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BRCGS 4.2.1 and 4.2.2 Food Defense

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Posted 14 February 2023 - 08:44 PM

Hi Everyone,

I've been working on our food defense plan for an upcoming BRC audit. I'm a little hung up on 4.2.1 and 4.2.2. We have some documented "food defense" policies that have worked in the past i.e. site security, cameras, some risk assessments for raw materials etc. I get the feeling this isn't going to work moving forward. I've been reading suggestions for the FDA Food Defense Plan Builder; but I'm having difficulty navigating it. For instance, our facility doesn't have any "Key Activity Types" as we just receive nuts, sort and clean them and sell them in bulk. Perhaps I'm missing something? Are there any other templates available that are more intuitive? Any help would be greatly appreciated. 

Thank You,



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Posted 15 February 2023 - 05:37 AM

Hi Marc,


Your key areas on site will be where the product is open, so unpacking, sorting, cleaning and packing areas. Vulnerability of incoming nuts and outgoing product will also depend on the packaging and how secure/tamper evident the packaging is.


4.2.1 is about Understanding/Knowledge/Training

The personnel carrying out the threat assessments and developing food defence plans need to understand potential food defence risks at the site and have knowledge of both the site and the principles of food defence.

For Sites required to register with FDA as a food facility: Qualified individuals undertaking activities related to the preparation of the food defence plan, conducting the vulnerability assessment, identifying mitigation strategies, and performing the plan reanalysis must have successfully completed training for the specific function at least equivalent to that received under a standardised curriculum recognised as adequate by FDA or be otherwise qualified through job experience to conduct the activities.

The Food Safety Preventive Controls Alliance (FSPCA) Intentional Adulteration training is a recognised course.


For 4.2.2 Threat Assessment/Food Defence Plan

BRCGS Global Standard for Food Safety Issue 9 Guidance states:

The company must undertake a threat assessment of the risks inherent to the operation

to prevent malicious intervention. The threat assessment needs to consider both external threats (e.g. individuals or organisations gaining unauthorised access to the site, building or products) and internal threats, such as malicious tampering by staff who are authorised to be on site.

Each area (e.g. warehouses, processing areas and external storage areas) needs to be assessed in terms of how vulnerable the product is to contamination. Sensitive or restricted areas, such as open product areas, are likely to be the most vulnerable; the vulnerability of the packaged product will depend on the nature of the packaging. Details of IT systems and data protection should also be included in the assessment.


Kind regards,



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Posted 15 February 2023 - 03:52 PM

Makes sense. Thank you Tony. 


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Posted 24 February 2023 - 05:08 AM

Did you complete the vulnerability assessment using the KATs? - that should be OK for both BRC and FDA as it is required by both.   


I agree that the FDA food defense plan builder can be difficult to use.   


Something as basic as your operation, i think its fine to use the KAT or the hybrid option.   


the templates for these are in the participant manual.  the link to the manual and training that will help meet the knowledge requirement is below.  


Intentional Adulteration | Food Safety Preventive Controls Alliance (FSPCA) | Institute for Food Safety and Health (IFSH) | Illinois Institute of Technology (iit.edu)

Edited by kingstudruler1, 24 February 2023 - 05:09 AM.




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