guarding america - defending freedom public health 779 amds/sgpm joint base andrews, md food safety...
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Guarding America - Defending Freedom
Public Health
779 AMDS/SGPM
Joint Base Andrews , MD
FOOD SAFETY AND
FOOD DEFENSE PROGRAMS
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Overview
Tri-Service Food Code, AFMAN 48-147
Operational Rations
Food Vulnerabilities
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The Tri-Service Food Code (TSFC)
TB MED 530/NAVMED P-5010-1/AFMAN 48-147_IP
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Overview
Document Sources Applicability General Principles Major Changes DD Form 2973, Food Operation Inspection Report
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Document Sources
AFMAN 48-147_IP, Tri-Service Food Code (TSFC) http://static.e-publishing.af.mil/production/1/af_sg/publication
/afman48-147/afman48-147.pdf
http://armypubs.army.mil/med/DR_pubs/dr_a/pdf/tbmed530.pdf
DD Form 2973, FOOD OPERATION INSPECTION REPORT http://www.dtic.mil/whs/directives/forms/eforms/dd2973.pdf
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Applicability
All Services CONUS & OCONUS Does not apply during OCONUS exercises where Food
and Water Risk Assessments are conducted at commercial facilities or foreign military food operations.
Does not replace veterinary regulations (e.g., AR 40-657/NAVSUP 4355.4H/MCO P10110.31H; or the DOD MIL-HDBK 3006C)
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General Principles Categories of importance & other symbols
Symbol Description Meaning
Asterisk * Designates a CRITICAL provision
Superscripted letter S Designates a SWING provision (may or may not be considered CRITICAL)
Superscripted letter N Designates a NONCRITICAL provision
Superscripted dagger †
Indicates the provision was added by the Uniformed Services and is not presented in the FDA Food Code
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General Principles Category Definitions
CRITICAL refers to a condition/provision that is likely to result in food contamination, illness, or a significant environmental health hazard
SWING provisions represent criteria that are generally critical, but may be considered a non-critical violation, depending on the circumstances. Regulators must apply professional judgment. Consistency among inspection team members will decrease frustration among food facility managers.
Provisions containing Swing items: 3-202.11 Temperature* (food receiving) 3-301.11 Preventing contamination from hands* 5-205.15 System maintained in good repair* (plumbing) 7-201.11 Separation* (poisonous or toxic materials) 7-208.11 Storage* (first-aid supplies) 7-301.11 Separation* (retail sale/stock poisonous or toxic materials)
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General PrinciplesRisk Category Inspection
Frequency Examples of Facilities
Extremely High Monthly Shipboard; Hospital nutrition care serving in- or out-patients; Child Care Facilities1; Field foodservice (tactical)
High Quarterly Dining Facility (DFAC); Fast-food concessions; Community club
High Quarterly
Retail Store: Large retail store providing one or more of the following Advanced2 food services: rotisserie chicken; on-site macaroni, tuna, egg, or potato salad prep, sandwich prep/Panini; sushi bar; self-serve salad/soup/buffet bar; bakery (preparation by mixing raw ingredients); fresh seafood department
Moderate 6 months Small food concession; Coffee shop (packaged food; not prepared on site); Ice cream shop; Mobile snack truck
Moderate 6 months
Retail Store: Retail stores providing Basic2 food services; characterized as retail stores providing typical grocer services (commercially packaged goods) and may include one or more of the following: limited bakery (bakes using frozen products or pre-mixed dough); deli that does not perform cooking or food prep from raw ingredients; self-serve sandwiches (hot breakfast or commercially packaged); hot dogs, pizza, or other pre-cooked foods held in hot holding for individual service. Examples include: Mini-mart, Shoppette/Express, or gas station retail store.
Low Annually Vending machine operations; Food establishments dispensing non-PHFs only
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Major Changes Regulatory inspection types (8-400.20 [page 151] and 8-6)
Inspection Type Description
Pre-operational conducted before a facility is authorized to open for business; new facility
Routine planned inspection; unannounced and always comprehensive
Complaint investigates specific issue/concern presented by a customer
Follow-up conducted as a result of a non-compliant rating (“shall be conducted no later than 5 calendar days following the Non-Compliant inspection”)
Other (specify) Walk-through, self-evaluation, or contract performance
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Major Changes
Food establishment self-evaluations (8-402.12 [page 156]) Performed & documented weekly by food establishment
manager/PIC; Documented using the Food Operation Inspection Report
or other appropriate self-evaluation checklist. Records retained on site for 1 year.
