Food Defense Threat Assessment

Hi All, 

I am in the process of completing updating our SQF to edition 9 and I have noticed that there is a new requirement for doing a threat assessment under food defense. I am just confused on what this exactly is. For years we have been doing a "Food Defense Risk Assessment" annually where we assess how effective our food defense is at our facility and see if anything has changed from the previous year. Auditors never really asked us to look at this but we have been doing it. I am wondering if this will suffice? Or does it need to be something similar to a food fraud vulnerability assessment where we have listed out all of the possible vulnerabilities and how likely they are to occur? Any input or even templates would be greatly appreciated to help explain. 

Thank you!

Chris 

Morning Chris,

Have you updated your FDP to meet the new(ish) FDA requirements for intentional adulteration (IA)? The last group (very small) just passed their requirement date to be compliant. If not, that's probably your first step in this journey.

There are several specific changes required by the FDA for FDP's in that rule that recently went in, one of which is a 'Vulnerability Assessment' with specific requirements for proper completion.

From what I've gathered SQF kind of piggy backs off of that and adds a few more requirements (I believe I recall seeing all GFSI will require a 'test' of their FDP among other things?).

Check this FDA website out if you haven't yet https://www.fda.gov/food/food-defense

Their food defense plan builder isn't bad, and that's what I used to build an FDA compliant FDP. You will want to work that hand in hand with any SQF requirements, and there are quite a few posts on this site where we went over various aspects of the new IA ruling.