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Food Defense Plan Insight for Success
Food Defense Plan Insight for Success

This question was submitted to use through the Ask an Expert Feature on the Food First blog. AIB International’s Food Defense Expert Earl Arnold gives guidance for this food safety professional struggling with mitigation strategies.

I am in the process of building my Food Defense Plan to meet FDA requirements and am struggling with the mitigation strategies (i.e., mitigation action and rationale). So if I have NO actionable process step, do we need mitigation strategies? How are action and rationale defined? Our product is shell egg. and I am struggling with these 2 areas. Can you please break it down? I feel like I am talking myself in circles. 
       Needing Food Defense Help ASAP

EA: Let’s cover the requirements of the regulation for context and background.

Requirements of the Food Defense Plan

The vulnerability assessment needs to capture the four contaminants that can be used as an intentional contaminant to cause harm.

  1. Biological
  2. Chemical
  3. Physical
  4. Radiological

You must also assess based on likelihood vs. severity the three fundamental elements (physical access, ability to contaminate, and public health impact). For each processing step you need to assess for these items and determine if you have any significant vulnerabilities.

If you did not identify the need for mitigation strategies, you still are required to justify why you do not have any significant vulnerabilities. If you do have a significant vulnerability, then this processing step would be considered an actionable process step and would require some type of mitigation strategy.

Mitigation Strategies - If during the assessment you identify an actionable processing step, you must develop mitigation strategies. This must be written and include your rationale as to how this mitigation strategy or strategies will significantly minimize or prevent the significant vulnerability you identified. Additionally, you must include the written procedures for food defense monitoring, food defense corrective actions, and food defense verification activity.

Training - The regulation requires all individuals that have a part in the food defense plan be qualified.


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