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Tip of the Week: Key Checkpoints In Reducing Intentional Adulteration In Your Facility
Tip of the Week: Key Checkpoints In Reducing Intentional Adulteration In Your Facility

What Is Intentional Adulteration?

The intentional adulteration of food is made up of two major issues:

  • Food Defense to prevent illness or death from terrorism and sabotage and;
  • Food Fraud, the adulteration or misrepresentation of food for economic gain.

Food Defense

Recognizing the vulnerabilities of the supply chain to terrorism and sabotage, the U.S. Food and Drug Administration created 21 CFR 121 Mitigation Strategies to Protect Food Against Intentional Adulteration from the requirements listed in the Food Safety Modernization Act (FSMA). This rule requires all domestic and foreign companies that are required to register with the FDA in accordance of the Food and Drug Cosmetic Act section 415, to prepare and implement a food defense plan, unless a facility meets one of the listed exemptions. The deadline for compliance was July 26, 2019 for large and medium-sized businesses. The deadline for companies that are considered small businesses, defined as having less than 500 full time employees is July 27, 2020.

Every covered facility is required to prepare and implement a food defense plan. This written plan must include a vulnerability assessment (conducted by a qualified individual) for each processing step and determine if they have any significant vulnerabilities. If significant vulnerabilities are identified, this is called an actionable processing step. If an actionable processing step is identified, then mitigation strategies, procedures for food defense monitoring, corrective actions, and verification activities are required. A reanalysis of the food defense plan is required at a minimum of every three years or when certain criteria are met, including mitigation strategies that are determined to be improperly implemented.

Food Fraud

Food fraud requirements have been included in the FDA’s 21 CFR 117 Preventive Contols of Human Food as economicallymotivated adulteration has become a growing issue. All FDA registered food facilities must comply with this regulation unless they meet one of the listed exemptions. Beyond regulatory compliance, the Global Food Safety Initiative (GFSI) also recognizes food fraud’s impact on food safety and has included key elements of food fraud prevention in version 7.2 of their benchmarking requirements. This ensures that food fraud is considered in the food safety management systems of any GFSI certified operation.

Why AIB International?

Founded in 1919, AIB International supports the world’s favorite food brands with comprehensive food safety training, certification, inspections, and consulting. We’re committed to raising the standard of food safety and developing practical and actionable solutions to emerging issues. 








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