For Internal Use Only

FOOD DEFENSE PLAN

Brij Honey Pvt. Ltd.
Village Tehara Lodha NH-11
Bharatpur Rajastahn, 321001 India
Phone: +91-9828523654 Fax: NA Other: NA

Facility Identification #s: FSSAI license number: 10015013000916, IEC number: 1305035062, Udyog aadhar number: MSMER-1
-06B0001150

Facility Descr: Brij Honey Pvt. Ltd. involved in production and processing of Honey with latest equipment such as
decrystallizer, Flash Heater, Pasteurizer, De-Humidifiers and Homogenizer

Employee Type Descr: Total 20 employees working in one shift and all are permanent worker.

Product & Processes: Processing of Honey. Key process involved are Receiving Honey-->Sampling and Lab. Analysis-->De-
Crystallization-->Filtration--> Flash Heating-->De-Humidification-->Homogenization--> Settling and
Filtration--> Packing and Filling--> Storage and Dispatch

FOOD DEFENSE TEAM

Name Title Phone Primary Contact
Mr. Vinit Singh Director +91-9828523654 Yes
Mr. Ikaramuddin FSTL +91-9828523655 Yes
Mr. Mohammad Imran Maintenace Head +91-9828523656 Yes
Mr. Nitin Kumar MR +91-9828523657 Yes
Mr. Sunil Gupta Purchase Incharge +91-9828523658 Yes
Mr. Gaurav Sharma Quality Executive +91-9828523659 Yes
Mr. Yogesh Tomar Quality Incharge +91-9828523660 Yes
Mr. Santosh Kumar Store Incharge +91-9828523661 Yes
Mr. Abhay Foujdar Marketting Head +91-9828523662 Yes

BROAD MITIGATION STRATEGIES

Section Measure Response Plan Content Comments Action Steps
Outside Security
1. Property Perimeter 1a. Is the property perimeter Currently Yes. Security Guard and
secured to prevent entry by Doing Wall provided.
unauthorized persons (e.g., by
security guards, fence, wall, or
other physical barriers)?
1b. Is there adequate lighting Currently Yes. Proper lightening
around the property perimeter? Doing facility is there.
2. Building Perimeter 2a. Is there adequate lighting Currently Yes. adequate lightening
outside each building and in Doing outside each building and
between buildings? in between building is
there.
2b. Are primary entrances to the Currently Yes
buildings and operating areas Doing
monitored and secured?
2c. Are emergency exit doors self- Gap We plan to make an emergency doors No Yes
locking from the outside, with self-locking from outside, with alarms
alarms that activate when the that activate when the doors are
doors are opened? opened
 For Internal Use Only
Section Measure Response Plan Content Comments Action Steps
Outside Security
2. Building Perimeter 2d. Are operational entrances, such Currently Yes
as the loading dock doors, secured Doing
when not in use?
2e. Are all possible access points Currently Yes
into the buildings covered, locked, Doing
or otherwise secured?
2f. Are products and ingredients Currently Yes
that are stored outside the secured Doing
building protected by fences,
tamper-evident seals, and/or locks?

