For Internal Use Only

FOOD DEFENSE PLAN

Jabs International Pvt Ltd
A-350, TTC Industrial Area
MIDC, Mahape, Navi Mumbai, 400710 Indai

Facility Identification #s: FSSAI Registration Number: 10013021000952

Facility Descr: Spice cleaning plant manufactured by Bhulers

Employee Type Descr: 45 Workers, 10 Managers

Product & Processes: Processing, (Cleaning, Sorting, ETO Sterilization) and packing of whole and ground Spices and Oil seeds
in jute, Paper and PP Bags

FOOD DEFENSE TEAM

Name Title Phone Primary Contact
Mr. Gaikwad Quality Incharge
Mr. Gopichand Ghatge Incharge Spice Processing
Umesh Patil QA 8850349608 Yes
Mr. Uday

BROAD MITIGATION STRATEGIES

Section Measure Response Plan Content Comments Action Steps
Outside Security
1. Property Perimeter 1a. Is the property perimeter Currently Boundry Wall from all
secured to prevent entry by Doing sides
unauthorized persons (e.g., by
security guards, fence, wall, or
other physical barriers)?
1b. Is there adequate lighting Currently Facility is provided in
around the property perimeter? Doing premises and street lights
2. Building Perimeter 2a. Is there adequate lighting Currently
outside each building and in Doing
between buildings?
2b. Are primary entrances to the Currently All primary entrances to the buildings
buildings and operating areas Doing and operating areas are secured. All
monitored and secured? doors have properly functioning locks or
alarms that arechecked on a regular
basis.
2c. Are emergency exit doors self- Gap Yes
locking from the outside, with
alarms that activate when the
doors are opened?
2d. Are operational entrances, such Currently The loading dock is regularly monitored
as the loading dock doors, secured Doing and doors are secured when not in use.
when not in use?
2e. Are all possible access points Currently All potential access points into the
into the buildings covered, locked, Doing facility, including windows, roof
or otherwise secured? openings, and ventilation openings are
secured and monitored regularly. All
doors other than the primary entrances
are configured as emergency exits only.

Section Measure
Outside Security
2. Building Perimeter 2f. Are products and ingredients
that are stored outside the secured
building protected by fences,
tamper-evident seals, and/or locks?
3. Vehicles 3a. Does the property have a
controlled or guarded entrance for
vehicles?
3b. Are all vehicles entering the
property identified by decals or
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
distance (i.e., a buffer zone)
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
throughout the facility?
4b. Is there an emergency lighting
system in the facility?
4c. Does your facility have
monitored and recorded security
cameras such as a closed circuit
television (CCTV) system?
4d. Does your facility have
established emergency procedures,
including procedures for
responding to an intentional
contamination?
4e. Does your facility have an
emergency alert system that is
tested regularly?
4f. Is access to production, storage
and other sensitive areas restricted
to a small number of employees?
4g. Is there a procedure in place for
individuals who normally do not
have access but have a legitimate
need to gain temporary access to
the restricted areas? This would
include all visitors, contractors,
salespeople, and employees.
For Internal Use Only
Response Plan Content Comments Action Steps
N/A
Currently The entry of vehicles and people to the
Doing facility property is controlled through a
single access point. Authorization to
enter is confirmed by the use of a key-
card, access code, or display of
identification to a security guard.
Currently Authorized employee and business
Doing vehicles must display a vehicle
identification card provided by the
company. Vehicles without this card
are required to sign in with security and
once approved, they are provided a
visitor entry tag to display in the
windshield.
Currently Vehicle parking areas are separated
Doing from the building by a buffer area.
Currently Lighting throughout the facility is
Doing adequate and maintained.
Currently Emergency lighting is installed at the
Doing facility and is tested regularly.
Currently A CCTV system is in place that records
Doing all major areas of the facility, including
restricted areas Recordings from the
CCTV are reviewed regularly.
Currently The facility has a standard operating
Doing procedure for emergencies, including
potential acts of intentional
contamination. Employees are trained
on the emergency procedures and the
facility conducts testing of the
procedures periodically.
N/A
Currently Restricted areas of the facility are
Doing clearly identified. Access is limited by
lock or alternative controls. Uniform
color is used to distinguish employees
who are allowed access to restricted
areas.
Currently A policy and procedure for granting
Doing temporary access to restricted areas for
visitors or employees is in place.
Individuals who are not normally
authorized to be in restricted areas
require escort by an authorized
employee at all times. Non-employees
may not bring personal items into the
processing areas. A log of visitors
entering the facility is maintained.

