and initiate activities that will be required for compliance. One approach is to start
small by taking a single food product and considering the following:
Assess: How much information is already available through past food safety and
food defense planning? Identify and document where action may be needed.
Understand Hazards: Select a food product and document the hazards that may
affect this product. Think outside the typical safety hazards. What could cause harm
beyond the normal concerns you have? Consult incident reports, published literature, and known cases. Have you considered introduction of pesticides, undeclared
allergens, or cleaning and sanitizing agents?
Assess the Supply Chain: Map the supply chain of the food product including the
supply chain of ingredients. Where is the product coming from? Indicate how it
travels and where there are inspection points. Can you document all the way back to
Plan: Do you have a food defense plan? If yes, evaluate to see that it meets the
requirements of the IA rule. Does it consider all hazards identified above the transportation network? Determine the last time the plan was challenged or exercised;
was it more than a year ago? If no, find a resource to aid your planning (e.g., FDA
Food Defense Plan Builder, U.S. Department of Agriculture, FPDI). Determine who
within the food company can initiate a food defense plan and start identifying and
prioritizing where vulnerabilities need to be mitigated first. Create a timeline for
development and review.
Conduct Vulnerability Assessments: Evaluate the production of the food product to
determine where it may be susceptible to intentional adulteration.
Determine Actionable Process Steps: From the vulnerability assessment, identify the
processes during food production where mitigation strategies can be applied and are
essential to substantially minimize or prevent the significant vulnerability.
Mitigate: Identify mitigation strategies for each actionable process step based on
your assessment. FDA has a database of mitigation strategies13 that may be helpful.
Next, determine the cost of those strategies and prioritize what strategies should be
implemented first. Finally, initiate a plan to implement selected strategies.
Educate and Train: Different team members need various levels of training or
awareness. Identify who will have a role in food defense and align the appropriate
training. There are many training opportunities already available at the FDA Food
Defense website. In addition, FPDI offers a variety of in-person food defense trainings14 as well as a food defense awareness online training15 for those looking to be
trained from the comfort of their home.
The Food Protection and Defense Institute
In 2004, the Department of Homeland Security (DHS) created the FPDI. The institute was formerly known as the National Center for Food Protection and Defense.
It was one DHS Center of Excellence established to evaluate and research the terrorist threat to the homeland. Over the past decade, the work at FPDI has evolved to
consider food system disruption regardless of motivation. Today, FPDI operates with
a mission of “Providing the highest impact innovation, education, and outreach to
defend the global food supply.” By taking a comprehensive farm-to-table view of the
food system, encompassing all aspects from primary production through transportation and food processing to retail and foodservice, FPDI’s work addresses both the
vulnerabilities requiring assessment by the IA rule and vulnerabilities throughout the
FPDI’s research and education programs aim to reduce the potential for
contamination at any point along the
food supply chain as well as the mitigation of potentially catastrophic public
health and economic effects of such
attacks. FPDI’s programs incorporate
cutting-edge research across a wide range
of disciplines, including supply chain
management, logistics, epidemiology,
risk assessment, economics, molecular
biology, food microbiology, biomedical
engineering, toxicology, information
sharing, supply chain security, cyber
security, and risk analysis.
FPDI education professionals and
subject matter experts have extensive
experience in designing, developing, and
delivering a continuum of food defense
training. FPDI also offers in-person
programs developed to address food
defense needs at all levels within an
organization—entry level to C-suite—and
across a variety of disciplines: national
to local government, law enforcement,
food manufacturing and retail, supply
chain and logistics, and foodservice,
catering, and restaurants.
In addition, a variety of training
opportunities and course offerings are
available that address FSMA IA training requirements, FSMA Preventive
Controls requirements regarding EMA,
increasing awareness of food defense on
a global scale, understanding and applying food defense principles, identifying
food defense vulnerabilities, creating tailored food defense plans, and challenging preparedness and response planning.
FPDI’s programming supports industry,
government agencies (law enforcement,
emergency responders), nongovernmental organizations, international partners,
undergraduate and graduate students,
and educators. FPDI strives to provide
strategies for prevention, mitigation,
response, and recovery from potentially
catastrophic public health and economic effects of attacks on our food supply.
“Today, the food system from farm to fork is a global, highly integrated, and
complex system of systems.”