Food Defense--risk assess it away?

Hello peeps. I'm working in shell eggs now-federally regulated commodity with hefty regulations. Here's today's quandry----I like a simple plan that meets requirements without the "fluff". As everyone knows, shell eggs are easy to spot when they've been damaged (I know, shocker right?!). Can I risk assess away the food defense portion on the PRODUCT and simply ensure the building is secure?  This is a time eater and not value added IMHO. Thoughts? Jokes?  Suggestions?  If I were in the USA, I wouldn't be asking (Canada does not have a "terrorism" requirement). Many thanks

assess away!

We wrote a "simple" plan for an egg facility.

It covers the defenses that are in place - camera system, key cards, chemical lockup, gmps, and all the other good stuff and that was for a company in the US.

It works out fine during the audit too.

Scampi,

From a simply US based perspective, the FDA requires IA plans if you have the following Key Activity Types:

Bulk liquid receiving and loading, liquid storage and handling, secondary ingredient handling, and mixing and similar activities.

So I think, again from a FDA perspective, that you would just have to a Food Defense Plan based upon everything but the product.

Marshall

Hi. 

We are shell egg. I get it, if it's damaged we know it, if it's damaged the machine knows it. 

We have a 'threat assessment plan' which to put it briefly covers the following:

- physical security

- shipping / receiving security

- mail handling 

- general inside security

- storage security 

- chemical control security 

- information security (leaks, adulterated docs)

- employee security 

- non-employee security

- internal security

- economically motivated adulteration 

- it / system 

- security training

- internal transport 

- other plan security 

I know it's an egg, but just because damage / contamination is easily identifiable,you can't presume the risk or motivation is any lower, but that the risk to consumer is lower due to identification before release. Consider staff, malicious contamination, fraud, the outcome is always going to be low with an egg, with motivation is definitely still there especially for such a small profit margin product. I would say our biggest threats (still tiny) are fraud (depends on what production methods you have, e.g. cage, barn, fr, organic) in relation to financial gain and probably staff - all it takes is a peed off member of staff to do something silly.  

It's still a lot to consider although the outcome and plan is very simple

Thanks all

Question to Glenn....did they still test it every year? 

Marshall, we are shell table eggs only----we have other facilities that handle breaking/pasteurizing.  

I should also add, eggs in Canada are quota controlled, we have a very robust tracing system (back to the individual barn and date egg was laid) and we have the obvious controls  (locked doors, security cameras, electronic traceability system etc.)  In Canada, its the egg board that controls movements and we have to report to them based on quota numbers,  they would if something "fraudulent" occurred and that would have to be from a high level employee i.e. the books would have to be altered