Food Defense Mitigation Strategies: How to Keep Your Facility Safe

You have a food safety plan in place, you’ve verified your foreign suppliers, and your delivery vehicles meet the requirements for sanitary transportation. Concerning FSMA, you’re feeling like everything’s “so far, so good.”

But you aren’t quite done yet. The Final Rule for Mitigation Strategies to Protect Food Against Intentional Adulteration is coming into play and it requires food processors to think about their risks and controls in a new way.

To keep your food products and facility safe, the Food and Drug Administration (FDA) developed a database of mitigation strategies. Here are five systems you can put in place at your facility that will help you implement these strategies.

Physical security systems

Your facility is busy every day with employees, delivery drivers, and maintenance workers going in and out. A physical security system helps you control access to your facility and your actionable process steps.

Mitigation strategies

  • Maximize visibility of perimeters, entry/exit points, locations, and operations (e.g., light adequately, install windows, remove visual obstructions)
  • Minimize the number of access points to your facility
  • Secure water, air, and gas supplies and supply lines
  • Use locks, fencing, gates or other physical barriers at perimeters, entry/exit points, locations, and operations to restrict access
  • Use personnel (e.g., guards, supervisors, trusted employees) to monitor perimeters, entry/exit points, locations, and operations
  • Use signage at perimeters, entry/exit points, locations, and operations to designate restricted areas
  • Use surveillance equipment (e.g., cameras) and/or alarms to monitor perimeters, entry/exit points, locations, and operations

Visitor management system

A visitor management system is software that automates your facility’s check-in/check-out procedure, visitor policy, and deliveries. A visitor management system helps you comply with the new rule by recording when people enter and exit your plant, among other benefits.

Mitigation strategies

  • Implement a check-in/check-out procedure at security or reception areas that includes verification of proper identification, screening equipment, and relinquishment of prohibited items
  • Implement a visitor policy which requires proper identification, escorts, and adherence to rules regarding restricted access
  • Implement a policy for acceptance of goods, mail, and packages that includes proper documentation review, screening procedures, and chain-of-custody when appropriate
  • Implement a policy for scheduling deliveries, maintenance, and service

Emergency response plan

If an emergency happens, will your team know what to do? An emergency response plan formalizes what you should do in the very first — and most critical — moments, as well as later, to ensure everyone is safe.

Mitigation strategies

  • Implement a policy for updating and maintaining accurate records (e.g., personnel files, training records, food defense plan documentation, emergency response contacts)
  • Implement emergency response procedures including preventing security breaches during evacuation
  • Maintain an up-to-date list of emergency contacts for food defense events and make it available to personnel

Cybersecurity protocols

Digital security is just as important as your physical security for keeping the food supply safe. Often, these two things go hand in hand. For example, if you have to take the unfortunate step of firing someone, you’ll want to make sure that employee no longer has access to your systems.

Mitigation strategies

  • Implement a policy for protection of sensitive information (e.g., computers, food defense plans, schematics) and periodically modify instituted security measures such as passwords, keys, access cards, and codes
  • Implement a policy to restrict access to locations, equipment and operations and periodically modify instituted security measures such as passwords, keys, access cards, and codes

Employee training program

Your employees are the first line of defense against food adulteration. But they can only help you keep your facility safe if they know what to look for and how to handle any suspicious people or activities.

Mitigation strategies

  • Train appropriate personnel on proper implementation of the food defense plan and conduct periodic retraining at appropriate intervals or when changes have been made
  • Train personnel on food defense awareness and conduct periodic retraining
  • Train personnel to recognize and report suspect items or events to the appropriate contacts and conduct periodic retraining

These are just a few of the strategies you can use to protect the food you make against intentional adulteration. Other approaches include revamping your parking system, implementing an inventory management system, and performing random security checks of your personnel, equipment, and processes.

The FDA is currently working on guidance documents to further assist food processors as they work to comply with the rule. So, be sure to visit the website regularly to stay up to date on the regulations and requirements.

Are you ready to try visitor management in your food facility? Start your free 14-day trial of the Receptionist for iPad today.

Additional resources from the FDA: