Strategy for Food Defense Plan

 

Introduction

Food defense is an intentional effort to protect food from the act of intentional adulteration. Have you heard of

• terrorist attack
• a dissatisfied employee seeking revenge on the company
• competitor trying to taint your product to damage your reputation etc.

To prevent the situation above, food defense act as a system/ tools that

1. Identify possible route of intentional adulteration at the plant
2. Prevent the act of intentional adulteration through the use of mitigation strategies
3. Check if the food defense program works

How to Develop a Food Defense Plan?

Fundamental for Food Defense Plan

There are few core elements for a Food Defense Plan. This includes:

1. Vulnerability Assessment
2. Mitigation Strategies
3. Monitoring and corrective actions
4. Verifications (Mock Food Defense)
5. Reanalysis (Reevaluation of the Food Defense Plan)

First step: Food Defense Team

Before we move on to build a food defense plan, we need a food defense team that can help us identify the vulnerable critical points at the plant considering all operational hours and activities at the plant. It is best completed using inter-department representative participation, to ensure we gain employee’s buy-in when implementing the food defense plan.

Second step: Vulnerability Assessment

Vulnerability Assessment is about assessing where and when the intentional adulteration could occur as well as who can be involve in the activities. While we will not be discussing the vulnerability assessment in detail today, here are few key activities that may be access point for intentional adulteration

• Shipping and Receiving
• Visitor and contractors identity
• Plant security (Door and key access)
• Employees (Previous history or upset employee)
• Process Flow (where are the most vulnerable location) extension.psu.edu
  • Bulk liquid receiving and loading
• Liquid storage and handling
• Secondary ingredient handling
• Mixing and blending activities
• Quiet time at the food storage location that may turn into intentional adulteration opportunities etc.

Third Step: Determine and Implement Mitigation Strategies

Once we have completed the vulnerabilities assessment, it is time to put and implement mitigation strategies to ensure we are monitoring or reduce the opportunities for intentional adulterations. Common mitigation strategies include:

• Verification of visitor and contractor identity
• Tamper evidence for receiving and shipping
• Employee background check
• Employee training to identify and report suspicious activities

Maintaining Food Defense Plan

Maintaining Food Defense Plan

Remember that all implemented plan needs to be regularly monitored and verified for effectiveness. In the event of food defense, it might be monitoring these activities

• Identity verification for visitors, contractors and new hires
• Visitor’s policy compliance
• Contractors following visitor policy
• Door and key card access
• Employee reporting intruder or suspicious activities

All employees must be trained to identify and report suspicious activities to their supervisor.

Annually, the food defense plan shall also be challenged with the identified key activities to ensure the mitigation strategies are working.

In addition, the food defense shall also be revised

• At least 3 years to ensure that the program is current
• Whenever there are changes to the key activities or policies that may impact the food defense plan
• As part of preventative actions to mitigate a breach to the site security

Conclusion

Food Defense plans can be a challenging task to manage especially if the food defense plan is developed and agreed upon by the QA department only.

Be sure to include a representative from the Human Resources, Maintenance and Warehouse department to ensure that they are always aware of their department activities and can be the advocate for maintaining the integrity of the food defense plan.

Training is also fundamental to ensure all employees are aware of the requirements and procedures to protect the food products and facility from intentional adulteration activities.

Resources

The Food Defense Plan Builder | FDA provides customizable tools to help food company build their food defense plan.

P/s: If you are seeking to be a Food Defense Qualified Individual, the blog article FSMA Friday – May 2019: IA Rule Summary and Options for Writing a Food Defense Plan (safetychain.com) indicated the following free and paid options for you:

• Overview of IA Rule – free, online
• Conducting Vulnerability Assessments using “Key Activity Types” (KATs) only – free to view slides only online, or receive certification for a fee
• Identification & Explanation of Mitigation Strategies – free to view slides only online, or receive certification for a fee
• Conducting Vulnerability Assessments – fee-based course available only in person by lead instructors approved by the FSPCA

FDA Resources:

Supplemental Draft Guidance for Industry: Mitigation Strategies to Protect Food Against Intentional Adulteration

• Draft Guidance for Industry: Mitigation Strategies to Protect Food Against Intentional Adulteration
  
• Final Rule: Mitigation Strategies To Protect Food Against Intentional Adulteration
  
• Guidance for Industry: Mitigation Strategies to Protect Food Against Intentional Adulteration – What You Need to Know About the FDA Regulation: Small Entity Compliance Guide
  
• All Food Defense Guidance and Regulations www.fda.gov