3. Vehicles 3a. Does the property have a Currently Yes

controlled or guarded entrance for Doing
vehicles?
3b. Are all vehicles entering the Currently Yes
property identified by decals or Doing
other form of company-issued
visual identification? This may
include forms of permanent
identification for employee
vehicles, and temporary
identification for vehicles belonging
to visitors, contract workers,
suppliers, and customers.
3c. Where practical, is there some Currently Yes
distance (i.e., a buffer zone) Doing
between parking areas and
entrances to food storage or food
processing areas or utilities?
General Inside Security
4. Facility/Plant 4a. Is there adequate lighting Currently Yes
throughout the facility? Doing
4b. Is there an emergency lighting Currently Yes. Desiel Generator is
system in the facility? Doing there.
4c. Does your facility have Currently Yes
monitored and recorded security Doing
cameras such as a closed circuit
television (CCTV) system?
4d. Does your facility have Currently Yes
established emergency procedures, Doing
including procedures for
responding to an intentional
contamination?
4e. Does your facility have an Gap We paln for same to implement in Currently not provided. Yes
emergency alert system that is system
tested regularly?
4f. Is access to production, storage Currently Yes
and other sensitive areas restricted Doing
to a small number of employees?
4g. Is there a procedure in place for Currently Yes
individuals who normally do not Doing
have access but have a legitimate
need to gain temporary access to
the restricted areas? This would
include all visitors, contractors,
salespeople, and employees.
4h. Are copies of the facility͛s site Currently Yes
plan and blueprints stored in a Doing
secured location at the facility and
in an offsite location?
4i. Are procedures in place to check Currently Yes
maintenance closets, personal Doing
lockers, and storage areas for
suspicious items or packages?
 For Internal Use Only
Section Measure Response Plan Content Comments Action Steps
General Inside Security
4. Facility/Plant 4j. Do you regularly take inventory Currently Yes
of keys to secured/sensitive areas Doing
of the facility?
5. Utilities 5a. Are controls for the Heating, Currently Yes
Ventilation, and Air Conditioning Doing
(HVAC) systems secured by a lock
to prevent access by unauthorized
persons?
5b. Are controls for refrigeration, N/A
including the main storage areas
for combustible materials like
ammonia, secured by lock to
prevent access by unauthorized
persons?
5c. Are the water systems used in Currently Yes
the food production process, Doing
including any storage tanks or
reservoirs and any water treatment
components, protected from
unauthorized access?
5d. Are the controls to the Currently Yes
electrical systems (main Doing
transformers and switchgear only)
protected from unauthorized
access?
5e. Are cleaning/sanitization Currently Yes
chemical dispensing systems Doing
secured from unauthorized access?
6. Laboratory 6a. Is access to the laboratory Currently Yes
facility restricted to authorized Doing
employees (e.g., by locked door,
pass card, etc.)?
6b. Is a procedure in place to Currently Yes
receive and securely store Doing
reagents?
6c. Are laboratory materials Currently Yes
restricted to the laboratory, except Doing
as needed for sampling or other
authorized activities?
6d. Is a procedure in place to Currently Yes
control and dispose of reagents? Doing
7. Process Computer 7a. Is access to these process Currently Yes
Systems control systems restricted to Doing
trusted employees?
7b. Is access to process control Currently Yes
computer systems password Doing
protected?
7c. Are firewalls built into the Currently Yes
computer network used for process Doing
controls?
7d. Is antivirus software installed Currently Yes
on the process controls computer Doing
system and is it frequently
updated?
7e. When an employee͛s Currently Yes
employment ends, is their access to Doing
process control computer systems
disabled?
 For Internal Use Only
Section Measure Response Plan Content Comments Action Steps
Logistics and Storage
Security
8. Suppliers and Vendors 8a. When choosing suppliers for Gap We paln to do same in our premises No Yes
your packaging materials, labels,
ingredients, and raw materials, do
you consider whether they have
developed a Food Defense Plan?
8b. Do you have a supplier approval Currently Yes
certification system in place to Doing
ensure that you purchase supplies
only from known, reputable
sources?
8c. Do you audit or inspect supplier Currently Yes
food defense programs or require Doing
that they have third party audits or
inspections?
9. Incoming Shipments 9a. Are trailers and trucks on the Currently Yes
premises maintained under lock Doing
and/or tamper-evident seal when
not being loaded or unloaded?
9b. Is there close supervision of the Currently Yes
unloading of vehicles transporting Doing
raw materials, finished products,
ingredients or other materials used
in food processing?
9c. Are there procedures that Currently Yes
require the acceptance of Doing
authorized, expected shipments
only?
9d. Is access to loading docks Currently Yes
controlled to avoid unverified or Doing
unauthorized deliveries?
9e. Are incoming shipments of raw Currently Yes
materials, ingredients, and Doing
packaging materials required to be
sealed with tamper-evident or
numbered seals (and documented
in the shipping documents)?
9f. Are tamper-evident seals Currently Yes
verified prior to acceptance? Doing
9g. Are less-than-truckload (LTL) or Currently Yes
partial load shipments vehicles Doing
checked?
10. Outgoing Shipments 10a. Are shipping vehicles (trucks, Currently Yes
tankers, rail cars) inspected prior to Doing
loading to detect the presence of
any foreign/hazardous materials?
10b. Are outgoing shipments Currently Yes
enclosed and sealed with tamper- Doing
evident seals (or locks)? Are the
seal numbers on outgoing
shipments documented on the
shipping documents?
10c. Are chain-of-custody Currently Yes
(possession) records maintained for Doing
all shipments of finished goods?
10d. Are effective product recall Currently Yes
procedures in place? Doing
11. Live Animals 11a. If you receive live animals, is N/A
there a procedure for immediately
notifying the appropriate
individuals when animals with
unusual behavior and/or symptoms
are received?
 For Internal Use Only
Section Measure Response Plan Content Comments Action Steps
Logistics and Storage
Security
11. Live Animals 11b. Are the feed and drinking N/A
water supplies for live animals
protected from possible intentional
contamination?
11c. When transportation N/A
companies are selected, is the
company͛s ability to safeguard the
security of live animals during
shipping considered?
12. Returned 12a. Are all returned Currently Yes
Products/Goods products/goods examined at a Doing
separate designated location in the
facility for evidence of possible
tampering before salvage or use in
