Is Your Food Defense Plan Inspection-Ready?

November 24, 2020
By Marc Digiorgio

At Harvest Food Solutions, we have written before about the importance of a strong Food Defense Plan as part of your business’ overall food security. Recently, the Food and Drug Administration (FDA) has announced the resumption of routine inspections of businesses of all sizes, in part to assess compliance with their standards regarding Food Defense Plans.

strong food defense planWe have previously outlined the steps you should take in order to conduct a vulnerability assessment of your facilities. While you undertake that assessment, keep in mind that a strong Food Defense Plan should include the following considerations:

  1. Potential impact to public health in the event of food contamination;
  2. Ease of physical access to the product; and
  3. Ease with which an attacker might contaminate the product.

Impact to Public Health

As we have said before, keeping food safe keeps communities safe. The perishable food industry is uniquely positioned to impact public health in a widespread way. While individuals may inadvertently misuse foods in a way that impacts their health, contamination of foods prior to sale can cause much more damage, including damage to public trust.

Food contamination may be accidental or deliberate, and your Food Defense Plan must make allowances for both types of instances.

  • Accidental contamination may occur due to improper manufacturing processes in a facility, cross-contamination due to proximity to allergens, or inadequate storage/transportation solutions.
  • Deliberate contamination may occur when agents either inside or outside of your facility strive to interfere with your products, with the goal of causing harm.

There are a number of different types of outbreaks that have occurred over the years as a result of food contamination, which have led to food poisoning and hospitalization of thousands of people at a given time. Salmonella is the most common cause with an average of over 19,000 cases per year, according to the Centers for Disease Control and Prevention (CDC). Other outbreaks include E. coli, botulism, listeria, and Hepatitis A.

Ease of Physical Access to the Product

When discussing physical access to your products, this generally indicates deliberate contamination. Obviously, your workforce and supply partners already have full access to your products. But part of a strong Food Defense Plan also examines accessibility from those outside your workforce. This is known as intentional adulteration, and is the focus of the upcoming FDA inspections.

The FDA Food Safety Modernization Act (FSMA) final rule is aimed squarely at prevention of intentional adulteration. This rule, issued in May of 2016, required both domestic and foreign food facilities to address the hazards that may lead to contamination, thus causing widespread endangerment to public health. This legislation is what prompted the creation of Food Defense Plans.

One of the major provisions of this rule specifically addresses the ease with which an outside attacker might access food products either during processing or while in transport. Points to consider include security measures at processing facilities, monitoring of internal processes and storage facilities, and proper transfer of products to their points of sale.

Ease with which an Attacker Might Contaminate the Product

Along with ease of access, there is also a factor of time. Once an attacker has achieved access to the food product(s) they wish to contaminate, is there sufficient time for them to actually achieve contamination? Are there quality control measures in place at a facility that might identify contaminated food products before they are released to the general public?

The general thinking behind intentional adulteration is that this would likely be the work of domestic or foreign terrorism. However, it is possible that this might also be the work of a disgruntled employee. Both scenarios need to be considered as part of a Food Defense Plan, along with many others. The bottom line is that intentional adulteration is designed to impact public health on a large scale, in terms of both physical and economic health.

Preparing Your Food Defense Plan for Inspection

The FDA has a number of benchmarks they use to evaluate the effectiveness of a business’ Food Defense Plan. The primary focus will be to “educate while we regulate”, meaning that initial routine inspections will be “quick checks” regarding the presence of a Food Defense Plan which satisfies the basic requirements. Following those initial inspections, the FDA will provide additional educational materials and food defense awareness training to bring all facilities into more extensive compliance with the FSMA.

It is also worth noting that mitigation strategies regarding food safety focus less on individual foods or food groups and more on continuing processes and monitoring. This is important to keep in mind when conducting your vulnerability assessment. For example, your Food Defense Plan should focus less on a particular type of allergen that your facility might handle and store, and more on how allergens in general are processed.

At Harvest Food Solutions, we can guide you through the process of solidifying your Food Defense Plan and preparing it for inspection. From goal setting to implementation, we are with you every step of the way.

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