A Food Safety Modernization Act rule will require food companies to have a written food defense plan that addresses significant vulnerabilities in a food operation. Following are six ways the new rule will affect companies.
1. It also applies to foreign companies. With specific farm exceptions, the proposed rule applies to both domestic and foreign facilities that manufacture, process, pack, or hold food. It requires that each facility be registered as a “food facility” with the U.S. Food and Drug Administration (FDA).
2. It focuses on the entire supply chain. The FDA defines food defense as the protection of food products from intentional adulteration by biological, chemical, physical, or radiological agents where there is an intent to cause public health harm or economic disruption. The proposed rule requires that mitigation strategies be applied to identified vulnerabilities that pose a risk to the supply chain. Food defense is distinct from food safety, which addresses the accidental contamination of food.
3. It reduces risks to consumers. The food and agriculture sector is a critical U.S. infrastructure, according to the National Infrastructure Protection Plan, and food defense is the sector’s counterterrorism effort. The probability of a food defense event is low, but the consequences are high.
4. Multidisciplinary teams are key. Food defense applies to vulnerabilities that are identified or anticipated along the entire supply chain, from the source of the ingredients to the consumer. A best practice is building a multidisciplinary team of global supply chain experts who can identify vulnerabilities and risks, and develop a comprehensive, sustainable mitigation program.
5. It is effective 60 days after publication. The proposed deadline for the final rule was May 31, 2016. The FDA proposed that businesses would be subject to the new requirements 60 days after the final rule was published in the Federal Register.
6. Resources are available. The FDA website has information on how to reduce the risk of intentional contamination of food products, including vulnerability assessments and food defense plan building tools. The U.S. Department of Homeland Security and the U.S. Department of Agriculture also offer food defense tools on their websites.
Judy Fadden is a member of the ASIS Food Defense and Agriculture Security Council and has 35 years of global security experience at General Mills.