rework/reconditioning?
12b. Are records maintained of Currently Yes
returned products/goods used in Doing
rework?
13. 13a. Is access to the piping systems Currently Yes
Ice/Water/Processing used to transfer potable water, oil, Doing
Aids or other ingredients limited?
13b. Are the piping systems used to Currently Yes
transfer potable water, oil, or other Doing
ingredients inspected periodically?
13c. Is access to water wells Currently Yes
restricted (e.g., by locked Doing
door/gate or limiting access to
designated employees)?
13d. Are there water storage tanks, Currently Yes
reservoirs, or water treatment Doing
systems? Is access to them
restricted?
13e. Is access to ice-making N/A
equipment and ice storage areas
restricted?
13f. If a public water supply is used, Currently Yes
have arrangements been made Doing
with local health officials to ensure
they immediately notify the plant if
the safety of the public water
supply is compromised?
14. Storage/Warehouse 14a. Is access to raw material and Currently Yes
ingredient storage areas restricted Doing
to designated employees (e.g., by
locked door or gate)?
14b. Is an access record maintained Currently
to indicate who has entered raw Doing
material or ingredient storage
areas?
14c. Is access to finished product Currently Yes
storage areas restricted to Doing
designated employees?
14d. Is access to any additional or N/A
temporary storage facilities, such as
leased warehousing, shipping
containers, storage sheds, or
vehicles/trailers, restricted?
14e. Do you conduct random Currently Yes
security inspections of all storage Doing
facilities (including temporary
storage facilities)?
 For Internal Use Only
Section Measure Response Plan Content Comments Action Steps
Logistics and Storage
Security
14. Storage/Warehouse 14f. Are product labels and Currently Yes
packaging held in a controlled Doing
manner to prevent theft and
misuse (e.g., counterfeiting)?
14g. Is finished product inventory Currently Yes
regularly checked for accuracy? Doing
15. Hazardous 15a. Are storage areas that contain Currently Yes
materials/chemicals hazardous Doing
materials/chemicalsʹʹsuch as
pesticides, industrial chemicals,
cleaning materials, sanitizers, and
disinfectantsʹʹrestricted to allow
access by authorized personnel
only?
15b. Is a regular inventory of Currently Yes
hazardous materials/chemicals Doing
maintained?
Management
16. Personnel Security 16a. Are basic background checks Currently Yes
and/or reference checks with Doing
previous employers conducted for
all new employees?
16b. Are more comprehensive Currently Yes
background checks conducted on Doing
employees who will be working in
sensitive operations?
16c. Are background checks and/or Currently Yes
reference checks conducted on all Doing
contractors (both permanent and
seasonal) who will be working in
sensitive operations?
16d. Do all employees receive Gap We paln to implement same as earliest Currently Food Defense Yes
training on security procedures and as and include in training material. Awareness Training not
food defense awareness as part of conducted
their orientation training?
16e. Are employees, visitors, and Currently Yes
contractors (including construction Doing
workers, cleaning crews, and truck
drivers) identified in some manner
at all times while on the premises?
16f. Do you control employee and Currently Yes
contractor access into the facility Doing
during working hours (e.g., coded
doors, receptionist on duty, swipe
card, etc.)?
16g. Does your facility control the Currently Yes
entry of employees and contractors Doing
into the facility during non-working
hours?
16h. Does your facility have a way Currently Yes
to limit temporary employees and Doing
contractors (including construction
workers, cleaning crews, and truck
drivers) to areas of the facility
relevant to their work?
16i. Is there a way to identify Gap We will plan to implement same with Currently we do not do Yes
employees that correlates with colour code or id number same activity to idetify.
their specific
functions/assignments/
departments (e.g., corresponding
colored uniforms)?
 For Internal Use Only
Section Measure Response Plan Content Comments Action Steps
Management
16. Personnel Security 16j. Does management maintain an Currently Yes
updated shift roster (i.e., who is Doing
absent, who the replacements are,
and when new employees are
being integrated into the
workforce) for each shift?
16k. Does your facility restrict Currently Yes
personal items and food within Doing
production areas?
16l. Is there a policy in place that Currently Yes
prohibits employees from removing Doing
company-provided clothing and
protective gear from the premises?
17. Food Defense Plan 17a. Is there a designated person or Gap We will implement same and designate Desiganated person or Yes
team to implement, manage, and sigle one responsible person regarding Team not appointed yet.
update the Food Defense Plan? Food Defense Plan
17b. Have supervisors, Gap We plan to do same with an external No Yes
management, and key personnel expert.
received additional food defense
training geared towards
management?
17c. Do you conduct regular food Gap We take advise from few experts. No Yes
defense exercises to test the
effectiveness of your Food Defense
Plan?
17d. Is the Food Defense Plan Gap We will consider it same from next one No as we implement same Yes
reviewed (and revised if necessary) years from upcoming months.
periodically?
17e. Are the details of food defense Gap We paln to make plan and procedure Food Defense Plan and Yes
procedures within the Food same with few expert advise. Procedure not made yet.
Defense Plan kept secure or It is continual process.
confidential?
17f. Is the emergency contact Gap Under process Under process Yes
information for local, state, and
federal government regulatory
authorities and public health
officials included in the Food
Defense Plan?
17g. Are procedures for responding Gap Under process Under process Yes
to threats and actual incidents of
product contamination detailed in
the Food Defense Plan?
17h. Does the Food Defense Plan Gap Under process Under process Yes
have procedures to ensure that
contaminated or potentially
harmful products are held at the
facility?
17i. Does the Food Defense Plan Gap Under process Under process Yes
have procedures for safe handling
and disposal of contaminated
products and decontamination of
the facility in accordance with local
environmental guidelines and
regulations?
17j. Are employees encouraged to Currently Yes
report signs of possible product Doing
contamination, unknown or
suspicious persons in the facility, or
breaks in the food defense system?
17k. Does your facility have Currently Yes
evacuation procedures in case of an Doing
emergency that include controlling
access to the facility during
evacuation?
 For Internal Use Only
VULNERABILITY ASSESSMENT
Process # Process Step Total A V Mitigation Suggestions
Name Score Score Score

