As usual, the FDA has cocked things up. They have withdrawn their Food Defense Plan Builder, as well as their link to Carver + SHOCK, because they do not comply with the Intentional Adulteration rule in FSMA.
Food Defense is a larger issue than the specific IA rule in FSMA. If you are not subject to the IA rule, you may be able to get away with a more generic Food Defense Plan.
Honestly, I do not understand why FDA has specifically targeted four areas in the IA rule that you have to address. One would assume that a more generic approach to Food Defense, that their tool did a good job of addressing, would not be sufficient.
Well, let me edit that....I do understand why they chose these four areas.... but it just seems to me that concentrating on these four areas is not looking at other areas that could be vulnerable. FDA has basically said that liquid reception, liquid holding, mixing and secondary ingredient addition are the only places that need to be looked at.
I can think of a whole bunch of areas in my production lines where a bad actor could contaminate product.
Edited by mgourley, 04 October 2018 - 10:53 PM.