Pro Tip: Following these four preliminary steps to develop a food defense plan can help bakeries meet regulatory requirements.

As per the Food Safety Modernization Act (FSMA), every domestic or foreign facility that is required to register with the Food & Drug Administration (FDA) — unless exempted from the regulation or sections of the regulation 21 CFR 121 — must implement food defense measures to protect food against intentional adulteration.

The Global Food Safety Initiative (GFSI) also includes food defense measures in its benchmark requirements.

Therefore, companies must have a documented food defense plan that includes a vulnerability assessment, mitigation strategies, monitoring procedures, corrective actions, records and training.

Before you start working on your food defense plan, it is recommended to start with these preliminary steps. They are not mandatory requirements but will contribute to the process:

1. Assemble your food defense team: Make sure to include a multi-disciplinary team with different backgrounds and experiences. The team should be led by a Food Defense Qualified Individual, a role required by FSMA. Team members from quality assurance, maintenance and human resources should also be represented.

2. Describe the product under evaluation: Include details such as consumer profile, serving sizes, production, distribution process, ingredients, product name and intended use. If you have already developed a food safety plan, you could leverage this information.

3. Develop a process flow diagram: You could create one specifically for food defense or leverage your existing flow diagram that’s used for food safety plans.

4. Describe the process steps under evaluation: When describing each process step, consider focusing on potential access and/or the ability of an adulterant to be added without being detected and/or observed.

Having a food defense plan will allow you to meet regulatory requirements and will also get you ready to protect food from intentional acts of adulteration.

Earl Arnold is manager and food defense/FSMA expert at AIB International.