* Receiving 1 During receiving raw 18 10 8 Accompany unauthorized persons

(e.g., visitors, contractors,
Raw Honey honey it can be
personnel) to restricted areas
intentionally Conduct periodic checks of both
contaminated with vehicle and products during
chemicals and transportation and prior to
pesticidal residue loading/unloading for suspect
items (e.g., security measures not
present or intact; product and
packaging integrity compromised;
abandoned, removed, or returned
items; lacks proper identification;
lacks proper documentation)
Conduct periodic checks of
packaging integrity (e.g., upon
receipt and prior to use) including
for packaged products,
ingredients, and equipment
components
Conduct random checks of visitors
and personnel (e.g., for proper
identification, for proper
authorization to access the
location or operation)
Refuse delivery of suspect items
(e.g., security measure not
present or intact; product or
packaging integrity compromised;
schedule/protocol not followed;
improper documentation or
identification)
Restrict operations to authorized
personnel
Schedule deliveries (e.g., schedule
departure/arrival time, driver
identity, confirm on-time delivery,
report schedule deviation)
Test for agents of concern using
standard industry testing
protocols (e.g., Fourier Transform
Infrared Spectroscopy, Near
Infrared Spectroscopy, Gas
Chromatography/Mass
Spectrometry)
Use GPS/RFID (Radio Frequency
Identification) or similar security
measures to monitor transport
Use mobile surveillance
equipment to monitor transport
(e.g., broad-band equipped or
mobile surveillance equipment,
communications)
Use personnel (e.g., guards,
supervisors, trusted employees)
for visual observation at restricted
locations and operations
Use secure packaging (e.g., self-
voiding tape, shrink wrapped
pallets, tamper-evident
packaging)
Use surveillance equipment to
monitor locations and operations
Use tamper-evident devices (e.g.,
seals, covers, locks) to secure
packaging and storage containers
 For Internal Use Only
Process # Process Step Total A V Mitigation Suggestions
Name Score Score Score

* Incoming 1 During incoming 18 10 8 Conduct periodic checks of both

vehicle and products during
Transportati transportation from
transportation and prior to
on beekeeper to plant loading/unloading for suspect
if not sealed items (e.g., security measures not
properly it may present or intact; product and
intentionally packaging integrity compromised;
abandoned, removed, or returned
adulterated with items; lacks proper identification;
water or some lacks proper documentation)
physical agent Keep one operator with
transportation at all times (e.g.,
use relay operators, relief driver,
peer-monitoring)
Require driver check-ins
Restrict access of drivers to
specified locations
Restrict access to ingredients,
products, and cargo to authorized
personnel
Restrict access to openings or
access points (e.g., to bins, tanks,
vats, ports/valves, conveyor belt,
inspection points, system
openings) to authorized personnel

