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Immediately address threats to food production and proactively guard against intentional contamination.
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A food defense plan is a tool that aims to help quality managers in the food business to meet the requirements of the Mitigation Strategies to Prevent Food Against Intentional Adulteration regulation (21 CFR Part 121) by the FDA. It outlines the process of protecting food products from intentional adulteration or contamination that can harm consumers, business establishments, or the general public. Use of a food defense plan isn’t required by law, but it is best practice to use the plan to supplement education, training, and experience for food safety. Doing so will be beneficial in avoiding food safety incidents, costly recalls, and disruptions in food production.
Food defense is a set of programs the FDA mandates to protect the food supply against intentional tampering. This proactive approach focuses on implementing preventive measures to avoid contamination altogether, as well as creating detailed response and recovery plans to mitigate the impact of potential incidents.
A food defense plan can be created by adapting the USDA’s Food Safety and Inspection Service (FSIS) four conditions on food defense plans and creating it according to the unique needs of your business. Follow these four steps to create your own food defense plan:
Form a team that will create a food defense plan based on assessments of vulnerable critical control points in food production and handling (related: TACCP). There are also tools available (FDA’s food defense plan builder) that can help build a customized food defense plan.
It is critical to engage the employees and get their buy-in when implementing a food defense plan. Conduct employee training and meet with stakeholders to implement processes that proactively promote the safety of food products.
Perform internal audits to catch gaps or non-conformance with the implementation of a food defense plan. Analyze food safety inspections to determine the most common non-conforming items and discover areas for improvement in food defense.
FSIS recommends reviewing the food defense plan at least once a year. Others recommend every three years or sooner if there are changes in operations. Based on audit reports, industry best practices, the latest regulations and standards on food safety (e.g., IFS Food), and new hazards, determine if the food defense plan needs to be updated or improve how it is implemented to keep up with new and changing threats to food defense.
To help you get started with a proactive approach to food defense, presented below is a snapshot of a sample food defense plan:
Area | Example of food vulnerability | Food defense example/solution |
Outside Security | Potential tampering of incoming shipments | Careful examination of incoming raw materials (e.g. incoming inspection) |
Inside Security | Suspicious packages and unexpected inventory changes | Establish SOP for reporting to appropriate personnel |
Personnel Security | Lack of awareness to security measures | Periodic food defense training |
Incident Response Security | Product spoilage due to equipment failure | Upgrade food defense system with preventive alerts (e.g. temperature and humidity sensors by Mitti (by SafetyCulture)) |
Here is a sample report for reference:
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This Product Traceability form was developed by a Mitti (by SafetyCulture) Industry Expert Partner to ensure traceability of materials and components throughout the production process, supporting compliance with ISO 9001:2015 Clause 8.5.2 (Identification and Traceability). Use this for food traceability procedures to ensure food safety across all stages of food production and distribution.
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This food defense checklist was digitized based on the USDA’s checklist for warehouses and distribution centers. This checklist uses yes-no-n/a response set to confirm if the following areas are covered: outside security, general inside security, shipping and receiving, mail handling, and personnel.
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This food defense checklist template is created for establishments that serve food products to customers. Evaluate the food defense established for the facility, employees, supplies, food preparation, and cleaning. Easily customize this template using Mitti (by SafetyCulture)’s drag-and-drop template editor to meet business-specific food preparation requirements.
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A food defense assessment template can be based on the TACCP risk assessment in order to assess risks at each critical control point of food production. Determine if a hazard is biological, chemical, physical, or radiological and identify the risk rating.
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This checklist helps ensure proper food handling techniques are being used to maintain food safety from receiving to serving, reducing the risk of cross-contamination. This checklist has also been certified by HACCP International to meet their requirements.
