What has been your experience on food defense training during audits?

What has been the experience on food defense training during audits? The interpretation of the standard says that the standard is not prescriptive to how knowledge is demonstrated, but could include training - I have heard that some sites are penalised for having no food defense training, but training is not essential if knowledge is demonstrated, correct? We are a small, low risk company. The interpretation and the standard sometimes seem to disagree with each other.

Thanks all!

Hi Mrs. Potter, welcome to the forum! We're a small company too, under FSSC22000. I usually add food defense training to our regular refresh, please see below:

Food Defense

• In case of emergency, call the management. In management absence, call 911
• Report to the Management in case of:
  • Strangers at company facilities
  • Any unusual subjects or smells in production or warehouse
  • Evidence of ingredient or packaging tampering
  • Personnel unusual or suspicious behavior

Apologies, this is a new stipulation for BRCGS version 9. The food defense team is essentially one person since our team is so small. If training is required, it would need to be external, but to me the interpretation and the standard could be read differently.

I have all of our employees watch the FDA's FIRST Line of Defense video and incorporate that into our training via a written quiz. 

We also include some parts of Food Defense into our daily GMP checks I.G. doors remain shut and locked, raw material bags are sealed, etc. 

This has been sufficient for our SQF auditors. 

Although you are in a different country and your regulations may differ, FDA has a program that will help you build a Food Defense Plan. You can browse through and see how you can make it work for you. Always consider inside threats in your assessment as well.  

This is from the site:

The Food Defense Plan Builder guides the user through the following sections:

• Facility Information
• Product/Process Descriptions
• Vulnerability Assessments
• Mitigation Strategies
• Food Defense Monitoring Procedures
• Food Defense Corrective Actions Procedures
• Food Defense Verification Procedures
• Supporting Documents
• Food Defense Plan Signatures

Below is the link:

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

Another resource for a free basic training from FSPCA is listed on the attached PDF.  The password is listed on the PDF as well.  This can give you an idea of what to include or can be used for training some staff members.  There is a certificate at the end.

Hope this helps give a little more insight.

What has been the experience on food defense training during audits? The interpretation of the standard says that the standard is not prescriptive to how knowledge is demonstrated, but could include training - I have heard that some sites are penalised for having no food defense training, but training is not essential if knowledge is demonstrated, correct? We are a small, low risk company. The interpretation and the standard sometimes seem to disagree with each other.

 

Thanks all!

How do you plan to show knowledge of food defense if you don't give any training?

What would the alternative be?

The auditor wants to have evidence that the knowledge is present.

Would you rather show the results of a training or have them interview a random employee and have them pick the one clueless person in the company?

I asked because the interpretation of the standard states the standard is not prescriptive on how knowledge is demonstrated but MAY include training - knowledge can also be demonstrated through experience, knowledge of the site, knowledge of possible risks and the effectiveness of the threat assessment and it's implementation. This is evidence of the knowledge. I'm just asking if the food defense team have this knowledge and do, could a non conformance be issued for no training. No one on the food defense team is the most clueless person in the company.

I don't disagree with your point, but why not do a simple addition of training anyway like Olenazh does?   It takes literal seconds to add it to an annual refresher, and then you're covered no matter what.  

And previous knowledge may or may not cover you.   My mother has been driving cars for 50 years.   Does that mean she knows how to rebuild a carburetor?

And also, if my auditors question an employee, it's rarely someone from the food defense team, or the HACCP team, or whatever.   They question floor employees, sanitation employees, maintenance employees, etc.   They're savvy enough to know a FSTL is going to know the answers.   They're going to ask people they think wouldn't know without being trained.

No one on the food defense team is the most clueless person in the company.

I'm sure that is true, but for food defense to be effective, ALL employees must have the food defense knowledge matching their position.

For example, even though they're not part of the food defense team, warehouse workers should know what to do when they encounter someone they don't know in the warehouse area. Be it from experience or training.

The objective of food defense plan is: TO PREVENT FOOD ADULTERATION. 

What can you do to prevent food adulteration and food defense in your company? Below are some ideas: 

a. Preventive measures:

1. Employee training on food defense and food adulteration
2. choose verified and reputable suppliers
3. Improve entry measure to the facility (visitor log, temporary badges, visitor escorting, visitor training) 
4. Use technology to detect any tampering incidence or intention (camera's/CCTV)
5. Control the outside of the facility
6. Control delivery vehicles (seals, cleanliness, driver(s) background check)

b. Reactive measures

1. Measures or procedures if food adulteration is detected (product withdrawal, recall and safe disposition)
2. Change of supplier/driver(s) or delivery company