Section Measure
General Inside Security
4. Facility/Plant 4h. Are copies of the facility’s site
plan and blueprints stored in a
secured location at the facility and
in an offsite location?
4i. Are procedures in place to check
maintenance closets, personal
lockers, and storage areas for
suspicious items or packages?
4j. Do you regularly take inventory
of keys to secured/sensitive areas
of the facility?
5. Utilities 5a. Are controls for the Heating,
Ventilation, and Air Conditioning
(HVAC) systems secured by a lock
to prevent access by unauthorized
persons?
5b. Are controls for refrigeration,
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
the food production process,
including any storage tanks or
reservoirs and any water treatment
components, protected from
unauthorized access?
5d. Are the controls to the
electrical systems (main
transformers and switchgear only)
protected from unauthorized
access?
5e. Are cleaning/sanitization
chemical dispensing systems
secured from unauthorized access?
6. Laboratory 6a. Is access to the laboratory
facility restricted to authorized
employees (e.g., by locked door,
pass card, etc.)?
6b. Is a procedure in place to
receive and securely store
reagents?
6c. Are laboratory materials
restricted to the laboratory, except
as needed for sampling or other
authorized activities?
For Internal Use Only
Response Plan Content Comments Action Steps
Currently An up-to-date copy of the facility’s site
Doing plan and blueprint is stored in a fire-
safe locked box in the facility manager’s
office. In addition, a copy is located in a
secure location offsite. Access to both
copies is controlled.
Currently Regular inspections of the facility are
Doing required and documented, including all
utility areas, storage areas,
maintenance areas, and production
areas. Employees are trained to report
suspicious activities or unusual
observations.
Currently Security access codes are deactivated
Doing when an employee leaves the company
or when an employee no longer needs
access. Physical keys are issued with
documentation maintained. Inventory
of keys to sensitive areas is taken once
each year.
N/A
N/A
Currently All main water delivery, storage, and
Doing treatment areas are considered
sensitive areas, with access restricted to
authorized individuals.
Currently The main electrical supply and
Doing switchgear are controlled to allow
authorized entry only.
Currently Storage areas and primary distribution
Doing systems for sanitation chemicals are
kept in a locked area that is restricted to
authorized individuals.
Currently The doors to the laboratory are locked.
Doing Access to the laboratory is restricted to
authorized employees. Authorized
employees are issued and required to
wear blue lab coats.
Currently Reagents are received only by
Doing authorized employees. They are stored
in a locked cabinet within the
laboratory. If reagents need to be taken
out of the laboratory, procedures are in
place to track them.
Currently Laboratory materials such as chemicals
Doing and reagents are restricted to the
laboratory. In instances where there is
a need to have laboratory materials
outside of the lab, there is a procedure
in place to get pre-approval from the
laboratory supervisor who then keeps a
record of such instances.
 For Internal Use Only
Section Measure Response Plan Content Comments Action Steps
General Inside Security
6. Laboratory 6d. Is a procedure in place to Currently Reagents are disposed of according to
control and dispose of reagents? Doing the facility’s disposal procedures. The
disposal of reagents is documented.
7. Process Computer 7a. Is access to these process Currently A limited number of authorized
Systems control systems restricted to Doing employees have the password to the
trusted employees? system.
7b. Is access to process control Currently Access to process control computer
computer systems password Doing systems is protected through
protected? passwords.
7c. Are firewalls built into the Currently Access to process control computer
computer network used for process Doing systems is protected through firewalls.
controls?
7d. Is antivirus software installed Currently Process control computer systems are
on the process controls computer Doing protected through antivirus software
system and is it frequently that is updated frequently.
updated?
7e. When an employee’s Currently Disabling an employee’s access to
employment ends, is their access to Doing computer systems is part of the close
process control computer systems out and sign off process for all
disabled? personnel when their employment
ends.
Logistics and Storage
Security
8. Suppliers and Vendors 8a. When choosing suppliers for N/A As the material is
your packaging materials, labels, procured from open
ingredients, and raw materials, do market and agro comodity
you consider whether they have
developed a Food Defense Plan?
8b. Do you have a supplier approval Currently All suppliers must be approved within
certification system in place to Doing our supplier certification program.
ensure that you purchase supplies
only from known, reputable
sources?
8c. Do you audit or inspect supplier N/A Procured from open
food defense programs or require market and known
that they have third party audits or sources
inspections?
9. Incoming Shipments 9a. Are trailers and trucks on the Currently All trucks and trailers with supplies, raw
premises maintained under lock Doing materials, or finished goods must be
and/or tamper-evident seal when sealed until use.
not being loaded or unloaded?
9b. Is there close supervision of the Currently Unloading of vehicles transporting raw
unloading of vehicles transporting Doing materials, finished products, ingredients
raw materials, finished products, or other materials used in food
ingredients or other materials used processing is conducted with close
in food processing? supervision.
9c. Are there procedures that Currently Loading and unloading activities are
require the acceptance of Doing scheduled and/or monitored. Only
authorized, expected shipments scheduled shipments are received.
only? Unscheduled or unauthorized
shipments are held until authorization is
obtained.
9d. Is access to loading docks Currently Loading dock access is controlled by a
controlled to avoid unverified or Doing lock and is monitored regularly. Only
unauthorized deliveries? authorized personnel have the key to
the lock.
9e. Are incoming shipments of raw Currently Incoming shipments are secured with
materials, ingredients, and Doing locks and numbered tamper-evident
packaging materials required to be seals. Procedures require personnel to
sealed with tamper-evident or verify the seal numbers and inspect
numbered seals (and documented documents prior to receipt of the
in the shipping documents)? shipment.

