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Validation of the Food Defense Program

Nonconforming Food Defense Validation

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#1 Tavish101

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Posted 05 June 2019 - 11:17 AM

I received a nonconforming for "Lack of Validation of the Food Defense Program" in an SQF Audit 2.5.5.2.  We have completed a Food Defense drill and use the FDA Food Defense Plan builder - so I am not sure what they are looking for?

 

 



#2 mahantesh.micro

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Posted 05 June 2019 - 11:55 AM

Dear Tavish

I think you need to conduct self inspection and validate mitigation plans in case of failure of your food defense system for that u need to prepare checklist and validation protocol. and also refer the below link that may help u.

 

https://www.qualitya...s-verification/



#3 Tavish101

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Posted 05 June 2019 - 12:21 PM

Thank you! We did a Food Defense self inspection/challenge  like the one in the article ( I incorrectly called it a drill).  I thought this was the Validation of the program - but not so? Would it be a statement of these checks working?

 

Sorry... I am still confused.



#4 SQFconsultant

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Posted 05 June 2019 - 12:54 PM

Don't do a "self" inspection.

 

We do food defense breach exercises - the people at the target company don't know who we are at all.

 

That is what you need to do - go out and get a friend or someone that no one at the company knows.

 

Have that person attempt to enter and breach  --- they need to chronicle the event, how they got in, etc.

 

You need to document everything, including the bads, your corrective actions, etc. 

 

This is not about making sure all the check boxes are complete - you actually want someone to breach your security controls that you have in place and document that information - yes, the bad stuff.

 

The Auditor doesn't want to look at a sheet of paper that shows that everything was wonderful, they want the truth of what happens in this kind of situation - aka "no snow job" "no sugar coating."


Warm regards,

 

 

Glenn Oster

Glenn Oster Consulting, LLC

 

SQF On-Site System Development & Implementation Consultant

You can DIY or Bring in the Professionals 

 

Small to Mid-Size Food, Food Packaging & Food Logistic/Storage 

SQF GAP Analysis of Operational & Capital Needs

Internal Auditor Training Program / United States of America, Canada & Centro America

772.646.4115 USA // glenn@glennosterconsulting.com

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#5 The Food Scientist

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Posted 05 June 2019 - 05:17 PM

Have you done a Food Defense challenge? Is the program being reviewed during annual management review meetings?


Everything in food is science. The only subjective part is when you eat it. - Alton Brown.


#6 Tavish101

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Posted 05 June 2019 - 06:27 PM

Yes we did a Food Defense Challenge and it is reviewed annually. We are a rural small company less then 10 people. 



#7 The Food Scientist

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Posted 05 June 2019 - 07:36 PM

I am really confused actually. The code clearly states it needs to be challenged and reviewed at least annually.  

 

Perhaps your auditor saw something around your facility that shows lack of validation to your food defense plan. 

Everything in food is science. The only subjective part is when you eat it. - Alton Brown.


#8 Leila Burin

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Posted 14 June 2019 - 03:29 PM

Hello, when challenging remember also:

  • personnel uniforms
  • informatics system
  • any closed TAG on RM or FP to be assessed

best regards,

Leila



#9 bob schap

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Posted 01 August 2019 - 01:25 PM

I was hit with a NC for a Food Defense meeting not occurring.  Does this fall into Lack of Verification?  How does everyone record their meetings.  apologies for being a noob here



#10 pHruit

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Posted 02 August 2019 - 08:23 AM

It'll depend a bit on what the nature of the meeting is, and possibly on the expectations of the certification standard involved.

For annual reviews for BRC purposes, we record in almost exactly the same way as for HACCP - the plan contains a defined topic list for the meeting, and the minutes detail the discussion and conclusion under each section. A printed copy is signed by all of the team members and filed with the plan.



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