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FDA Food Defense, Mitigation Strategies for Intentional Adulteration

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    Grade - AIFSQN

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Posted 17 January 2018 - 04:00 PM

I recently took the AIBI Food Defense Coordinator training. This went in depth into the law (21 CFR 121 Mitigation strategies to protect food against intentional adulteration) and industry best practice in food defense. It was a good class and I recommend it. 


However, has anyone noticed the incongruity between the FDA's suggested mitigation strategies and the requirements of the regulation? If you look at the suggested mitigation strategies, most of them do not seem to consider the possibility of an inside attacker.


Anyway, my main reason for posting is that I work in the process industry and we have a facility that produces spray-dried dextrose that is run 24/7 in three shifts with only one operator per shift. How can I implement mitigation strategies to actionable process steps when I have to consider that the one operator will be the attacker? Alarms, key control, peer monitoring, authorized personnel areas, etc. do not work when there is only one person running the process. And no, we cannot hire more people.


Any input is appreciated.






    Grade - SIFSQN

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Posted 18 January 2018 - 08:16 AM



I suggest putting CCTV cameras. Then you can monitor your operation anywhere thru your computer and phones.




Andre Kutassy

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Posted 23 January 2018 - 11:48 AM

Hi John, 


In this case I dont think there is much you can do regarding mitigation action.


I agree with Red Fox suggestion, in case on an inside attacker, CCTV it may intimidate the attacker. 


Another suggestion to complement the CCTV is through zoning where you can establish for this specific area the use of uniform without pockets, and restricting the objects it can enter the area. 


Also some indicators can be used indirectly like employee satisfaction survey, it may give you an idea on how your employees feels about the company, as  usually an insider attacker is not happy with salary, career progression, shifts....and so on. it may identify some issues where you can do a preventive action.



Hope I could help!

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Also tagged with one or more of these keywords: Food Defense, FSMA, Intentional Adulteration, Food Defense Coordinator

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