FOOD DEFENCE SELF-ASSESSMENT CHECKLIST

GRAIN HANDLING FACILITIES

Copy No. Uncontrolled

Canadian Grain Commission

Process Verification and Accreditation Office
Industry Services
900-303 Main Street
Winnipeg, Manitoba
Canada R3C 3G8

April 1, 2017
2017 © Canadian Grain Commission Revision 1
Table of Contents

Using this Checklist ........................................................................................ 3

Determining Risk ........................................................................................... 3
Physical Security of the Facility ........................................................................ 6
Access to the Facility ...................................................................................... 7
Personnel Procedures ..................................................................................... 9
Receiving and Shipping Procedures ................................................................ 11

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 Food Defence Self-Assessment Checklist
Grain Handling Facilities

The first part of developing a Food Defence good operating practice is to perform a
self-assessment of your current security and food defence practices. This self-
assessment will help you determine which policies and practices you may already
have in place to prevent intentional tampering, and as well, will serve as a guide to
helping you implementing food defence good operating practices.

This checklist is not an exhaustive list but is meant to be a guidance tool for
assessing your facility’s compliance to PPR-015 Food Defence. You may encounter
critical areas or assets not covered in this checklist that are specific to your facility
that may be at risk to tampering or intentional contamination. Likewise, you may
also find that your facility has dealt with potential food defence risks in ways that
are not suggested by this checklist. The best way to use this checklist is to compare
the recommended practices to your facility’s current practices, adding security
measures where deficiencies are found and omitting recommendations that are not
applicable to your facility or where other measures adequately cover the risk.

Using this Checklist

Each section focuses on an asset or process that may be at risk and lists a series of
options that may be used to increase the security of that asset or process. Security
options for each section may include, but are not limited to, one or a combination of
any number of the options given.

If “no” is selected for a security option, it is highly recommended that your facility
consider implementing policies, procedures and infrastructure to enhance the
security for that particular asset or process. There may be options that are not
feasible for your facility or may be deemed excessive for your operation (e.g.
installing fences around your facility, video surveillance cameras). If this occurs,
then the following questions should be considered:

1. What is the risk to the asset or process if this security option is not
implemented?
2. Are there other security measures implemented or that can be implemented
that would mitigate any security breach of that asset or process?

Determining Risk

Determining whether an asset or process is at risk involves thinking about these

assets and processes from the perspective of an attacker wanting to do harm. You
want to identify the most attractive targets for attack and what points in your
facility’s infrastructure or operations are most vulnerable. Once you have

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determined which assets or processes are most at risk, you can then focus
resources on reducing the likelihood of security breaches within your facility.

Using a risk assessment model, such as the CFIA model shown in Figure 1, may
help to assess the significance of a food defence breach. This may help you to
decide where resources are best allocated for your facility’s food defence plan.

If you answer “no” to any of the questions in the checklist, you should consider:
 How likely is it that an attack could occur without this measure in place?
 How severe are the consequences if there was an attack?

The likelihood of occurrence as depicted on the vertical axis (Figure 1) refers to the
chance that an attack may occur. The likelihood of a breach in security increases as
control over assets and processes decreases.

The severity of the consequences as depicted on the horizontal axis (Figure 1)

refers to the impact that intentional taint or tampering will have on human health.
The severity of consequences is broken down into one of 3 categories:

Low – no medical attention required

Medium – medical attention required, but full recovery of consumer expected
High – medical attention required, no chance of recovery of the consumer

To determine the risk of tampering or intentional taint, combine the results of the
likelihood of occurrence with the severity of the consequences. The outcomes vary
based on the likelihood that tampering or intentional taint will occur and the
severity of the consequences.

High A Mi Ma C

medium A Mi Ma Ma
Likelihood of
Occurrence

low A Mi Mi Mi

remote A A A A

low medium high

Severity of
Consequences

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There are four levels of risk in this model:

Acceptable (A) – a very small possibility of risk

Minor (Mi) – a low level of risk
Major (Ma) – a moderate level of risk
Critical (C) – a high level of risk

Depending on the outcome of your risk assessment, you may need to evaluate
whether or not another security measure will mitigate this risk or if additional
security measures are required. It is impossible to eliminate all risk, but you must
be able to ensure that risk is reduced to an acceptable level.

When completing this checklist, conduct the risk analysis for each section to which
you answered “no” and then document your justification for your risk mitigation
action. It may be as simple as having another security measure in place that will
protect the process or asset. If you find that a process or asset is not adequately
addressed, other security measures may need to be implemented.

