Food Defense: It’s Everyone’s Job

A series of webinars on the Intentional Adulteration rule can be found on the Food Safety Preventive Controls Alliance (FSPCA) website.

In these webinars FDA presents expectations and methods for achieving compliance to the rule. Present them to your food defense team and employees, customize the message to your situation, and, above all, get the conversation started.

There’s also a tool for identifying appropriate mitigation strategies. This tool is built on a mitigation strategies database, which is broad reaching and practical.

The FDA also provides helpful posters, called Employees First. These can be printed off and used to educate frontline food employees as to what they can do to promote food defense.

Beyond awareness training, the topics and level of complexity in your education programs will be dictated by the responsibilities of the individual. The following table provides a breakdown of topic categories based on job role.

The Qualified Individual

The Intentional Adulteration rule clearly states that the food defense plan must be prepared by a qualified individual. The plan must also include a written explanation stating how each strategy significantly minimizes or prevents the significant vulnerability at the actionable process step.

One of the ways to gain this expertise is by taking the FSPCA intentional adulteration training that will be available in both a face-to-face version and an online option.

The qualified individual, with support from senior management, will be best positioned to determine a training plan that will address all individuals in the facility including seasonal and temporary employees.

The Food Defense Team

The food defense team is at the heart of your defense plan. Who is on that team and how they are trained is critical. Most will never have been involved in a food defense event, and this will be new territory for them.

Following best practices for risk assessment and building a multi-disciplinary team will be particularly helpful in this situation. In addition to a trained and knowledgeable team leader, consider other plant roles, such as human resources, health and safety, security, and IT, as team members. They can bring insight into potential vulnerabilities that need to be understood and addressed.

The risk assessment team must think outside the box and challenge themselves to consider vulnerabilities that are unique to the process and the particular facility. For example, have they considered the threat of a cyberattack? How easy would it be for the refrigeration systems to be hacked? Could hackers break into your PLC or refrigeration systems, bypass the alarm, and turn a cooler up for five hours and then back down on a weekend?

If some of your team members are new to risk assessment in general, they will require training on the topic. The same is true for procedure writing skills, conducting a gap analysis, understanding cybersecurity threats, and recognizing signs of employee dissatisfaction.

The type of vulnerability assessment training that you select will depend on the two methodologies outlined by the FDA: the three elements from Carver + Shock or the four key activity areas. It is up to you to select the one that you feel your team can best manage.

The results of the vulnerability assessment will highlight the food defense practices required to maintain the production processes and environment, and these may function much like food safety prerequisite programs. Once again, training will help focus efforts and prioritize implementation of prevention strategies. Most of us understand the need to keep doors closed and locked, but how significant is that threat when compared to protecting an isolated area of the facility where product is exposed and multiple ingredients are blended?