Food Defense

You’ve got 24 hours to provide the FDA with documentation showing your food production facility Intentional Adulteration Vulnerability Assessments (IAVA). Do you have those documents?

April 18, 2024 | 3 Min Read

Food Defense is defined by the Food and Drug Administration (FDA) as: The effort to protect food from intentional acts of adulteration where there is an intent to cause wide scale public health harm. (21 CFR 121.3)

A fully implemented Intentional Adulteration Vulnerability Assessment (IAVA) process is required by the Food Safety Modernization Act (FSMA) in order to maintain a proactive Food Defense posture, because it puts in place measures to reduce or eliminate the possibility that an intentional adulteration event will occur. The IAVA process requires the development of a food defense plan, general and targeted training requirements based upon an individual’s food defense responsibilities, recordkeeping requirements, and food defense plan reanalysis requirements.

Performing an IAVA on your in-house processes is just the first step. You must also perform an IAVA on how your food transportation carrier gets your bulk ingredient product to your plant. The FDA clearly states in FD.4 that it is the food production facility, not the carrier, that must take mitigation steps necessary to protect the cargo during transit.

Intentional Adulteration can come from: a disgruntled employee; corporate sabotage by a rival company; an act of terror. Unloading contaminated bulk ingredients at your food facility could result in much more than just a food crisis, recall, and plant shutdown. If the FDA determines that you did not mitigate the intentional adulteration vulnerabilities to the cargo during transit, then you could also face criminal charges.

Your mitigation actions have to be proactive, not reactive. To effectively implement the FDA requirement for mitigating intentional adulteration vulnerabilities, 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 dynamic system. Our patented system is currently being used by some of the largest national brand food, bakery, and candy producers in the United States for their cargo traceability, tracking, security, and employee safety. 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. Unlike other RFID seals on the market that will continue to read after being cut, our seals cannot be circumvented. You are alerted as soon as the trailer pulls into your lot whether the bulk ingredient shipment was potentially adulterated during transit.

With Surelock Seals, you know BEFORE you unload.

If you have questions regarding Food Defense, or the FSMA Intentional Adulteration ruling, please contact us for a handout that outlines the issues, the FDA expectations, and how you can mitigate the vulnerabilities.

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