Section Measure
Logistics and Storage
Security
9. Incoming Shipments 9f. Are tamper-evident seals
verified prior to acceptance?
9g. Are less-than-truckload (LTL) or
partial load shipments vehicles
checked?
10. Outgoing Shipments 10a. Are shipping vehicles (trucks,
tankers, rail cars) inspected prior to
loading to detect the presence of
any foreign/hazardous materials?
10b. Are outgoing shipments
enclosed and sealed with tamper-
evident seals (or locks)? Are the
seal numbers on outgoing
shipments documented on the
shipping documents?
10c. Are chain-of-custody
(possession) records maintained for
all shipments of finished goods?
10d. Are effective product recall
procedures in place?
11. Live Animals 11a. If you receive live animals, is
there a procedure for immediately
notifying the appropriate
individuals when animals with
unusual behavior and/or symptoms
are received?
11b. Are the feed and drinking
water supplies for live animals
protected from possible intentional
contamination?
11c. When transportation
companies are selected, is the
company’s ability to safeguard the
security of live animals during
shipping considered?
12. Returned 12a. Are all returned
Products/Goods products/goods examined at a
separate designated location in the
facility for evidence of possible
tampering before salvage or use in
rework/reconditioning?
12b. Are records maintained of
returned products/goods used in
rework?
13. 13a. Is access to the piping systems
Ice/Water/Processing used to transfer potable water, oil,
Aids or other ingredients limited?
For Internal Use Only
Response Plan Content Comments Action Steps
Currently Procedures require personnel to verify
Doing the seal numbers and inspect
documents prior to acceptance of the
shipment.
Currently Upon arrival of the shipment, any less-
Doing than-truckload (LTL) or partial
shipments are verified. Multiple delivery
trucks have to provide documentation
of all seal changes with approval by
authorized signatures. Open trucks are
checked for content and condition.
Currently Outgoing vehicles are examined for
Doing suspicious activity, evaluated for
previous use or presence of potentially
hazardous materials. Inspections of
outgoing shipments are documented.
Currently Outgoing shipments are sealed with
Doing tamper-evident seals. Documentation
of outgoing shipments is required.
Multiple transports seals are
documented and justified.
Currently Shipping documents are required for
Doing each load indicating the proper
inventory, date and time, and the
number of the tamper-evident seal that
was applied to the load.
Currently A documented product recall plan is in
Doing place. It must be reviewed annually.
Trace-back and trace-forward records
are maintained and tested regularly
through mock-recall events. The recall
plan ensures segregation and proper
disposition of recalled product and
documentation of disposition.
N/A Only agro products
processed
N/A
N/A
Currently Where possible, returned goods are
Doing inspected prior to return and disposed
of if not suitable for reuse.
Currently Returned goods are documented, as are
Doing reused or discarded goods. When
returned goods are suitable for reuse,
original lot numbers are recorded and
included in the record of ingredients
used.
Currently Access to lines that transfer water or
Doing ingredients are is restricted.

