Food Defense

Food Facilities are responsible for mitigating Intentional Adulteration vulnerabilities during transit – not the carrier.

April 1, 2024 | 3 Min Read

It’s no April Fool’s joke: The FDA says that the owner, operator, or agent in charge of a food facility that manufactures/processes, packs, or holds food for consumption in the United States, is responsible for implementing mitigation measures to protect food products they ship or receive from intentional adulteration – not the carrier.

Since the Food Safety Modernization Act (FSMA) is a law, violations may be treated as criminal acts. The FDA may arrest responsible parties, conduct an extended audit of company practices, or even suspend the registration of food facilities (which can lead to temporary or permanent shutdown).

Here are the two points taken directly from the FDA FAQ on FSMA:

FD.4. Do food carriers need a defense plan during transport?
No. The mitigation strategies are more appropriately implemented by food facilities, rather than by carriers. If a facility has identified a significant vulnerability related to transportation, the facility must take steps to reduce that vulnerability.

FD.10. If I am exempted from some requirements of the preventive controls for human food rule under sections 117.5(b) (seafood), 117.5(c) (juice), 117.5(d) (LACF), 117.5(e) (dietary supplements), am I also exempted from the Intentional Adulteration rule? Do I need to develop a food defense plan?
The Intentional Adulteration rule does not include exemptions for seafood, juice, LACF, or dietary supplements. The IA rule applies to the owner, operator, or agent in charge of a domestic or foreign food facility that manufactures/processes, packs, or holds food for consumption in the United States and is required to register under section 415 of the Federal Food, Drug, and Cosmetic Act unless subject to an exemption (see 21 CFR 121.5).

The FDA defines Food Defense as “…the effort to protect the food supply against intentional contamination due to sabotage, terrorism, counterfeiting, or other illegal, intentionally harmful means. Potential contaminants include biological, chemical, and radiological hazards that are generally not found in foods or their production environment.” Intentional Adulteration can also come from disgruntled employees, acts of terrorism, and corporate sabotage.

Ensuring that your traceability actions are proactive, not reactive, is critical to securing the movement of food materials in the supply chain. To effectively implement the FDA requirements, you must have a dynamic system in place to ensure that the bulk ingredients unloaded at your facility were not adulterated in transit.

Surelock Seals provides that system that can alert you if the bulk ingredient shipment was potentially adulterated during transit. We are your Out of The Box solution for food traceability and security, offering both handheld and stationary RFID reader options to fit your budget. Our patented, double-locking RFID seals are attached to the trailer hatches after the bulk ingredient is loaded, and if tampered with in transit, they will be permanently destroyed, informing you of possible adulteration. With Surelock Seals, you know BEFORE you unload.

If you have questions regarding food traceability or the FSMA, check out this previous article on those topics.

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