Jump to content

  • Quick Navigation
Photo
- - - - -

FSMA Food Defense


  • You cannot start a new topic
  • Please log in to reply
3 replies to this topic

#1 BostonCream

BostonCream

    Grade - AIFSQN

  • IFSQN Associate
  • 48 posts
  • 13 thanks
6
Neutral

  • Canada
    Canada

Posted 21 November 2019 - 04:56 PM

Hi all,

 

We are doing FSMA Food Defense gap analysis, and the guideline says below:

 

You do not need to evaluate points, steps, and procedures that are not part of your food operation. For example, you would not consider mail handling procedures, human resources procedures, utilities and processing aids that do not come into contact with or that are not incorporated into the food, facility emergency evacuation procedures, and other business processes.

 

It looks like FSMA only cares about Food Defense at processing steps. They want us to use a HACCP approach to analyze each process step, but do not care about the "traditional" facility defense part (visitor control, mail handling etc).

 

Am I misunderstanding it?



#2 jcieslowski

jcieslowski

    Grade - MIFSQN

  • IFSQN Member
  • 161 posts
  • 55 thanks
23
Excellent

  • United States
    United States
  • Gender:Male

Posted 22 November 2019 - 02:12 PM

I would start by using the FDA food defense plan builder to get a good idea of what they're looking for.

 

https://www.fda.gov/...se-plan-builder



#3 Leila Burin

Leila Burin

    Grade - MIFSQN

  • IFSQN Member
  • 87 posts
  • 28 thanks
5
Neutral

  • Spain
    Spain

Posted 29 November 2019 - 02:19 PM

Hello, as per my understanding, those topics (external fence, training, mail box, etc) are the basic Food Defense elements.

Then, the mitigation assessment (vulnerability/accessibility), is your REAL food defense plan, where you describe mitigation measures as a function of your result

ok?

 

best regards,

Leila



#4 Fishlady

Fishlady

    Grade - MIFSQN

  • IFSQN Member
  • 102 posts
  • 31 thanks
6
Neutral

  • United States
    United States
  • Gender:Female

Posted 01 December 2019 - 07:30 PM

The FDA Intentional Adulteration Rule focuses only on potential food defense issues within the production and bulk liquid storage areas. So FDA would only audit food defense measures related to those areas. It is prudent to take additional measures like gates and monitoring mail, but these are outside the scope of the FDA rule.






0 user(s) are reading this topic

0 members, 0 guests, 0 anonymous users

EV SSL Certificate