FSMA and Supply Chain FSMA and Supply Chain Security Security

Andrew Wynter MSc, CPP, PSP, PFSO. Compliance and Investigations Manager GIA Grace Kennedy

Setting the context:Setting the context:

Big Jamaican drug find overseas - Canadians seize C$19m in contraband among shipment of pumpkins

Canadian police have seized more than 626 kilograms of

hashish, hash oil and ganja stashed under a shipment of Jamaican produce including pumpkins, yams and sweet potatoes.

The drugs, with an estimated street value of C$19 million (J$1,086,800,000) were discovered on July 22 wrapped in plastic and hidden under a false floor in a container shipped to Halifax, Nova Scotia, on the Atlantic Coast.

FSMA and Supply chain FSMA and Supply chain Security Security

SEC. 103. HAZARD ANALYSIS AND RISK-BASED PREVENTIVE CONTROLS REQUIRES THAT

The owner, operator, or agent in charge of a facility shall, in accordance with this section, evaluate the hazards that could affect food manufactured, processed, packed, or held by such facility, Identify and implement preventive controls to significantly minimize or prevent the occurrence of such hazards and provide assurances ….. monitor the performance of those controls, and maintain records of this monitoring as a matter of routine practice.

Components of a Supply Components of a Supply chainchainPrimary & Secondary sourceTransportationProduction or processing facility Warehouse / storage facilityDistribution centerIT / communication Wholesale or retail facilityCustomer/ consumer

Example of a Modern Example of a Modern Supply Chain Supply Chain

Hazards that can affect Hazards that can affect the Supply chainthe Supply chainPiracy Narcotic/ weapon smugglingRegulationsCounterfeiting products Diversion/ hijacking Organized crime Natural / manmade disastersContamination

◦Biological◦Chemical ◦Physical

Hazards that can affect Hazards that can affect the Supply chain cont’dthe Supply chain cont’dPilferage Fraud Labor unrest Weather SabotageInadequate Security People (Employee, suppliers,

customers)

Supply chain vulnerability. Supply chain vulnerability. Any point along the chain

◦Transportation◦Warehouses, ◦DCs, storage yards, ◦Manufacturing◦packaging facility ( Cargo at rest is cargo at risk)

Anyone who has access to your products

Organized crime networks ◦domestic ◦ international

AddressingAddressing hazards hazards affecting the supply chain affecting the supply chain Identify – Threats , hazards,

Assess – Threats, hazards (Risk assessment )

Develop – Plans, procedures, and program to mitigate threats, hazards.

Implement – program

Monitor and review – program, processes, procedures

Implement corrective action program

ELEMENTS OF ELEMENTS OF SUPPLY CHAIN SUPPLY CHAIN SECURITY DETAILSSECURITY DETAILS

FSMA and Supply chain Security

Supply chain security Supply chain security (People)(People)

Detailed background checks

Awareness trainingPre-employment / recruiting screening

Psychometric testing for honesty Detailed background checksDrug testing

Well designed and relevant policies and proceduresWhistle blowing or reporting program Well conducted Investigations Creation a culture of honest or risk intelligent culture

Supply chain Physical Supply chain Physical Security Security 1. Construction of the facility2. Access control 3. CCTV4. Intrusion detection5. Perimeter equipment (Fencing,

Walls etc)6. Guarding operations 7. Key control8. Screening policies and procedures9. Lighting

Supply chain conveyance Supply chain conveyance Registered or approved haulage

contractorsRegistered and approved air and sea

carriersUse seals that meet international

specificationProper custody and documentation

Seals should be distributed in sequential order Seals should be properly secured Audit seals regularly Shipper should sign as an indication that they are in

possession of seal(s) Keep proper records of seals issued and received Damaged or unused seals should properly

destroyed Inspect seals before and after installation

What regulators are looking for in What regulators are looking for in the program the program Regular auditing and reviewing of

processes Compliance reports Security assessmentsSelf assessments reports Corrective action plans reports Properly organized and maintained

recordsChange management processUp to date certifications

What regulators are What regulators are looking for in the looking for in the program program Risk assessment Training and awareness ( staff &

suppliers)Well developed security program External audits, and reviewsIT SecurityProperly documented procedures

and processes

Benefits of good Benefits of good qualityquality supply supply chain security programchain security program

Protects your brand revenue and reputation

Reduces cost Improves efficiency of process Builds confidence with your customersBuilds confidence with your suppliersBuild confidence with the regulatorsDeters criminal activity Opens opportunity in new markets

Summary of a high quality Summary of a high quality Supply chain security Supply chain security programprogramWell develop security planPlan is owned and driven by

management Staff are trained on the supply chain

security plan Contracts have a clauses to address risk Robust IT system with security protocols Good relationships with law enforcement

and security professionals Facility for employees and/or third parties

to make reports Reported incidents are fully investigated Monitoring and reviewed regularly.

Internationally recognized standards and programs that support supply chain security

BASC, CTPAT, ISO 28000 – Supply chain ISO17712 – ( Mechanical )Freight Seals ISO 31000- Risk Management ISO22000 FSSC/ HACCCP ISPS Maritime Security Codes

Little things that make a big Little things that make a big differencedifferenceFit and proper persons or companies No cleaning of containers or packages No inspection of containers Errors and mistakes on documentationWeak security controls and practicesOut of date certificationsPoor record keeping Poor employment practices

Supply chain Security Supply chain Security

QUESTIONS

Minefield or opportunity depends on how you manage your program