The FDA Food Defense Plan Builder can be a pain, but it should be straightforward if you familiarize yourself with it and the FDA Guidance for Industry.
Completed FDA Food Defense Plans should not be shared with anyone outside of authorized personal in the facility except relevant inspectors/authorities, for reasons cited below.
7. Food defense manuals
Customers must now verify that their suppliers are in compliance with regulatory laws and regulations as part of their supplier control programs. They also want to make sure their raw materials are being supplied by a company that has programs in place to protect products from accidental and intentional contamination. If your food defense program or manual is requested will you provide your most guarded security measures? The plant should have two versions of their food defense manual. The facility’s version will be very detailed and confidential. It will likely include private information, such as FDA registration and pin numbers, security guard requirements, and information for sensitive areas. The customer manual will be very general.
For example, the facility version might list how many guards police the property, what they check, when they are present, when the plant is vulnerable, and the mitigation measures during these times. With the new FSMA requirements, FDA inspectors will be looking at specific areas and mitigation strategies. This could also be included in this detailed manual. In the general manual you would simply say you have a security guard program, but not provide detailed information.
Edited by kettlecorn, 28 July 2020 - 04:49 PM.