Schedule deliveries (e.g., schedule

departure/arrival time, driver
identity, confirm on-time delivery,
report schedule deviation)
Use GPS/RFID (Radio Frequency
Identification) or similar security
measures to monitor transport
Use locks to secure location,
equipment, and controls when
not in use or unattended (e.g., use
tamper-proof containers, locks,
gear locks, remove keys)
Use mobile surveillance
equipment to monitor transport
(e.g., broad-band equipped or
mobile surveillance equipment,
communications)
Use one-way valves to restrict
access to product
Use tamper-evident devices (e.g.,
seals, covers, locks) to secure
transport operations
* De- 1 This is CCP and if 10 6 4
Crystallizati temperature not
on acheived then
biological
comtamination may
take place.
* De- 1 In tis step moisture 6 4 2
Humidificati reduces to an
on acceptable level and
if same not
controlled then
biological
contamination may
take place.
 For Internal Use Only
Process # Process Step Total A V Mitigation Suggestions
Name Score Score Score

* Filtration 1 In this step if 14 6 8

fiteration chamber
not proprly cleaned
and matenance then
biological and
physical
contamination may
take place.
Intentional chemical
and physical
contamination also
take place if
unautorized peson
access tis poin.
* Homogeniza 1 if homogenisation 8 4 4
tion not take place
proper in
homogenization
take and if access
goes to
unauthorized
person then
chemical
contamination may
take place.
 For Internal Use Only
Process # Process Step Total A V Mitigation Suggestions
Name Score Score Score

* Filling, 2 if proper filling not 10 4 6 Clean / sanitize equipment and

components periodically (e.g.,
Packing and done in Food Grade
immediately prior to use, after
Sealing Material then maintenance, when security
Chemical devices are breached, following a
contamination may suspect event)
take place. Also if Conduct periodic checks of
equipment and components for
unauthorized suspect items and events (e.g.,
person will pack and security measures not present or
seal same then intact; packaging integrity
intentional compromised; abandoned,
removed, or returned items; lacks
contamination may proper documentation)
take place. Conduct periodic checks of
packaging integrity (e.g., upon
receipt and prior to use) including
for packaged products,
ingredients, and equipment
components
Conduct random checks of visitors
and personnel (e.g., for proper
identification, for proper
authorization to access the
location or operation)
Recognize and report suspect
items and/or events (e.g., security
measure not present or intact,
product or packaging integrity
compromised, abandoned items,
documentation or identification
not displayed or incorrect,
unauthorized individuals, protocol
not followed, suspect behavior)
Restrict access to ingredients and
products to authorized personnel
Restrict access to openings or
access points (e.g., to bins, tanks,
vats, ports/valves, conveyor belt,
inspection points, system
openings) to authorized personnel

Store ingredients and products in

a secured location
Store potential contaminants
(e.g., waste, chemicals, pesticides,
cleaning supplies, laboratory
cultures) in separate and secured
location immediately upon receipt
and after use
 For Internal Use Only
Process # Process Step Total A V Mitigation Suggestions
Name Score Score Score

* Outgoing 1 if container not 18 10 8 Keep one operator with

transportation at all times (e.g.,
Transportati sealed properly and
use relay operators, relief driver,
on tempered then may peer-monitoring)
cause intentional Restrict access of drivers to
physical and specified locations
chemical Restrict access to transport
operations to authorized
contaminatiom. by personnel
unauthorized Use GPS/RFID (Radio Frequency
person Identification) or similar security
measures to monitor transport
Use locks to secure location,
equipment, and controls when
not in use or unattended (e.g., use
tamper-proof containers, locks,
gear locks, remove keys)
Use mobile surveillance
equipment to monitor transport
(e.g., broad-band equipped or
mobile surveillance equipment,
communications)
Use one-way valves to restrict
access to product
A - Accessibility V - Vulnerability
* Process step(s) in bold have been identified as actionable process step(s).

EMERGENCY CONTACTS
Emergency Phone List
Resource Phone
Local Emergency 911
Local Police Department 100
Local Fire Department 101
Local FBI
Local Public Health Department 102
Poison Control
County Law Enforcement Agency
State Law Enforcement Agency
State Department of Health
FBI Headquarters 24 Hour Hotline (202) 324-3000
FDA Non-Emergency Phone # Use this link
[http://www.fda.gov/Safety/ReportaProblem/ConsumerComplaintCoo
rdinators/default.htm] to find the FDA consumer complaint
coordinator # in your area.
FDA 24 Hour Emergency Phone # 1-866-300-4374 or 301-796-8240
FDA District Office Use this link [
http://www.fda.gov/ICECI/Inspections/IOM/ucm124008.htm] to find
an FDA District Office in your area.

