glossary of Security -Related Terms.

3 Page 52. 1. Introduction This Guide assists grain elevators, feed and feed (NAMA) participated in reviewing and modifying the ingredient manufacturers, flour mills, and other grain draft. and oilseed processors in conducting Facility risk assessments, as well as in developing and implementing Importantly, this Guide provides basic concepts Facility Security plans. that can be used as a starting point upon which to build Facility -specific Risk-Assessment and secu- This Guide was developed initially by the National grain rity plans. As such, it should be viewed as a and Feed Association (NGFA) in 2001. It subse- foundation or the base of a pyramid upon quently was updated and expanded by the NGFA in which individual companies can build their own 2004. In 2008, it was reviewed and further revised by tailored plans specific to their Facility operations the Joint Agroterrorism/ Facility Security Committee and personnel; agricultural commodities handled;. comprised of members of the NGFA, North American geographic surroundings; potential threats; and Export grain Association (NAEGA), and grain other conditions.

4 Elevator and Processing Society (GEAPS) to reflect lessons learned from a series of Facility vulnerability Appendix 2 may be particularly useful. It pro- assessments in which these organizations participated vides a sample template for developing a Facility in partnership with federal and state agencies. In Security plan. addition, the North American Millers Association How this Guide is Organized This document is organized in the following manner: Appendix 2 contains a Sample Facility Security Plan Template that can be used in Part I provides guidance for conducting a conjunction with Part II of this Guide to Facility risk assessment. develop a new or modify an existing . Security plan for your Facility . Be sure to Part II provides guidance for developing and include other or different Facility - Security implementing a Facility Security plan. procedures already used at your Facility and its operations. This template also is available Part Presents a menu of options electronically in a fill-in-the-blank format by for addressing the general Security of the clicking here.

5 Importantly, this document is physical Facility and grounds. designated as Sensitive Security Information . (SSI) under federal law, and is not to be Part Presents options for address- distributed or released to persons not in a ing operating and personnel procedures. need-to-know status within your company. Part Presents options for address- Appendix 3 contains generic flow diagrams ing shipping and receiving procedures. of various types of facilities to assist in con- ducting a Risk-Assessment . Part Presents options for address- ing incident-response procedures. Appendix 4 contains links to useful Facility Security -related information available from Appendix 1 contains sample forms that can various public and private-sector websites. be used for developing: 1) an emergency telephone list; 2) an employee emergency Appendix 5 contains a glossary of commonly telephone list; and 3) a visitor's log. used Security -related terms. 2. The topics discussed and guidance provided in this effective, practical and realistic for the type, document are not formal recommendations.

6 Nor are characteristics and operation of the Facility for they a comprehensive compilation of all Security issues which they are intended, as well as the physical confronting the grain , feed, milling and processing environment in which the plant exists. There is industry or other agribusinesses. Rather, this docu- no one-size-fits-all approach. Further, different ment provides a menu of ideas and concepts that plans may be appropriate for different facilities managers can consider when conducting a Facility risk operated by the same company, based upon the types assessment and developing a Facility Security plan. of processes, circumstances and conditions present. In addition, it is extremely important that you It is extremely important when conducting a risk select Facility - Security measures that address assessment and developing or modifying a Facility real, rather than perceived, risks, are achievable Security plan to select those procedures that are and will be implemented.

7 Benefits In addition to the obvious benefit of reducing the risk human resource policies that increase the aware- of an attack from an insider or outsider, there are ness of and address disgruntled employees or several major business-related benefits to conduct a behavioral issues in the workplace. Facility risk assessment and develop a sound Facility Security plan: It encourages building ongoing relationships with local law enforcement, emergency responders and It helps facilities comply with government-man- other key local, state and federal officials who are dated food/feed-defense requirements. critical resources in the event of a natural disaster, terrorism event or other emergency. It reinforces a Facility 's standard operating proce- dures, internal controls, quality-assurance plans and It may make Facility and product liability insurance other programs that foster the production of safe more available and affordable. food and feed, thereby providing additional assur- ances to customers.

8 It makes management more aware of the other systems upon which their facilities rely, such as It makes management and employees alike more suppliers, transporters and other infrastructure. aware of potential risks to their operations, as well as mitigation strategies that can help prevent It ultimately protects the company's shareholder theft and other non-terrorist-related incidents. and brand value, which can be undermined by a food/feed safety incident. It encourages the development/refinement of Federal Government Requirements Several federal government standards and directives Presidential Security Directives: In the pertain to Facility Security . Some of those that may aftermath of Sept. 11, 2001, President Bush issued apply to your Facility are explained in this section, and a host of Homeland Security Presidential Direc- are provided for your awareness. Not all apply to all tives ordering federal departments and agencies facilities; for instance, the maritime Security require- to take specific actions to protect the nation from ments apply to grain and other facilities regulated terrorist acts.

9 For agriculture, the most important under the Maritime Transportation Security Act of these is Homeland Security Presidential Direc- (MTSA). This section also may not encompass all tive Number 9 (HSPD-9), designed to harden the requirements that apply to all facilities. agricultural sector and make it less vulnerable to a terrorism incident or other Security -related 3. breaches that could compromise the safety of the tampering ; 3) actions to be taken in the event of a food supply. HSPD-9 is a sweeping executive national emergency ; and 4) emergency contact order that directs several federal agencies to work information for local Security authorities. For more cooperatively to develop plans to protect the safety information from the NGFA, click here. and Security of the nation's plant and animal-based food supply. USDA's Requirements for Suppliers of Do- mestic and International Food Assistance: Among other things, HSPD-9 directs the secretar- Similarly, USDA has indicated its intent to soon ies of agriculture; health and human services require contractually that companies supplying raw (which includes the Food and Drug Administration), or processed agricultural commodities for its and homeland Security to expand and continue domestic or foreign food aid programs (such as the vulnerability assessments of the agriculture and School Lunch Program and 480 food aid food sectors, and to update those assessments shipments) conduct Facility vulnerability assess- every two years.

10 It also requires USDA and the ments and implement Facility Security plans. Departments of Homeland Security , Health and Human Services, and Justice (including the FBI), as Bioterrorism Act Facility Registration: Under well as the Environmental Protection Agency, CIA the Bioterrorism Act of 2002, the Food and and other federal agencies, to prioritize, develop Drug Administration (FDA) requires domestic and and implement mitigation strategies to protect foreign facilities (and their agents) that vulnerable critical nodes of production or processing manufacture, process, pack or hold ( , store). from the introduction of diseases, pests or poison- food for human or animal consumption in the ous agents. And it calls on federal agencies to United States to register with the agency. Among expand on the development of common screening the types of facilities covered by this regulation are and inspection procedures for agriculture and food grain elevators, commercial feed mills, flour mills, products imported into the United States, and to corn and oilseed processing plants, pet food manu- maximize effective domestic inspection activities facturers, renderers and others.


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