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Physical Security of the Facility

Required outcome: physical barriers and deterrents are installed to deter

intruders and prevent access to the facility

Assessment: What type of physical security measures does your facility have to
prevent unauthorized access to the critical areas or assets of your operation?
Yes No N/A
Unattended entry points (doors, windows, ventilation system
access) to the facility are secured with locks, seals or sensors
Security lighting in high risk or dimly lit areas
Motion activated lighting in high risk areas
Motion detection devices and alarms that are monitored by an off-
site security company or contractor
Video surveillance equipment in high risk areas
Surveillance patrols by a contracted security firm
Perimeter fencing around the facility with locked gates

Risk analysis and mitigation:

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Access to the Facility

Required outcome: access to assets or processes that are at risk for tampering or
taint is restricted for unauthorized persons

Assessment: What type of operational security measures does your facility have to
prevent unauthorized access to the critical areas or assets of your operation?
Yes No N/A
Designating sensitive or high risk areas of the facility as restricted
areas (e.g. chemical storage, utility system access, areas used to
store sensitive information) and controlling access to these areas
Maintaining employee shift schedules to ensure that supervisors
know which employees to expect on-site
Limiting employee access to critical areas or assets of a facility
based on employee job function
Designating specific areas for parking, keeping staff parking
separate from visitor parking
Requiring all visitors, contractors and vendors to sign in with a
designated company representative upon arrival
Requiring all visitors, vendors and contractors to be accompanied
while on the premises

Risk analysis and mitigation:

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Assessment: How is the grain handling process flow secured in your facility?
Yes No N/A
Preoperational assessment of the premises and equipment is
conducted to inspect for signs of tampering, vandalism or breach
of security
Exterior ladders are locked/access is restricted
Receiving pit is covered and secured when not in use (e.g. after
hours)
Grain discharge spouts are secured when not in use
Storage bins and containers are secured when not in use
Doors to maintenance and tool sheds and chemical storage areas
are secured
Access to the facility’s control room is restricted
Access to the facility’s power supply (e.g. electrical panels,
generators) is restricted
Computer-generated information is safeguarded; information is
password-protected; anti-virus software is installed and updated;
and saved data is backed up and stored off-site
Inventory records of all grain and non-grain inputs are kept
current
Physical records (documents, scale tickets, bills of lading etc.) are
stored in a secured, locked area
Restrict access to company keys and/or limit access to authorized
personnel only

Risk analysis and mitigation:

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Personnel Procedures

Required outcome: procedures are in place to ensure that employees of the

facility are unlikely to pose a food defence risk to the facility or its operations

Assessment: Does your facility have food defence personnel procedures in place?
Yes No N/A
Resumés are requested from applicants; qualifications are
screened; and multiple references are contacted
Short-term and seasonal employees are restricted from accessing
critical assets or areas
Work assignment schedules are developed and maintained
Employees are trained in food defence and security policies and
procedures, including whom to contact in case of emergency,
which areas of the operation are high risk and where the shut-off
points are for utilities. Training is conducted on a regular basis for
new employees and as a refresher for existing employees
Employees are trained to report suspicious activities or
behaviours, misplaced equipment or suspicious materials or
devices
Supervisors and management are trained to be alert for atypical
illness or health conditions among employees
When employees are terminated or resign, all employee
identification, facility keys, access cards, cell phones and other
company electronic devices are returned
When employees are terminated or resign, all access to
information (e.g. computer log-in and email accounts) is
suspended
When employees are terminated or resign, company records are
updated to reflect this change in authorization and customer
contacts are notified in the change in authorization
Contractors performing work on site are briefed on the facility’s
security rules and what areas of the plant they are allowed to
access
Truck drivers delivering grain and non-grain inputs are restricted
to receiving areas only
The entry of employees into the facility during non-working hours
is restricted to authorized personnel only
Employees and contractors are prohibited from bringing personal
items not required for job performance into the grain handling
area

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Risk analysis and mitigation:

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Receiving and Shipping Procedures

Required outcome: inbound and outbound grain and non-grain inputs are not
potential targets for taint or intentional contamination

Assessment: what procedures does your facility have in place to ensure the
security of the receiving and shipping operations?
Yes No N/A
The company has a supplier approval program for purchasing
non-grain inputs
The company has a producer approval program in place for
purchasing grain
Grain is inspected upon receipt for evidence of taint or tampering
Non-grain inputs are inspected upon receipt for evidence of taint
or tampering
The receiving area, including the pit, is inspected as part of the
facility’s start-up procedures
Transport affidavits are required before incoming grain is received
at the elevator
Transport conveyances (railcars, containers, trucks) are inspected
before grain is loaded for shipping
Outgoing shipments are sealed with tamper-evident seals and the
seal number is documented on the outgoing shipping documents
Access to receiving areas and loading docks are monitored
Unfit and contaminated goods are segregated in a way that
minimizes the likelihood of compromising other goods
Security measures and procedures are in place at all off-site and
public warehousing locations

Risk analysis and mitigation:

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