FSIS focused on food defense

The Food Safety and Inspection Service (FSIS) has set a goal that by the end of this year, 90 percent of all establishments will have functional food defense plans. To assist establishments in meeting this goal, FSIS has developed several guidance documents (http://bit.ly/regleg0815) to assist industry in the development of a food defense plan.

At this time, only the very small establishment category of plants is not meeting the goal; unfortunately because enough very small establishments do not have a plan, the overall goal of 90 percent for all establishments is not being met. If the goal is not met, food defense plans would move from a voluntary program to a FSIS regulatory mandated program. It is worth noting that the Food and Drug Administration’s (FDA) proposed rule for Preventive Controls for Human Food that will be finalized later this year includes food defense considerations.

For an establishment to have a functional plan, it must take four steps. First, it must develop a written plan. The FSIS Guidance materials include a template that establishments can use to develop a customized plan. All the establishment needs do is check the boxes that apply to the establishment and sign the document. Once the establishment has a written plan, it must be implemented; the measures identified in the plan have been or are adopted and executed. Third, over time, the establishment should also test the plan to ensure that the plan is effective (e.g., check locked doors; make unannounced walks around the perimeter of the building). Finally, the establishment should periodically review the plan and make any necessary adjustments based on the review. A functional plan does not need to be difficult and should reflect the establishment’s operation.

When developing the plan, an establishment should consider the following areas: outside security, inside security, personnel security measures and incident response security measures. The FSIS template includes suggested items for each area. An establishment can choose to include one or more of the FSIS suggested items, or it may incorporate something more applicable to its operation. For example, if all employees are family members, conducting background reference checks on potential employees would not make sense. Locking doors at night and incorporating outside lighting, however, may become key elements in the company’s food defense plan.

Establishments that do not have food defense plans may find they already have steps in place to reduce the risk of intentional contamination. Are visitors asked to show identification? Are they escorted during the visit? If these or other elements for secure food are already in place, they could easily be documented and verified by the establishment as a food defense plan.

By adopting a food defense plan, not only will you be part of helping the industry maintain this as a voluntary program (by meeting the 90 percent goal), you will be taking the necessary steps to ensure a safe and secure food supply. NP

Dennis R. Johnson is a principal with Olsson Frank Weeda Terman Matz PC in Washington, D.C. Mr. Johnson has 30 years experience in food-safety law and regulation, representing large and small meat and poultry companies.

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