Section Measure
Logistics and Storage
Security
13. 13b. Are the piping systems used to
Ice/Water/Processing transfer potable water, oil, or other
Aids ingredients inspected periodically?
13c. Is access to water wells
restricted (e.g., by locked
door/gate or limiting access to
designated employees)?
13d. Are there water storage tanks,
reservoirs, or water treatment
systems? Is access to them
restricted?
13e. Is access to ice-making
equipment and ice storage areas
restricted?
13f. If a public water supply is used,
have arrangements been made
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
ingredient storage areas restricted
to designated employees (e.g., by
locked door or gate)?
14b. Is an access record maintained
to indicate who has entered raw
material or ingredient storage
areas?
14c. Is access to finished product
storage areas restricted to
designated employees?
14d. Is access to any additional or
temporary storage facilities, such as
leased warehousing, shipping
containers, storage sheds, or
vehicles/trailers, restricted?
14e. Do you conduct random
security inspections of all storage
facilities (including temporary
storage facilities)?
14f. Are product labels and
packaging held in a controlled
manner to prevent theft and
misuse (e.g., counterfeiting)?
14g. Is finished product inventory
regularly checked for accuracy?
15. Hazardous 15a. Are storage areas that contain
materials/chemicals hazardous materials/chemicals––
such as pesticides, industrial
chemicals, cleaning materials,
sanitizers, and disinfectants––
restricted to allow access by
authorized personnel only?
For Internal Use Only
Response Plan Content Comments Action Steps
Currently Water lines are regularly inspected for
Doing integrity.
Currently Access to water wells is restricted by a
Doing lock. Only authorized personnel can
unlock the well.
Currently Access to potable water storage tanks
Doing and water reuse systems is restricted to
authorized personnel only.
N/A
N/A Bore well water
Currently Access to the storage areas for raw
Doing materials and ingredients is restricted to
authorized personnel.
Currently Employees that enter storage areas are
Doing required to enter their name, date, and
time on a registry that is kept near the
entrance. Only authorized personnel
have access to the storage areas.
Currently Access to finished goods storage areas
Doing is restricted to authorized personnel.
Currently Leased warehouses are required to
Doing have access controls similar to our
facility controls. Any temporary storage
on our facility must be locked and
accessible only by authorized personnel.
Currently Routine and random unscheduled
Doing checks include inspection of all
warehouses and all storage areas,
including temporary storage areas and
storage outside the facility. Records are
required for these regular inspections.
Currently Labels and packaging materials are
Doing controlled to prevent theft and misuse.
Regular inspection and examination of
these materials is conducted.
Currently Periodic inventory and examinations for
Doing tampering of materials in storage are
performed. Previously unattended
materials are checked before use.
Unexpected changes in inventory
(product or equipment) are reported to
appropriate personnel.
Currently Hazardous materials and chemicals,
Doing including pesticides, cleaning chemicals,
and sanitizers, are in a restricted area
and secured by a lock. Only authorized
personnel have access to the restricted
area.