Daily informal assessments do not require documentation.
Documents reviewed by regulatory authority during routine inspections.
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Major Changes
Inspection frequencies Minimum frequencies recommended for
each type of food operation based on Assumed risk associated with operation
complexity Primary population served Historical inspection performance
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Major Changes
Inspection Rating Criteria (page158) Process is no longer subjective
Rating CriteriaFully Compliant No deficiencies
Substantially Compliant No Imminent Health Hazard (IHH)1; Two or less Critical findings Corrected on Site (COS)2; Five or less Non-Critical findings
Partially Compliant No IHH Three or more Critical findings COS; Six or more Non-Critical findings
Non-Compliant Any IHH present Any Critical findings not COS
1 Presence of any imminent health hazard results in a Non-Compliant rating.2 Presence of any Critical finding that cannot be corrected on site results in a Non-Compliant rating.
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Major Changes Time frame for corrections and follow-up inspections (8-405.11
& 8-406.11 [page 160])— Critical findings shall be corrected on-site (COS) (i.e. during
the inspection); Non-compliant inspection ratings require a formal follow-up
within 5 calendar days. Critical findings not COS will result in a Non-Compliant
inspection rating Follow-up inspections are documented on the Food
Operation Inspection Report, DD Form 2973. Follow-up inspections will continue (within 5 calendar days
of the last inspection) until the critical finding is completed Non-critical findings must be corrected by a date & time
agreed to or specified by the regulatory authority & no later than 30 calendar days.
Follow-up inspection to verify correction of non-critical violations are at the discretion of the regulatory authority.
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Major Changes Medical Authority vs. Regulatory Authority
The designation of these roles was not consistently applied by each Service
Medical authority is the medical commander or command surgeon whose authority is above the preventive medicine, public health, or veterinary activity performing food safety surveillance
Regulatory authority is the public health, preventive medicine, or Vet asset with jurisdiction over the food establishment to conduct food safety surveillance
Highly susceptible population Definition broadened to include Service members during Initial Entry Training Military, DOD civilians, and contract personnel during
deployments & afloat Personnel in field exercises lasting > 2 weeks
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Major Changes Potentially hazardous food (“PHF”)
Now called Potentially Hazardous Foods – Time and Temperature Control for Safety Foods [PHF(TCS)]
Includes heat-treated plant foods, raw seed sprouts, cut melons, cut leafy greens, and cut tomatoes
Safe Temperatures for holding PHF(TCS) food Cold holding temp changed from 40oF to 41oF (5oC) or below.
Hot holding reduced from 140oF to 135oF (57oC) or above
“Temperature Danger Zone” is 42oF (6oC) through 134oF (56oC) inclusive
Cold Holding Temperature Danger Zone
Hot Holding
Less than or equal to 41oF (5oC)
42oF (6oC) through 134oF (56oC) inclusive
Greater than or equal to 135oF (57oC)
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Major Changes Leftovers (3-501.110 [p. 580])
Cold hold up to 72 hours Hot hold until consumed or discarded
“Topping off” hot hold items is prohibited Retention of foods containing leftover items as an
ingredient is prohibited (no leftover leftovers) Time Only as a Public Health Control (3-501.19 [p. 57])
4-hour rule unchanged for hot & cold holding in temperature danger zone
New 6-hour rule: Chilled PHF(TCS) food may be held for up to 6 hours outside of the safe temperature zone as long as the food does not exceed 70oF at any time during the 6-hour period
Facility must have a written procedure that is approved by the regulatory authority before “Time Only” may be employed.
Does not include food prep time
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DD Form 2973
Inspection form: DD Form 2973, Food Operation Inspection Report
Used for ALL food service operation types (except Tactical Kitchens, which require DD Form 2974, Tactical Kitchen Food Sanitation Inspection)
Replaces: DA Forms 5161-R, 5161-1-R , 5162-R; MEDCOM Form 640-R; AF Form 977 (obsolete), and NAVMED 6240/1 (and all local variations).
Customization of the DD Form 2973 without authorization is not permitted.
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Operational Rations
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Purpose
Types of Rations
Location and Frequency of Local Rations Inspections
Overview
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Purpose
Our ability to sustain a fighting force in a combat zone depends upon the ability to keep the troops supplied with the necessities of life.
