How to Build a Goal-Based Food Defense Plan for Your Facilities

To protect the food supply, and ultimately the population, food companies must develop a goal-based food defense. A goal-based food defense is effective for two key reasons: it satisfies FSMA requirements, and it keeps people, products, assets, and brands protected against any potential threats. The goal of a Food Defense Plan should be to restore a facility to its pre-event state following tampering or another type of event. Yet, instead of returning to a pre-event state after an event, it proactively aims to prevent an event from happening in the first place.

A Food Defense Plan comprises the following steps:

• Identify critical business components

• Conduct a vulnerability assessment at every facility (not just one location)

• Assess threats and opportunities

• Develop protective measures and mitigation strategies

• Prioritize protective strategies

• Implement protective measures

• Plan and train all staff

The Food Defense Plan also encompasses a Food Response Plan, which includes these key activities:

• Assemble a Crisis Response Team

• Implement response plans

• Monitor business components

• Assess response capability

• Contain the impact

• Implement mitigation strategies (developed in the Food Defense Plan)

• Recovery

• Return to normalcy

Food Defense Plans share the same goal as food safety plans: to protect the food supply, assets, and brand. While food defense protects against intentional contamination, Food Safety (HACCP) Plans protect against unintentional contamination. For food defense, taking a goal-based approach is most effective.

Goal-based assessments are less subjective than risk-based assessments. In the latter, the process focuses on identifying risks – which is inherently a subjective process – but not security processes or solutions. If strong security measures are already in place as a result of taking a goal-based approach, there will naturally be significantly fewer risks.

The process of performing a goal-based assessment includes understanding the purpose of the defense plan, establishing appropriate goals to achieve the purpose, defining the goals, and finally, defining what needs to be demonstrated to ensure the goals are achieved.

Because meeting goals is more objective in nature than performing a risk-based assessment, it can produce quantifiable results. This allows companies to develop benchmarks in terms of whether or not goals are being met. In addition to providing this clear picture of the efficacy of your mitigation strategies, goal-based food defense plans are also beneficial because they comply with the Intentional Adulteration (IA) Rule of FSMA, which states that companies must be able to validate and demonstrate that their mitigation strategies are working.

Assessing Threats

Of course, terrorism is not the only threat for food and beverage companies to consider. There are also criminal, accidental, and natural threats that pose dangers to a facility and its people or products. Once you have identified the types of threats that could occur, you can then develop a sound defense strategy which factors in the likelihood of occurrence for each threat. Keep in mind that this likelihood should not be based on past experience, but the effectiveness of the barriers you have in place. In other words, failing to protect against a certain type of incident simply because it has never happened before is ineffective. Instead, you must ask, “Does our company want to wait until after something has happened to ensure our safety and security?” Most likely, the answer will be no – which is why food defense is based on prevention, not reaction.

Determining Appropriate Levels of Security

A common question in the food and beverage industry is: How much security is enough? While the answer varies from one facility to the next, it should always be dependent on what is being protected. A facility with ready-to-eat food products and bulk ingredients would clearly demand higher levels of security than an empty warehouse.

Evaluating your Food Defense Plan to ensure it is compliant and effective in fully protecting your company requires time and careful consideration. However, it is among the most important things food and beverage companies can do to ensure the safety of their products, people, brand, and assets. By taking the time to put a solid plan in place now, you will not only have procedures to follow if an event ever should occur, but also reduced likelihood of an issue happening in the first place.