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HACCP and food defense


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#1 qualitymanager

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Posted 16 January 2017 - 10:59 AM

Hello everyone,

 

I m working in a company of food packaging and i m updating our HACCP analysis. I would like to add the food defense in our HACCP plan because i think it will be easier as we are talking about risks.

 

Does someones have a model of HACCP+food defense?

 

 

Thank you for your help


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#2 FurFarmandFork

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Posted 16 January 2017 - 08:25 PM

No need for anything extra if you wanted to combine, really if you do a "column" approach with physical, biological, and chemical hazards, you could also include a "defense vulnerability" hazard analysis for each processing step, and include your controls for food defense that way.


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#3 Big Wally

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Posted 17 January 2017 - 04:20 PM

I am also in the packaging industry and personally would not like to combine these 2 programs. Although both need to have risk analysis, food defense refers to the intentional vs the unintentional haccp.


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#4 Ryan M.

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Posted 17 January 2017 - 09:01 PM

I HIGHLY recommend you download, install and use the FDA Food Defense Plan Builder Tool.  This tool will build your food defense plan with your input.  A lot of the input is already in the tool as a template and you just need to select that various items that apply to your facility and process.

 

For our facility it took our team 4 hours to complete the food defense plan and another 2 hours to verify/validate the plan for the "Action Items".  It includes a vulnerability assessment and mitigation strategies.  There's other nifty items in the plan such as emergency contacts and attachment of supporting documents.

 

http://www.fda.gov/F...s/ucm349888.htm


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#5 mgourley

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Posted 17 January 2017 - 11:47 PM

Considering that Food Safety and Food Defense are two completely different things, I would not recommend you combine the two.

As Ryan points out, the FDA FSPBT is perfectly suited to not only do the Food Defense Assessment, but to build the plan. Since the FDA spent quite a bit of time building it, one would assume the FDA would accept it.

 

I have had no issues with BRC auditors accepting it as well.

 

Marshall


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#6 qualitymanager

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Posted 18 January 2017 - 11:23 AM

Hello Big wally,

 

can you show me your food defense plan please?


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#7 Jo Deakin

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Posted 18 January 2017 - 12:26 PM

Hi,

 

Try AIB website they have a lot of food defence material.

 

Cheers

 

Aldeen


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#8 Big Wally

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Posted 18 January 2017 - 01:24 PM

Sorry qualitymanager,

 

I attempted to send you a redacted version of our plan but can not attach files in a message to you. 


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#9 qualitymanager

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Posted 19 January 2017 - 02:40 PM

Hi Big wally,

 

Can you send it by mail please?

 

If you are certified BRC/IOP, what did you do for this clause: 2.2.5?

 

my mail is:xxxxx


Edited by Charles.C, 26 January 2017 - 04:56 PM.
email removed

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#10 Ryan M.

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Posted 19 January 2017 - 02:41 PM

I wouldn't recommend anyone sending other persons on this board or even customers, vendors, etc your food defense plan.  Instead you should have a statement you have a food defense plan in place per FDA requirements.  Something to that effect.

 

Your food defense plan should contain the preventive actions and security measures you take for food defense in your facility.  It is almost akin to giving someone your network router password.

 

I also urge others to not provide your FDA facility registration number.  In a nefarious persons hands this number is all someone needs to gain access to your FDA food facility registration on the website.  I know a lot of customers ask for the number, but just provide them a statement around your facility being registered, you have a food defense plan in place, and you see the registration number as secure and confidential.


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#11 QAGB

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Posted 26 January 2017 - 04:15 PM


I also urge others to not provide your FDA facility registration number.  In a nefarious persons hands this number is all someone needs to gain access to your FDA food facility registration on the website.  I know a lot of customers ask for the number, but just provide them a statement around your facility being registered, you have a food defense plan in place, and you see the registration number as secure and confidential.

 

I had never heard this part before. We're constantly asked for our registration number via the hundreds of questionnaires we get every year. That's a good idea. I should probably just give our history or registration -- such as dates of re-registering via the new 2 year regulation the FDA has rolled out.

 

Thanks Ryan!

 

QAGB


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#12 Ryan M.

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Posted 26 January 2017 - 04:39 PM

Yup...many people respond with their number without a second thought.  To be honest I did so when the whole FDA registration process began until an auditor pointed out not to share it and why you shouldn't.  A customer or whomever has no reason to have your registration number.  They just want confirmation you are FDA registered and it is current.

 

I had never heard this part before. We're constantly asked for our registration number via the hundreds of questionnaires we get every year. That's a good idea. I should probably just give our history or registration -- such as dates of re-registering via the new 2 year regulation the FDA has rolled out.

 

Thanks Ryan!

 

QAGB


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#13 FurFarmandFork

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Posted 26 January 2017 - 04:41 PM

I've heard it tangentially, and I think somewhere in the registration database it says to use the confirmation letter as proof and not share your registration number if possible. But the FDA Q&A has this to say:

 

30.3 Q: Is a facility required to provide its food facility registration number, assigned by FDA when the registration is submitted, to customers or other businesses who request the number. Is a facility prohibited from revealing its registration number?

 

A: Section 415(a)(5) of the FD&C Act prohibits FDA from publicly disclosing certain registration-related information, including the registration number. However, this prohibition does not prevent a facility itself from disclosing such information. In fact, for imports, a facility will likely need to provide its registration number to any downstream commercial entity who will be submitting prior notice for a food manufactured by the facility. The FD&C Act does not prevent a foreign facility from entering into an agreement with its customers to limit the circumstances in which the facility's registration number may be disclosed to third parties

 

M.4 FDA’s list of facilities and registration documents are not subject to public disclosure. How do we know that a supplier, for instance, is registered?

 

Section 415(a)(5) of the FD&C Act provides that certain food facility registration information is not subject to disclosure under FOIA. However, disclosure of such information by the facility itself is not prohibited. FDA expects that generally, foreign suppliers and their customers will resolve this question as part of their agreement to buy and sell food for consumption in the United States.

 

M.5 Will FDA require the food facility registration number to be displayed as part of a food label?

 

No. There is no requirement to list on the food label the registration number (or numbers) for the facility (or facilities) associated with manufacturing/processing, packing, or holding the food. FDA actually discourages food facilities from including their registration numbers on the food label to prevent others from using the registration number for improper purposes.

 

 

I still am unsure just what exactly these improper purposes would be, other than potentially pretending to be another company when importing?

 

Ultimately though, since in M.4 FDA clarifies that they'll do nothing to help you confirm whether a facility is actually compliant, them providing an X digit number to you does nothing to verify compliance, so you might as well just get them to say "we're registered" in writing, it's as good as anything else.


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