Part of that plan is to feed our troops operational rations until other food supply lines and equipment have been established and received.
DOD rations’ inspection program ensures consistency and accuracy among the services.
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MRE
22
Meal Ready-to-Eat (MRE)
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Meal, Religious
Meal, Religious, Kosher/Halal
23
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MCW/LRP
Meal, Cold Weather/Long Range Patrol
24
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TOTEM
Tailored Operational Training Meal
25
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HDR
26
Humanitarian Daily Ration
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Survival, GP
Survival, General Purpose, Improved (GP-I) Sustain an individual under all environmental
conditions, including escape & evasion
Contains 5 compressed bars, lemon tea, sugar, and soup 1446 calories
Individual prepares food…H2O needed for beverage
27
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Types and Scheduling of Inspections
Receipt Inspections Surveillance Inspections Warranty Inspections Prior to Sale or Shipment (Surveillance) Special
28
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Food Vulnerability Assessment (FVA)
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Overview
Food Defense Goals References Roles and Responsibilities Procedures for conducting a FVA Reporting/routing
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Food Defense Goals
Risk Management Deter Contamination Delay Contamination Detect Contamination Respond to Contamination
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References
AFI 10-245, Antiterrorism AFI 10-246, Food and Water Protection Program AFI 48-116, Food Safety Program USAFSAM/PHR
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Food Defense - protecting the food supply from deliberate or intentional acts of contamination or tampering
The World Health Organization states that the ‘malicious’ contamination of food by terrorists is a real and credible threat and could have global impact
Food Defense
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Antiterrorism Officer (ATO) Core Vulnerability
Assessment Management Program (CVAMP)
DTRA Classifications Mitigation ATWG FPWG TWG
High Risk Vulnerability Medium Risk Concern Low Risk Concern Neutral Observation Positive Observation
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Risk Management is a cyclic systematic process to address potential hazards. It is a structured, common sense approach that can be applied to reduce risks and ensure that the best security measures are applied to daily operations (in this context, the food and water supply)
RM Five-Step ProcessThe RM five-step process is a continuous cycle and only works if all five steps are followed in sequence as each is a building block for the next step
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DoD Risk Matrix for BW Threat (HAZARD PROBABILITY)
GREATEST LEAST
Catastrophic
Critical
AnthraxBot.ToxinPlagueRicin
Marginal
TularemiaStaph. Enterotoxin
Mycotoxins (Tricothecene)
NegligibleQ-FeverCholera
Brucellosis
Med
ical R
isk
LEA
ST
G
REA
TES
T
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Facilities on and off Base Flight Meals, Water & Beverages for aircrews Emergency Rations – delivery, prep and storage Off-base Assets (distributors, caterers & contract quarters) Prioritize – (numbers served, key leaders, mission critical
personnel, etc.) Symbolic locations
An accurate, current list of prime vendors and food product flow diagrams will help to pinpoint important points in each process!
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Know who has access to the food and where it has been
Distribution Center
Distribution Center
Receipt/Inspection
Produce Storage
Food Preparation
Serving Line
Self-ServicePacking /Pickup Area
Troop Pickup
Dining Hall2
Dining Hall3
Meat Storage
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Human Element Workers, Supervisors, Managers, Auditors, Drivers - Anyone
who has access to the food is a risk
Physical Security Secure exterior doors Eliminate places where intruders can hide Ensure restricted areas are monitored and have physical
barriers such as lockable doors or roll down gates when appropriate
Stored food products securely (including refrigeration units) Proper Lighting Control roof access
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FDA and Department of Agriculture define food targets as items that are consistently at a higher risk for attack. Some factors that play into food targets are:
Large Batches Uniform Production Short Shelf Life Ease of Access
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FVA Step 1: Lead must be PHO or NCOIC (7-lvl or 9-lvl) or 5-lvl with FVA
training Coordinate with base Anti-Terrorism Officer (ATO) and
Physical Security Managers (PSMs) Facilitate FVA schedule with ATO, MSG/CC, MDG/CC, facility
managers, DeCA, FSS, SFS, and AAFES
Review previous FVAs
Review local threat brief
Review all base food operation contracts
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FVA Step 2: Develop a comprehensive list of food assets and contact facility mangers (On and Off-Base facilities, Distributors, Caterers, and Contract Establishments)
FVA Step 3: Conduct on-site assessment of facility (Begin five-step RM process using the appropriate DTRA checklist) Guided discussion with food facility/operation manager
Example: What are the procedures for responding to food product tampering?
