Verification is the process by which an evaluation is made of whether a set of implemented mitigation strategies around APSes has been working as designed. Monitoring, on the other hand, identifies important points of potential system failure that could, if not mitigated, increase the probability of a successful intentional product or packaging adulteration attack, resulting in loss of product security that could adversely impact public health or cause widespread economic disruption.
Somebody Needs to Do It
I’ll end the article by re-telling a very clever short story, famously used the world over in organizational development circles. The brief story speaks so well to the cause of system breakdowns:
“There was an important job to be done and Everybody was sure that Somebody would do it. Anybody could have done it, but Nobody did it. Somebody got angry about that, because it was Everybody’s job. Everybody thought Anybody could do it, but Nobody realized that Everybody wouldn’t do it. It ended up that Everybody blamed Somebody when Nobody did what Anybody could have done!” (Anonymous)
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].
Food Defense Plan Builder
On Sept., 19, 2019, the FDA launched an updated version of the Food Defense Plan Builder to help companies meet the requirements of the Intentional Adulteration rule under the FDA Food Safety Modernization Act (FSMA). According to the FDA, the free, updated Ver. 2.0 tool has been aligned with the requirements in the IA rule so that it can be used to easily create food defense plans and support compliance with the rule. The tool is available with a registration at: https://www.fda.gov/food/food-defense-tools-educational-materials/food-defense-plan-builder
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