As a food-related facility covered under the requirements of the IA Rule, trustworthiness must be earned by partnering with others occupying space in the global supply chain by making a management commitment and resource investment to ensure cooperative understanding and sharing of responsibility to mitigate international product security risks. Even if a food-related facility is not covered by regulatory statute under applicable FSMA rules, including the IA Rule, commercial agreements between supply chain parties may still contain language that requires FSMA compliance to specific FSMA rules and their provisions prior to engaging in the purchasing, manufacturing, and sale of goods. A relationship in food defense requires honest and effective communication of clear expectations among all stakeholders.
With the exception of an opportunistic intentional terrorist attack using toxic agents, most perpetrators, in their deceit, have no intent of harming life. Sadly, akin to a food safety incident that occasionally escapes detection and control, supply chain food defense breaches that the IA Rule now addresses can have serious adverse health consequences or death for human or animals. Everything possible must be done to intercept these product security issues before they become public health concerns. The chain of food protection and product security custody and trustworthiness, once broken, has already been proven to be both difficult and costly to regain.
Park is the principal for Food-Defense, LLC. He has practiced food protection technical and management consulting for 46 years, is an FDA-recognized international processing authority, and an FSPCA PCQI Lead instructor. Reach him at [email protected].
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