Intentional Adulteration


Protecting Food Against Intentional Adulteration.

The FDA Food Safety Modernization Act (FSMA) includes rules for mitigation strategies to protect animal and human food against intentional adulteration.  The rules are designed to prevent wide-scale harm to public health, including through acts of front-line employees or terrorists; they also protect against diluting or mislabeling products for economic motivations.  Although such acts are not likely to occur, it’s critical to implement and enforce mitigation strategies to protect against occurrences that could cause illness, death and economic disruption of the food supply.

Food Defense Plan.

Food and Beverage manufacturers and handlers are required to have a food defense plan to assess and implement risk mitigation strategies and ensure those strategies are working as intended.  The FDA has taken an approach similar to the HACCP food safety system to advance and strengthen safeguards against intentional adulteration of the food supply.  The written plan must identify vulnerabilities and actionable mitigation strategies and procedures for food defense monitoring, corrective actions and verification.  Key components include:

  • Vulnerability Assessment. Identify vulnerabilities and develop actionable processes for each type of food manufacturer, processed, packed or held at a food facility.
  • Mitigation Strategies. Identifying and implementing practices to minimize or prevent vulnerabilities.
  • Mitigation Strategy Management. To ensure the proper implementation of mitigation strategies, food defense plans must include mechanisms for:
    • Monitoring.
    • Corrective Actions.
    • Verification.
  • Training & Record Keeping. Personnel assigned to vulnerable areas must receive appropriate training and proper records for food defense monitoring, corrective action and verification activities must be maintained.

Contact Us to learn more about how Missouri Enterprise can help with your Food Defense Plan, intentional adulteration mitigation strategies and other food safety initiatives.