Food Defense: A Commitment to Your Product, People, and Reputation 

Many in the industry can mistake food defense measures for a simple checkbox on a compliance form, but the cost of such incidents can be devastating.

In 2018, reports of food tampering that involved sewing needles inserted in Australian strawberries wreaked havoc for strawberry farmers across the country, leading to a drop in wholesale prices and serious damage to the reputation of Australian strawberries in export markets.

“Food defense is not just a regulatory requirement. It is a commitment to protecting our product, our people, and our reputation, and training is one of the most powerful tools we have,” according to Anh Tran, Food Safety and Quality Specialist for the Hershey Company.

Tran’s comments came during "How to Develop and Implement an Effective Food Defense Strategy," a webinar hosted by Food Safety Magazine this week that also featured Jon Woody, Chief Science Officer at the National Fisheries Institute.

The Hershey Model: Tiered Training

According to Tran, her company has deployed three distinct levels of training for food defense:

1. General food defense awareness: Mandatory training for all hourly and salaried employees to boost safety culture and vigilance. 
2. Food defense for leaders: Teaches managers how to proactively respond to potential food defense threats.
3. Vulnerability assessment training: The most comprehensive form of company training, involving training from an outside provider and internal training run by Hershey. 

Tran highlighted how it's not enough to merely train for food defense; companies must also document these preventive measures. 

“Robust documentation is the backbone of any effective program. It is important to capture any company-wide (food defense) requirements with documentation to ensure that the facility personnel can comprehend their role for compliance,” Tran said. 

She added that a one-size-fits-all copy and paste approach won’t cut it when assessing the different steps in your food defense plans.

Tran also discussed why companies must apply broad mitigation strategies as part of their approach to food safety and apply practical measures at each step in the production process.

She also discussed Hershey’s “Train the Trainer” approach, in which those who undergo the training help train their colleagues, to “reduce reliance on one trainer, focus on the scalability, enhance employee development, and foster a learning culture.”

During the presentation, Tran also walked viewers through a series of best practices for food defense:

• Identify trusted food defense owners and assign responsibilities, including cross-functional roles (production, maintenance, sanitation, HR, etc.)
• Include walk-through audits to observe and assess operations
• Conduct annual food defense challenges and tests, and keep employees empowered to speak out on areas of concern 
• Establish a food defense forum to foster collaboration and keep food defense owners updated on regulatory news  

Coping with the FSMA Intentional Adulteration Rule 

During his comments, Jon Woody told viewers about the FDA Food Safety Modernization Act (FSMA) final rule for the prevention of intentional adulteration and how companies can meet its guidelines.  

The IA rule applies to facilities that manufacture, process, pack, or hold human food, and domestic and imported food. It does not apply to farms, retail food establishments, or very small businesses with a less than $10 million threshold of human food sales/value.   

Woody, who directed the FDA’s development and implementation of the rule, described how the plan requires companies to develop and implement a food defense plan, which must include:

• Vulnerability assessments 
• Development of mitigation strategies
• Food defense monitoring procedures
• Food defense corrective action procedures
• Food defense verification procedures 

Woody noted that the plan also requires facilities to analyze their food defense plans at least once every three years. 

Woody said he has seen instances “where a company thought they had a complete food defense plan in compliance with the FSMA IA rule. And then we did a little digging and realized that there were sections or parts of sections that were missing.” 

He said this can be more likely to happen with smaller and mid-size companies that are subject to the rule but may not have the resources to develop a food safety plan effectively. 

Like Tran, Woody said that companies “may need to avail themselves of the available training,” in order to prepare their teams to develop and implement food defense plans. He added that the FDA “built as much flexibility into the rule as possible,” and it is by no means a ‘one size fits all’ regulation.”

Regarding the challenges companies face, he said that while the FDA provided flexibility regarding the requirements for vulnerability assessments, “flexibility can introduce some misunderstandings about what needs to be done and what is required to conduct a vulnerability assessment. So we continue to see some challenges around.”

He also noted that common challenges of food defense plan implementation include high employee turnover and the need for new training, verification of camera effectiveness, pushback from employees who don’t want to be monitored at work, and the limited availability of industry examples and case studies due to confidentiality issues.  

What if the call is coming from inside the house? 

Woody noted that one of the difficulties in developing strong food defense plans is that companies often focus more on preventing external threats, as opposed to those coming from within the building. 

“The FSMA IA rule is geared toward preventing the actions of an insider. What we see a lot of times is companies have good facility-wide security measures, security checkpoints for vehicles coming in, exterior doors, locked fencing around the perimeter of the facility, et cetera. Those are all good, solid security measures, but they don't prevent the actions of an insider who may be trying to access a specific process step.” 

He added that training and education are key. 

“What I’ve heard from companies is that training becomes critical to understanding the requirements of the food defense plan and individual employees’ requirements. And when you add in things like employee turnover, training becomes really, really critical.”

If you missed the live feed of the webinar, you can stream it on demand here. To learn more about how Rootwurks Consulting can provide your company with onsite training, strategic consulting, and customized documentation to handle complicated food safety guidelines and build a culture of safety, reach out here.