The rule mandates facilities adopt a process approach, similar to Hazard Analysis and Critical Control Points, or HACCP, when creating the required food defense plan. A vulnerability assessment must be conducted to identify weaknesses and actionable process steps. Mitigation strategies are developed for each actionable process step to minimize and prevent identified vulnerabilities. Mitigation strategies must include procedures for monitoring, corrective actions when strategies are not properly implemented, and verification activities to ensure monitoring is conducted as required and is effective. Employees must be appropriately trained and records of the monitoring, corrective actions, and verification activities must be maintained. At a minimum, the food defense plan must be reanalyzed every three years.
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Explore This IssueApril/May 2017
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From rules governing beer in 1700 B.C. to the seven foundational rules of FSMA enacted in 2011, government and commerce have worked together to create food safety regulations and best practices for protecting human health.
Thoma, a food safety and quality professional with nearly 20 years of experience in food manufacturing and food safety auditing, has worked for NSF International for four years as both a GFSI certified auditor and as a technical specialist in the Supply Chain Food Safety group. Reach her at firstname.lastname@example.org.