Food Defense Mitigation Strategies
Food Defense Mitigation StrategiesPreventing Intentional Adulteration
What are food defense mitigation strategies?
Mitigation strategies are defined by the rule as those risk based, reasonably appropriate measures that a person knowledgeable about food defense would employ to significantly minimize or present significant vulnerabilities identified at actionable process steps. Those measures must also be consistent with the current scientific understanding of food defense at the time of the analysis.
For example, your food defense team has identified a significantly vulnerable step in your process where a mixer is oftentimes left unattended with product inside. A mitigation strategy may be to control access so no unauthorized personnel would be allowed to access the mixer during vulnerable times.
Are mitigation strategies required?
What are the requirements?
As stated above, for each identified actionable process step in your process, you must identify and implement mitigation strategies in order to significantly minimize the risk for intentional adulteration of your products. Remember, an inside attacker is likely your biggest threat. Also, for each mitigation strategy implemented, the facility must also provide an explanation of how the mitigation strategy prevents or significantly reduces the vulnerability associated with the actionable process step.
For instance, in the example given earlier where controlling access to an unattended mixer has been identified as a mitigation strategy at this actionable process step, an explanation of why the mitigation strategy was chosen might look like the following:
Access to the mixer will be controlled by closing and securing the lid with a combination padlock where only approved personnel have the code to open the lock. This will prevent unauthorized personnel from accessing the mixer and potentially adding a contaminant to the mixer while it is left unattended.
Both the strategies and explanations that are developed must be written and directly relate to the significant risk that was identified during the vulnerability assessment.
The Mitigation Strategies DatabaseA helpful tool
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2. Food defense corrective actions
3. Food defense verification
C. Contaminant-specific analysis
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