4 Components Your Food Defense Plan Must Include

The highest priority of any food and beverage company is maintaining food safety standards and quality. But have you invested enough resources and time in preparing your facility for defense against intentional adulteration?  

With overseas conflicts and social unrest on the rise, potential threats from disgruntled employees, terrorists, or other bad actors also loom, making it more important than ever to have a solid food defense plan. 

Why do you need a food defense plan? 

FDA’s Food Safety Modernization Act includes a Mitigation Strategies to Protect Against Intentional Adulteration rule that requires food companies to have a food defense plan preventing intentional contamination with the aim of impeding or reducing public harm. 

The purpose of a food defense program is to outline all of the food safety risks your facilities face, as well as the steps you will take to manage them. It should include the following: 

• A vulnerability assessment 
• Mitigation strategies 
• Food defense monitoring records, corrective action steps, and verification information 
• Training documentation 

Let’s dive deeper into these four key food defense management components. 

1. Vulnerability Assessment 

A vulnerability assessment is an evaluation of your facility’s processes with the goal of identifying potential risks for intentional contamination. It should pay special attention to these: 

• Physical security flaws offering access to a potential attacker 
• Whether an attacker can contaminate products without detection 
• Process risks (e.g., processes that can uniformly distribute a contaminant throughout a product batch) 
• The public impact of contamination 

The assessment must also take into account both the vulnerabilities that could allow an “insider” (e.g., an employee) vs. an “outsider” (e.g., a terrorist) attack. 

2. Mitigation Strategies 

The next section of your food defense plan should focus on mitigation strategies for each of the vulnerabilities you identified. 

Some basic mitigation strategies include: 

• More comprehensive hiring practices (e.g., background checks) 
• More thorough procedures or policies around employee and visitor access to your facility
• Updating exterior and interior facility security (e.g., lighting, access control systems, or fencing)
• A clear plan for reporting suspicious activity 

Note that some of your mitigation controls may already be in place as part of other programs, such as base good manufacturing practices (GMPs) or hazard analysis critical control point (HACCP) programs. However, you should still document and review them as part of your food defense plan's mitigation strategies. 

For more ideas, FDA offers a Mitigation Strategies Database with additional food defense information on common preventive measures. 

3. Food Defense Monitoring and Verification Procedures 

You need to develop monitoring and verification procedures to ensure you properly implement the mitigation strategies you’ve developed for each noted vulnerability. 

These written procedures must include the following: 

• How frequently mitigation efforts are to be performed 
• A clear documentation process for record-keeping 
• An outline of corrective action procedures for when mitigation strategies are incorrectly or improperly carried out 

Similar to HACCP systems, you must periodically reassess, reanalyze, and re-verify your food defense plan, especially if your facility’s operations change significantly or you learn about new vulnerabilities or threats. 

4. Training Documentation 

Maintaining food defense is a company-wide effort, which is why you should create an interdisciplinary food defense team that oversees the development, implementation, and management of the food defense plan. 

Once you’ve formed the team, make sure you provide the proper training, guidance, and resources on the latest food defense regulations and best practices. AIB’s Food Defense Coordinator Online course is designed to help participants manage every step in the food defense plan, as well as train other team members in food defense. Upon completing the course, participants can take another exam to receive their Food Defense Coordinator Certification. 

Level Up Your Food Defense With AIB International 

Food defense plans are crucial for food companies to protect themselves, and, given the public health and brand risks of intentional adulteration, it’s well worth the proactive investment. 

If you’re ready to kickstart, update, or revamp your food defense strategy, AIB International can help. Our team has helped companies across the globe improve their food safety programs, including strategies for mitigating and responding to intentional adulteration. Our Intentional Adulteration Assessment program brings our experts into your facility to review your food defense plan, identify gaps, and suggest corrective actions while ensuring FDA compliance. 

This critical step helps understand exactly where your current weak points are and what your facility needs to improve food safety. Click here to learn more about the assessment and schedule a site visit. yt6