Food Labeling Compliance Seminar – September 24-25, 2018 in Kansas City, MO

Specializing in FDA Regulatory Matters

Food Defense

The safety of the U.S. Food Supply requires close coordination between food manufacturing and processing facilities, carriers, retailers and of course, the FDA.  As part of the Food Safety Modernization Act (FSMA), FDA is proposing the companies address vulnerabilities in their operations in order to prevent any nefarious acts which could cause large scale harm against the U.S. food supply.  These proposed rules would affect both domestic and foreign facilities and would require the largest food businesses to have a written food defense plan.

The Food Defense rules provide a foundation to prevention as directed by FSMA:

  • Protect against intentional adulteration
  • Improved standards for produce safety
  • Foreign supplier verification program for importers
  • Third party accreditation auditors to conduct food safety audits and issue certifications of foreign facilities which supply food for human and animal consumption.

Each facility covered by this rule would be required to prepare and implement a written and actionable food defense plan.

EAS consultants, experts in food defense, food safety and developing effective import procedures, can help companies to comply with proposed FDA regulations in the preparation of:

  • Prepare actionable process steps to identify  facility specific vulnerabilities
  • Prepare strategies to mitigate the identified risks of adulteration of foods
  • Establish and implement procedures, including the frequency with which they are to be performed, for monitoring the focused mitigation strategies.
  • Determine any necessary corrective actions
  • Develop steps to verify appropriate monitoring of activities, mitigation strategies and corrective actions. A reanalysis of the food defense plan would be required every three years or under certain conditions, every year.
  • Appropriate training of personnel and supervisors
  • Establish and maintain appropriate record keeping protocols including the written food defense plan; records documenting monitoring, verification activities and corrective actions, and documentation related to training of personnel.