If You Like Regulations and Want More Regulations “Don't Develop a Food Defense Plan"
As part of the survey FSIS inspection personnel first asked if the establishment had a Food Defense Plan. If a company had a Food Defense Plan, FSIS asked the following questions to assist them in determining if it was a functional plan:
* Does the plan designate a person or team to oversee and implement the plan?
* Does the plan require training of key personnel in provisions of the plan?
* Does the plan require periodic tests or drills on operational elements of the plan?
* Have the plan and associated records been tested or drilled in the last four months?
* Do the plan and associated records have a frequency at which they must be reviewed and revised?
* Have the plan and associated records been revised in the last four months as a result of a tested event or drill?
* What is the nature of various security measures that the plant has in place?
The complete list of actual survey questions can be found at:
Food Defense is not the same as Food Safety. Food Safety addresses the accidental contamination of food products during processing or storage by biological, chemical or physical hazards. HACCP plans deal with Food Safety issues. Food Defense focuses on intentional contamination by people who want to harm us. Intentional acts are generally not reasonable and are hard to predict.
A functional Food Defense Plan contains 5 elements.
- Development. The establishment performs a vulnerability assessment. In the vulnerability assessment the establishment looks for vulnerable points, determines risks and develops defense measures.
- Implementation. The defense measures are implemented.
- Testing. The establishment periodically evaluates the effectiveness of its defense measures.
- Assessment. The establishment periodically reviews its plan and revises as necessary.
- Maintenance. The establishment maintains its plan by ensuring that the defense measures it implements continue to be effective. FSIS has developed excellent resource materials to assist plants with their Food Defense Plans. At the USDA website href="http://www.fsis.usda.gov/Food_Defense_&_Emergency_%20Response/Guidance_Materials/index.asp">www.fsis.usda.gov/Food_Defense_&_Emergency_Response/Guidance_Materials/index.asp you can find an assortment of information on Food Defense. At this website there are documents such as, “Developing a Food Defense Plan for Meat and Poultry Slaughter and Processing Plants” updated June 2008; “Elements of a Functional Food Defense Plan”, “Information on Food Defense Podcasts”, and several other very helpful documents.
If you already have a Food Defense Plan, great! Test it and maintain it to make sure it is a functional Food Defense Plan. If you don’t have a Food Defense Plan perhaps now is the time to pause and develop one. Make sure your Food Defense Plan is both reasonable and practical. Remember: Food Defense Plans are important.