Here again, the FDA has provided a useful tool in its Food Defense Plan Builder. This user-friendly software program helps you tailor a food defense plan to your facility. It harnesses existing FDA tools, guidance, and resources into a single application. By asking you a series of questions about your production process, it calculates a vulnerability score for each step in the process that will help you prioritize your efforts.
Training to Support a Food Defense Culture
The ultimate goal of any training program is behavior change. You want people to do things differently. In this case, you want them to understand how intentional adulteration can occur, recognize threats to your food products, and take ownership of the part they play in preventing threats from becoming realities.
There are three key areas in training:
- Knowledge—how well your employees know the topic, both the fundamentals of food defense and the requirements of your plan;
- Skill—how well they can perform specific tasks as itemized in your food defense plan; and
- Attitude—how they approach their role in food defense.
Once you have classified these areas, you can customize your training program to address specific gaps. Assessing attitude is by far the most difficult task, as is training for attitude change. And yet, it is the most important. Just because someone has been trained on a topic, or has passed an exam, it’s no guarantee of success.
When people choose to do something because they believe it is the right thing to do—even though it might take longer and even though it might interfere with their other duties—then you know you are building a strong food defense culture.
Onett is the technical manager for training and education services at NSF International. Reach her at [email protected].
The FSMA Intentional Adulteration Rule
The purpose of the Intentional Adulteration rule is to prevent intentional acts of adulteration of the food supply that would cause wide-scale harm to the public. Since 2004, the FDA has been conducting vulnerability assessments on a wide range of products and processes as per the Homeland Security Presidential Directive #9.
Using the Carver + Shock prioritization tool, it identified three of the seven elements that contributed most consistently and significantly to the threat of intentional adulteration of food:
- Criticality—measure of public health and economic impact;
- Accessibility—degree of physical access to the facility and the product; and
- Vulnerability—ease of accomplishing the attack (including the possibility of an inside attacker).
These form the basis for the step-by-step vulnerability assessment of the process and contributed to the FDA’s identification of four key activity types: 1) bulk liquid receiving and loading; 2) liquid storage and handling; 3) secondary ingredient handling; and 4) mixing and similar activities.
A food defense vulnerability assessment must at a minimum assess the process against the key activity types. This assessment must also include the possibility of an inside attacker.
The guidance document released by FDA in August 2017 describes the rule in detail and includes the following training requirements.
- The vulnerability assessment and the resulting food defense plan must be conducted by a qualified individual, with the education, training, and experience to conduct the assessment and the reanalysis. This includes the written explanation of the chosen mitigation strategies.
- The individuals responsible for implementing the mitigation strategy at the actionable process steps must be trained in those activities and must receive food defense training.
- Supervisors of those responsible for implementing the mitigation strategy at actionable process steps must receive training to ensure they can carry out supervisory activities and receive food defense training. Records of training must include the type of training, date, and names of the persons trained and must be maintained for two years.—K.O.
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