4 Components Your Food Defense Plan Must Include

The most important priority of managing any food company is maintaining high food safety standards. But have you invested similar resources and time in preparing your facility for the possibility of 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 that prevents intentional contamination with the aim of impeding or reducing public harm.

This food defense plan should describe not only the food safety risks your facilities face but also 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 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 the following:

• 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 GMPs or HACCP; 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 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 reverify 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.

Ramp Up Your Food Defense

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 is here to help — our Intentional Adulteration Assessment reviews your food defense plan to identify gaps and suggest corrective actions while ensuring it’s compliant with FDA requirements and meets your obligations to maintain food safety. >Contact us to get started today.