The aim of a food defense plan is to identify how your food business is going to protect food from acts of intentional adulteration. However, like most contingency planning, the identification of potential risks and strategies for control are just one part of a robust system. In this post, find out the other key elements required to ensure the success of your food defense plan.
The key elements of a robust food defense plan are:
The focus of this post is on verification activities related to the review process, internal auditing and challenging the system. If you are interested in learning how to document and implement your food defense plan, please click here.
If you have 3rd party GFSI certification in your business, there may be a requirement to both review and challenge your food defense plan, but what is the difference?
The review process means that you are checking to see that all information contained within the plan is still current. For example, contact details, management positions, includes all compliance requirements, site plans, hazard risk levels etc.
The process of ‘challenge’ means that you are testing the effectiveness of your written food defense plan.
The most common way to challenge your food defense plan is by setting up scenario of seeing how far you (or a designated representative) can penetrate the system. A big part of challenging the system is seeing how your own staff react to an unfamiliar person or unusual situation. Do they follow reporting procedures? Do they question intruders? As an auditor, I have been requested by management to see how far I can penetrate their system unaccompanied.
In some cases, after you have ‘challenged’ the food defense system, you may find that what you have written as a strategy for control or prevention is not actually effective in meeting the overall mission.
A common question I get asked is “Isn’t challenging the system the same as completing an internal audit?” The best way that I can answer this question is to explain the internal audit context in this situation.
The process of ‘audit’ is when you are checking to see that what you have documented within your food defense plan is actually being implemented. For example, are all external doors locked, is the perimeter fencing not damaged, are people only in their designated areas or maybe have all visitors signed-in.
During both the internal audit and challenge verification activities, you might find that staff re-training is required. To help staff understand the importance of food defense check out this online training.
How have you challenged your food defense plan? Share your experience and knowledge with the HACCP Mentor community by leaving a comment below this post.