Pro Tip: Performing a vulnerability assessment to meet regulatory, Global Food Safety Initiative (GFSI) and brand protection requirements can be challenging in any industry.
Consider these three elements when choosing a food defense method and conducting an assessment:
- Understand the requirements that need to be covered: Under the Food Safety Modernization Act , each Food and Drug Administration (FDA)-registered facility, unless exempted, must create and implement a food defense plan. A vulnerability assessment must be completed by a qualified individual, and mitigation strategies must be implemented if significant vulnerabilities are identified. GFSI requires a food defense threats assessment to identify potential risks and prioritize food defense measures.
- Understand the method to conduct a vulnerability assessment: GFSI does not stipulate any specific requirements for threat assessments so facilities can decide what process works best for them. Meanwhile, the FDA defines specific requirements, including consideration of chemical, biological, physical and radiological contaminants that can be used to intentionally adulterate products. Moreover, you will need to determine the severity of the impact on public health, the amount of physical access to the product and the ability to successfully contaminate the product.
- Choose the best option: To meet GFSI or FDA requirements, training and experience are key factors. Training for vulnerability assessments currently ranges from a few hours to a few days, depending on the methodology. The Key Activity Type (KAT) method is quick and easy for conducting vulnerability assessments while the Carver Plus Shock Method is more complex.
Earl Arnold is manager, food defense/FSMA at AIB International.