Company Emergency Contacts

Name Title Phone
Brij Honey Pvt. Ltd. Mr. Vinit Singh +91-9828523654
 For Internal Use Only
Supplier Contacts
Company Name Phone Number(s) Contact Person(s)
Customer Contacts
Company Name Phone Number(s) Contact Person(s)
Contractor Contacts
Company Name Phone Number(s) Contact Person(s)
Other Contacts
Company Name Phone Number(s) Contact Person(s)

ACTION PLAN
Measure # or Process Step Action Step Status Responsibility Priority Dates
2c. Are emergency exit doors We take approval from Top Management New Mr. Mohammad High Trgt Cmplt:8/31/2017
self-locking from the outside, and Raise Puruchase Order for same Imran Pln Strt:8/1/2017
with alarms that activate when ( Comments: Same will be completed at Act Strt:8/1/2017
Act Cmplt:8/31/2017
the doors are opened? given time frame )
4e. Does your facility have an Approval and into notice with Top New Mr Mohammad Medium Trgt Cmplt:8/1/2017
emergency alert system that is Mangaement. Imram Pln Strt:8/1/2017
tested regularly? ( Comments: Same will be completed witin Act Strt:8/1/2017
Act Cmplt:8/15/2017
time frame )
8a. When choosing suppliers Acknowledge same to Top Management New Mr. Abhay Faujdar Medium Trgt Cmplt:8/31/2017
for your packaging materials, and take approval for same to implement Pln Strt:8/1/2017
labels, ingredients, and raw as earliest as. Act Strt:8/1/2017
Act Cmplt:8/31/2017
materials, do you consider ( Comments: Same will be completed within
whether they have developed a given time frame. )
Food Defense Plan?
16d. Do all employees receive Take approval and make presentation slide New Mr. Ikaramuddin High Trgt Cmplt:8/31/2017
training on security procedures on same Pln Strt:8/1/2017
and food defense awareness as ( Comments: Same will be completed within Act Strt:8/1/2017
Act Cmplt:8/31/2017
part of their orientation time frame. )
training?
16i. Is there a way to identify We acknowledge same to our director and New Mr. Nitin Kumar Medium Trgt Cmplt:8/31/2017
employees that correlates with take approval to implement same Pln Strt:8/1/2017
their specific ( Comments: Same will be completed within Act Strt:8/1/2017
Act Cmplt:8/31/2017
functions/assignments/ time frame. )
departments (e.g.,
corresponding colored
uniforms)?
17a. Is there a designated We acknlowledge same and came into New Mr. Vinit Singh High Trgt Cmplt:8/31/2017
person or team to implement, notice to our directors and they approve Pln Strt:8/1/2017
manage, and update the Food same to implement in our system. Act Strt:8/1/2017
Act Cmplt:8/31/2017
Defense Plan? ( Comments: Same will be completed within
time frame. )
17b. Have supervisors, Approval made. New Mr. Ikaramuddin Medium Trgt Cmplt:8/31/2017
management, and key ( Comments: Same will be completed within Pln Strt:8/1/2017
personnel received additional given time frame. ) Act Strt:8/1/2017
Act Cmplt:8/31/2017
food defense training geared
towards management?
17c. Do you conduct regular Approval made New Mr. Ikaramuddin Medium Trgt Cmplt:8/31/2017
food defense exercises to test ( Comments: Same will be completed within Pln Strt:8/1/2017
the effectiveness of your Food time frame. ) Act Strt:8/1/2017
Act Cmplt:8/31/2017
Defense Plan?
17d. Is the Food Defense Plan Approval made New Mr. Vinit Singh Medium Trgt Cmplt:8/31/2017
reviewed (and revised if ( Comments: Same will be completed within Pln Strt:8/1/2017
necessary) periodically? time frame. ) Act Strt:8/1/2017
Act Cmplt:8/31/2018
 For Internal Use Only
Measure # or Process Step Action Step Status Responsibility Priority Dates
17e. Are the details of food Approval made New Mr. Piyush Tomar Medium Trgt Cmplt:8/31/2017
defense procedures within the ( Comments: Same will be completed within Pln Strt:8/1/2017
Food Defense Plan kept secure given time frame. ) Act Strt:8/1/2017
Act Cmplt:8/31/2017
or confidential?
17f. Is the emergency contact Approval made New Mr. Piyush Tomar High Trgt Cmplt:8/31/2017
information for local, state, and ( Comments: Completed ) Pln Strt:8/1/2017
federal government regulatory Act Strt:8/1/2017
Act Cmplt:8/1/2017
authorities and public health
officials included in the Food
Defense Plan?
17g. Are procedures for Approval made New Mr. Ikaramuddin High Trgt Cmplt:8/31/2017
responding to threats and ( Comments: Completed ) Pln Strt:8/1/2017
actual incidents of product Act Strt:8/1/2017
Act Cmplt:8/1/2017
contamination detailed in the
Food Defense Plan?
17h. Does the Food Defense Approval made New Mr. Piyush Tomar High Trgt Cmplt:8/31/2017
Plan have procedures to ensure ( Comments: Completed ) Pln Strt:8/1/2017
