Comprehensive pest management, sanitation and food safety programs are enough to protect the food products that are produced in your facility, right? Then what is food defense? These are questions food processing professionals are frequently asking themselves.
Pest management experts at Sprague
can help food processors understand the difference and ensure their facilities and products are fully protected.
The difference can be summed up: Under provisions of the Food Safety Modernization Act (FSMA), the FDA defines ‘food defense’ as the effort to protect food from intentional acts of adulteration, while ‘food safety’ focuses on the unintentional adulteration of the food supply.
FSMA’s final rule is aimed to prevent intentional adulteration from acts intended to cause wide-scale harm to public health, including acts of terrorism targeting the food supply. Rather than targeting specific foods or hazards, the rule requires mitigation (risk-reducing) strategies for processes in food facilities.
For the first time food processors are required to create a written food defense plan. Each facility must have a plan that identifies vulnerabilities and actionable process steps, mitigation strategies, and procedures for food defense monitoring, corrective actions and verification.
Rod Wheeler, CEO and founder of the Global Food Defense Institute, and one of the country’s leading experts on food defense strategies, says the first step in food defense is to identify potential weak links – even those that appear innocent - within your operation.
Wheeler cites example of a large food processing facility in a Western state that proudly hung a sign stating it provided products for 2 million consumers daily. What does that seemingly harmless statement mean to an individual or group with dubious intentions?
“It means an opportunity,” says Wheeler. “With the influx of temporary workers and outside contractors, facility managers need to identify who does or doesn’t have access to critical areas of the facility. Are there cameras in place to monitor the production floor? Are full-time employees saying something if they see something unusual?”
What steps do food processors need to take as they create a food defense plan?
Vulnerability Assessment – Managers need to identify their facility’s vulnerabilities and list the actionable process steps for each type of food manufactured, processed, packed or held at the food facility.
The following elements must be evaluated:
- The severity and scale of the potential impact on public health. This includes such considerations as the volume of product, the number of servings, the number of exposures, how fast the food moves through the distribution system, potential agents of concern and the infectious/lethal dose of each; and the possible number of illnesses and deaths.
- The degree of physical access to the product. Are there physical barriers including gates, railings, doors, lids, seals and shields?
- How easy would it be for someone to successfully contaminate products?
Mitigation Strategies – Managers need to determine what corrective actions can be taken to assure that vulnerabilities will be minimized or prevented. These strategies must be customized to the facility and its procedures, and if done correctly, will sufficiently reduce the risk of intentional adulteration.
Steps to be taken to effectively develop and implement mitigation strategies include:
- Monitoring – The frequency and methods for monitoring the mitigation strategies being used in a facility.
- Corrective Actions – Actions which will be taken if the mitigation strategies are not properly implemented
- Verification – Verification activities to ensure that monitoring is being done and that appropriate decisions about corrective actions are being made.
Training and Recordkeeping – The final pieces of the puzzle are making sure the facility staff receive proper training and that records for food defense monitoring, corrective actions, and verification activities are maintained and organized.