Walk through Example: Are the procedures documented? Ask employees questions
FVA Benchmarks and tools (“Gumbo Site”, https://gumbo2.area52.afnoapps.usaf.mil/epi-consult/foodprotection/fooddefense/)
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FVA Step 4: Identify hazards (Step one of RM process) Potential aggressors? Possible threats? Hazardous agents?
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FVA Step 5: Assess the hazard (Step two of RM process)
Use “What If” tool
Consider Utility Protection Principles
Deter, Delay, Detect, and Respond (DDDR)
SEVERITY
CAT I- CATASTROPHIC – complete mission failure, death.Example: Death or widespread severe illness.
CAT II - CRITICAL – Major mission degradation, severe injury, illnessExample: Multiple food borne illnesses.
CAT III - MODERATE – Minor mission degradation, minor injury, illnessExample: Sporadic food borne illness, loss of confidence in food supply safety.
CAT IV - NEGLIGIBLE – less than minor, little or no adverse impact on mission capability or readiness.
Frequent Likely Occasional Seldom Unlikely
A B C D E
Catastrophic I
Critical II High
Moderate III
Negligible IV Low
PROBABILITY
SEVERITY
RISK LEVELS
Extremely High
Medium
A.FREQUENT - Occurs often in career to individuals , population is continuously exposedB. LIKELY – Occurs several times in a career, population regularly exposed.
C. OCCASIONAL – Will occur in a career, sporadic in a population.
D. SELDOM – May occur in a career, occurs seldom in a population.
E. UNLIKELY – Can assume it will not occur, occurs very rarely in a population.
PROBABILITY
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FVA Step 6: Determine and assign risk levels
VULNERABILITY A situation or circumstance that if left unchanged May result in the loss of life or damage to mission-essential resources.
Medium Concern
Low Concern
A situation that is exploitable and that can indirectly lead to loss of life or damage to mission-essential resources.
Neutral
A practice that is neither exploitable nor can be reasonably assessed as leading to the death of a service member, DoD civilian, family member or the destruction of mission essential resources, but is being identified to suggest consideration of modification or continuation.
PositiveA practice that contributes to a successful AT program and merits further analysis and dissemination.
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FVA Step 7: Provide recommendations for controls (Step three and four of RM process)
Cost Factors Physical controls Engineering controls Procedures Feasibility – will it work? Impact to mission Upcoming renovations Timing - When to implement Attitudes – well received or
not Political environment Stakeholders - outside interest Chain of command – buy-in Willingness to maintain
Wing Commander Unit Commander ATO
Involve Stakeholders Facility Manager DECA AAFES SERVICES CE Fire Safety Security Forces Public Health
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FVA Step 8: Generate written report
CONFIDENTIAL
Provide to ATO and USAFSAM/PHR Food Protection via SIPR
Discuss at Threat Working Groups within 60 days of report
FVA Step 9: Supervise and evaluate (Step five of RM process)
Monitor effectiveness of control
Track progress on mitigating strategies and fixes, compliance with procedures
Provide updates to Force Protection Working Group, Threat Working Group, and Anti-Terrorism Working Group as needed
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Benchmark Description
CVAMP Benchmark G
BA
G (1
50
0)
SK
YB
AR
(30
0)
OB
DH
(30
00)
ZO
NE
(25
1)
TIG
GE
R (5
0)
KIT
E (2
50)
HO
MA
S (18
4)
MIJ
AS (
98
)
YU
TE
C (4
5)
Retail Facility Benchmarks: A Person is assigned responsibility for security and procedures… FS-FF-01
Access into building… FS-FF-02
Potable water storage… FS-FF-03
Contractors/visitors are supervised… FS-FF-04
Hazardous chemicals… FS-FF-05
Employees have… FS-FF-06
Truck locks and seals… FS-FF-08
Food products are inspected… FS-FF-09
Customers have unrestricted… FS-FF-11
Transportation Benchmarks: Drivers are required… FS-TR-04
CODE KEY:X = High Risk, Vulnerability.X = Medium Risk ConcernX = Low Risk, Observation/Concern N = Neutral ObservationP = Positive Observation
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QUESTIONS?