Section Measure
Logistics and Storage
Security
15. Hazardous 15b. Is a regular inventory of
materials/chemicals hazardous materials/chemicals
maintained?
Management
16. Personnel Security 16a. Are basic background checks
and/or reference checks with
previous employers conducted for
all new employees?
16b. Are more comprehensive
background checks conducted on
employees who will be working in
sensitive operations?
16c. Are background checks and/or
reference checks conducted on all
contractors (both permanent and
seasonal) who will be working in
sensitive operations?
16d. Do all employees receive
training on security procedures and
food defense awareness as part of
their orientation training?
16e. Are employees, visitors, and
contractors (including construction
workers, cleaning crews, and truck
drivers) identified in some manner
at all times while on the premises?
16f. Do you control employee and
contractor access into the facility
during working hours (e.g., coded
doors, receptionist on duty, swipe
card, etc.)?
16g. Does your facility control the
entry of employees and contractors
into the facility during non-working
hours?
16h. Does your facility have a way
to limit temporary employees and
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
employees that correlates with
their specific
functions/assignments/
departments (e.g., corresponding
colored uniforms)?
16j. Does management maintain an
updated shift roster (i.e., who is
absent, who the replacements are,
and when new employees are
being integrated into the
workforce) for each shift?
For Internal Use Only
Response Plan Content Comments Action Steps
Currently We require a daily inventory of
Doing hazardous materials and chemicals.
Inventory controls are in place that
require documentation. Any
discrepancies are immediately reported
to management and investigated.
Currently Background or reference checks are
Doing conducted for all new hires. A more
comprehensive background check is
conducted for authorized employees
who work in sensitive areas.
Currently A more comprehensive background and
Doing reference checks are conducted for
employees working in sensitive
operations.
Currently Background and reference checks are
Doing conducted for temporary, seasonal, or
contract workers that will have access
to restricted or sensitive production
areas.
Currently All new employees are trained on food
Doing defense. Refresher awareness training
is required for employees annually.
Employees are trained to report
suspicious activities or unusual
observations.
Currently A procedure to recognize or identify
Doing employees in the facility is in place. It
consists of color-coded badges for
visitors, contractors, cleaning crews and
others.
Currently All employees and contractors are
Doing required to enter through a single
employee entrance. They must also
have valid identification and be verified
before they are allowed into the facility.
This single employee entrance is
supervised during regular working hours
and monitored during off hours.
Currently During non-working hours, access to the
Doing facility is restricted to authorized
personnel. Any employees or
contractors who need access to the
facility must be admitted by the
supervisor on duty.
Currently Contractors, temporary employees, and
Doing non-facility personnel are restricted
only to the specific area they have been
authorized. They must display
temporary badges that list where they
are authorized to be within our facility.
Currently Color-coded smocks are used to identify
Doing different functions. Visitors and
contractors that require an escort are
required to use a specific colored
badges.
Currently Each supervisor is responsible for
Doing maintaining and reporting the
employee roster for each shift. The
roster must identify regular, seasonal,
and temporary employees.