that contaminated or Act Strt:8/1/2017
Act Cmplt:8/1/2017
potentially harmful products
are held at the facility?
17i. Does the Food Defense Approval made New Mr. Ikaramuddin High Trgt Cmplt:8/31/2017
Plan have procedures for safe ( Comments: Same will be completed within Pln Strt:8/1/2017
handling and disposal of given time frame. ) Act Strt:8/1/2017
Act Cmplt:8/31/2017
contaminated products and
decontamination of the facility
in accordance with local
environmental guidelines and
regulations?
De-Crystallization - 1. This is New Mr. Ikaramuddin High Trgt Cmplt:8/15/2017
CCP and if temperature not All time CCP will be monitored by operator Pln Strt:8/1/2017
acheived then biological and verified and recorded in CCP Act Strt:8/1/2017
Act Cmplt:8/1/2017
comtamination may take place. monitoring log book by FSTL / QA.
( Comments: Completed )
De-Humidification - 1. In tis New Mr. Ikaramuddin High Trgt Cmplt:8/15/2017
step moisture reduces to an All time CCP will be monitored by operator Pln Strt:8/1/2017
acceptable level and if same and verified and recorded in CCP Act Strt:8/1/2017
Act Cmplt:8/1/2017
not controlled then biological monitoring log book by FSTL / QA.
contamination may take place. ( Comments: Completed )
 For Internal Use Only
Measure # or Process Step Action Step Status Responsibility Priority Dates
Filling, Packing and Sealing - 2. Clean / sanitize equipment and New Packing Supervisor High Trgt Cmplt:8/31/2017
if proper filling not done in components periodically (e.g., Pln Strt:8/1/2017
Food Grade Material then immediately prior to use, after Act Strt:8/1/2017
Act Cmplt:8/1/2017
Chemical contamination may maintenance, when security devices are
take place. Also if unauthorized breached, following a suspect event)
person will pack and seal same Conduct periodic checks of equipment and
then intentional contamination components for suspect items and events
may take place. (e.g., security measures not present or
intact; packaging integrity compromised;
abandoned, removed, or returned items;
lacks proper documentation)
Conduct periodic checks of packaging
integrity (e.g., upon receipt and prior to
use) including for packaged products,
ingredients, and equipment components
Conduct random checks of visitors and
personnel (e.g., for proper identification,
for proper authorization to access the
location or operation)
Recognize and report suspect items and/or
events (e.g., security measure not present
or intact, product or packaging integrity
compromised, abandoned items,
documentation or identification not
displayed or incorrect, unauthorized
individuals, protocol not followed, suspect
behavior)
Restrict access to ingredients and products
to authorized personnel
Restrict access to openings or access points
(e.g., to bins, tanks, vats, ports/valves,
conveyor belt, inspection points, system
openings) to authorized personnel
Store ingredients and products in a
secured location
Store potential contaminants (e.g., waste,
chemicals, pesticides, cleaning supplies,
laboratory cultures) in separate and
secured location immediately upon receipt
and after use
( Comments: Will be commenced soon.. )
Filtration - 1. In this step if New Mr. Ikaramuddin High Trgt Cmplt:8/15/2017
fiteration chamber not proprly Filter will be changed after each and every Pln Strt:8/1/2017
cleaned and matenance then lot processing and same will be cleaned Act Strt:8/1/2017
Act Cmplt:8/1/2017
biological and physical and matenance under QC deptt. and same
contamination may take place. will be recorded in separte log book.
Intentional chemical and ( Comments: Completed )
physical contamination also
take place if unautorized peson
access tis poin.
Homogenization - 1. if New Mr. Ikaramuddin High Trgt Cmplt:8/15/2017
homogenisation not take place All time Homogenization will be monitored Pln Strt:8/1/2017
proper in homogenization take by operator and verified and recorded in Act Strt:8/1/2017
Act Cmplt:8/15/2017
and if access goes to separate monitoring log book by Operator
unauthorized person then / QC / QA.
chemical contamination may ( Comments: Completed )
take place.
 For Internal Use Only
Measure # or Process Step Action Step Status Responsibility Priority Dates
Incoming Transportation - 1. Conduct periodic checks of both vehicle New Loading Supervisor Medium Trgt Cmplt:8/31/2017
During incoming transportation and products during transportation and Pln Strt:8/1/2017
from beekeeper to plant if not prior to loading/unloading for suspect Act Strt:8/1/2017
Act Cmplt:8/1/2017
sealed properly it may items (e.g., security measures not present
intentionally adulterated with or intact; product and packaging integrity
water or some physical agent compromised; abandoned, removed, or
returned items; lacks proper identification;
lacks proper documentation)
Keep one operator with transportation at
all times (e.g., use relay operators, relief
driver, peer-monitoring)
Require driver check-ins
Restrict access of drivers to specified
locations
Restrict access to ingredients, products,
and cargo to authorized personnel
Restrict access to openings or access points
(e.g., to bins, tanks, vats, ports/valves,
conveyor belt, inspection points, system
openings) to authorized personnel
Schedule deliveries (e.g., schedule
departure/arrival time, driver identity,
confirm on-time delivery, report schedule
deviation)
Use GPS/RFID (Radio Frequency
Identification) or similar security measures
to monitor transport
Use locks to secure location, equipment,
and controls when not in use or
unattended (e.g., use tamper-proof
containers, locks, gear locks, remove keys)
Use mobile surveillance equipment to
monitor transport (e.g., broad-band
equipped or mobile surveillance
equipment, communications)
Use one-way valves to restrict access to
product
Use tamper-evident devices (e.g., seals,
covers, locks) to secure transport
operations
( Comments: Will be commenced soon... )
Outgoing Transportation - 1. if Keep one operator with transportation at New Unloading High Trgt Cmplt:8/31/2017
container not sealed properly all times (e.g., use relay operators, relief Supervisor Pln Strt:8/1/2017
and tempered then may cause driver, peer-monitoring) Act Strt:8/1/2017
Act Cmplt:8/1/2017
intentional physical and Restrict access of drivers to specified
chemical contaminatiom. by locations
unauthorized person Restrict access to transport operations to
authorized personnel
Use GPS/RFID (Radio Frequency
Identification) or similar security measures
to monitor transport
Use locks to secure location, equipment,
and controls when not in use or
unattended (e.g., use tamper-proof
containers, locks, gear locks, remove keys)
Use mobile surveillance equipment to
monitor transport (e.g., broad-band
equipped or mobile surveillance
equipment, communications)
Use one-way valves to restrict access to
product
( Comments: Will be commenced soon... )
 For Internal Use Only
Measure # or Process Step Action Step Status Responsibility Priority Dates
Receiving Raw Honey - 1. Accompany unauthorized persons (e.g., New Quality Supervisor High Trgt Cmplt:8/31/2017
During receiving raw honey it visitors, contractors, personnel) to and Bee-Keeper Pln Strt:8/1/2017
can be intentionally restricted areas Act Strt:8/1/2017
Act Cmplt:8/1/2017
contaminated with chemicals Conduct periodic checks of both vehicle
and pesticidal residue and products during transportation and
prior to loading/unloading for suspect
items (e.g., security measures not present
or intact; product and packaging integrity
compromised; abandoned, removed, or
returned items; lacks proper identification;
lacks proper documentation)
Conduct periodic checks of packaging
integrity (e.g., upon receipt and prior to
use) including for packaged products,
ingredients, and equipment components
Conduct random checks of visitors and
personnel (e.g., for proper identification,
for proper authorization to access the
location or operation)
Refuse delivery of suspect items (e.g.,
security measure not present or intact;
product or packaging integrity
compromised; schedule/protocol not
followed; improper documentation or
identification)
Restrict operations to authorized
personnel
Schedule deliveries (e.g., schedule
departure/arrival time, driver identity,
confirm on-time delivery, report schedule
deviation)
Test for agents of concern using standard
industry testing protocols (e.g., Fourier
Transform Infrared Spectroscopy, Near
Infrared Spectroscopy, Gas
Chromatography/Mass Spectrometry)
Use GPS/RFID (Radio Frequency
Identification) or similar security measures
to monitor transport
Use mobile surveillance equipment to
monitor transport (e.g., broad-band
equipped or mobile surveillance
equipment, communications)
Use personnel (e.g., guards, supervisors,
trusted employees) for visual observation
at restricted locations and operations
Use secure packaging (e.g., self-voiding
tape, shrink wrapped pallets, tamper-
evident packaging)
Use surveillance equipment to monitor
locations and operations
Use tamper-evident devices (e.g., seals,
covers, locks) to secure packaging and
storage containers
( Comments: Will be commenced soon... )