Section Measure
Management
16. Personnel Security 16k. Does your facility restrict
personal items and food within
production areas?
16l. Is there a policy in place that
prohibits employees from removing
company-provided clothing and
protective gear from the premises?
17. Food Defense Plan 17a. Is there a designated person or
team to implement, manage, and
update the Food Defense Plan?
17b. Have supervisors,
management, and key personnel
received additional food defense
training geared towards
management?
17c. Do you conduct regular food
defense exercises to test the
effectiveness of your Food Defense
Plan?
17d. Is the Food Defense Plan
reviewed (and revised if necessary)
periodically?
17e. Are the details of food defense
procedures within the Food
Defense Plan kept secure or
confidential?
17f. Is the emergency contact
information for local, state, and
federal government regulatory
authorities and public health
officials included in the Food
Defense Plan?
17g. Are procedures for responding
to threats and actual incidents of
product contamination detailed in
the Food Defense Plan?
17h. Does the Food Defense Plan
have procedures to ensure that
contaminated or potentially
harmful products are held at the
facility?
For Internal Use Only
Response Plan Content Comments Action Steps
Currently Employees and visitors are restricted as
Doing to what they can bring in or take from
the facility, including personal items,
food, and cameras. Employee lockers
are inspected periodically and at
random.
Currently Locker rooms and laundry services are
Doing available on the facility. Employee
uniforms and protective gear may not
be taken out of the facility.
Currently Leadership of the food defense team is
Doing delegated to the Quality Manager. A
cross-functional team has been formed
to support food defense. The list of
members of the food defense team is
updated at least once a year and when
major changes are made to the team.
Currently In addition to awareness training for all
Doing employees, key employees are trained
on the facility’s food defense plan.
Currently Mock exercises to test the ability of
Doing unauthorized persons to enter the
perimeter, the facility, or sensitive areas
are performed annually. Routine
inspections and annual audits are
performed to confirm that procedures
of the Food Defense Plan are being
followed.
Currently The food defense team is required to
Doing review and update the Food Defense
Plan at least annually. Self-assessments
are conducted annually by the team
Currently The Food Defense Plan is a confidential
Doing document. A summary of the plan and
a summary of results of audits may be
shared. Detailed elements and
vulnerabilities will not be shared.
Currently Facility personnel contact information is
Doing kept up to date and reviewed/updated
annually. Emergency contact lists are
kept up to date and are located in
conspicuous areas––near phones, break
rooms, locker areas, etc.
Currently The food defense team has established
Doing procedures for responding to threats as
well as actual product contamination
events. They have pre-established
communication with local, state, and
federal incident response personnel for
a more efficient response.
Currently Established quality “HOLD” procedures
Doing will be used to mark and segregate
products where an intentional
contamination is known or suspected.
In addition, the products will be
physically isolated, locked where
possible, to support potential criminal
investigations.

Section Measure
Management
17. Food Defense Plan 17i. Does the Food Defense Plan
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
report signs of possible product
contamination, unknown or
suspicious persons in the facility, or
breaks in the food defense system?
17k. Does your facility have
evacuation procedures in case of an
emergency that include controlling
access to the facility during
evacuation?
For Internal Use Only
Response Plan Content Comments Action Steps
Currently Potentially hazardous waste (biological
Doing or chemical) is controlled and disposed
of properly. Disposal and
decontamination procedures are
included as part of the food safety plan
and are attached as a supporting
document to this Food Defense Plan.
Contact information for the local
environmental agency is in the
emergency contact section of the Food
Defense Plan.
Currently Employees receive annual training on
Doing FDA’s FIRST and ALERT food defense
awareness and are encouraged to
report unusual activities.
Currently Established facility evacuation
Doing procedures are required to address the
physical security of the facility and
entrances during an evacuation. Only
properly identified emergency
responders will be allowed access to the
facility during an evacuation.

VULNERABILITY ASSESSMENT
Process # Process Step Total A V Mitigation Suggestions
Name Score Score Score

Security 1 Receiving of Goods 6 2 4

Receiving 1 Incoming Inspection 4 2 2
the RM/PM
Receiving 2 Uloading 6 4 2
the RM/PM
Storage of 1 Storage and Issue 6 4 2
RM/PM
Processing 3 Sortex 6 2 4
Processing 4 Packing 8 4 4
Processing 5 ETO 8 4 4
Processing 6 Storage 8 4 4
Processing 7 Cleaning of Spices 8 4 4
FG Storage 1 Storage of finished 8 4 4
and goods
DIspatch
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 Police Department 101
Local Emergency 9-1-1

Company Emergency Contacts

 For Internal Use Only
Name Title Phone
Bhaskarbhai Managing Director 9820073814

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 Emergency exits are installed with self- Planning Jagdish Bhai Low Trgt Cmplt:2/20/2019
self-locking from the outside, locking doors and alarms that will sound Pln Strt:12/2/2018
with alarms that activate when when emergency exit doors are opened Act Strt:2/15/2019
Act Cmplt:2/20/2019
the doors are opened? will be provided