The proposed FSMA rule for intentional contamination uses the phrase "a person knowledgeable about food defense" in several places. What it doesn't tell you is how to choose a consultant (internal or external) with these capabilities. This blog article explores how to find a provider for your food defense plans.
That phrase, or a similar one, "prudent and knowledgeable about food defense," are used in several contexts. These include the person selecting targeted mitigation measures, the person training employees responsible for implementing targeted mitigation measures, and the person performing a vulnerability assessment.
Note that a vulnerability assessment is not required if the facility chooses to identify "actionable process steps" based on the four identified key activity types. This is a topic of a previous blog: 2 ways to look at vulnerability assessments (Part 1)
The FDA has requested comments on how to determine if a person is "knowledgeable about food defense." By the time the final rule is published, there could be consensus on this question. In the meantime, we offer this suggestion for your consideration:
Ask for a biography, CV, or resume from the employee or service provider you intend to use for your food defense work. Compare it to the 10 attributes detailed below. Just as Important, attach the bio to your food defense plan and training documents so you can justify and document your selection.
Does your provider have a degree related to food defense? This may be the least critical attribute today, but I believe it will take on growing importance in the years ahead. There are now a small number of degree programs concentrating on food defense, or food safety programs with significant food defense components.
What these (mostly young) people don't yet have is much industrial experience. That will come with time, and the best programs include exposure to industry.
Is your provider certified in food defense? There are very few certification or credential programs in food defense and nothing that is universally recognized. Where provided by a recognized and reputable organization this can serve as a good indicator of at least basic education.
Some providers may show you a certificate of completion of some workshop or seminar. This is helpful so far as it goes, but attendance does not necessarily imply mastery of the subject.
How long has your provider been working in food defense? The FDA began work in this field soon after 9/11/2001. The earliest guidance documents date to about 2003, so it is unlikely to find someone with more tenure than that. With a proposed rule out, there may be some newcomers that hope to leverage their related food safety or general security businesses.
Is your provider an authority on the subject? Have they authored any book, chapter, or white papers on the topic? What about magazine or blog articles? Are these publications well read and referenced by others? If you search online for this person's name and "food defense," do you get any results?
Is your provider up to date? Have they read the proposed rule cover to cover? What recent events, presentations, or forums have they participated in? Do they contribute to online discussion groups, newspaper interviews or recent blogs?
Does your provider train others? Do they teach workshops and webinars? How often, what topics and are they In demand? Who are they doing the training for?
Is your provider sought after as a speaker on the topic of food defense at industry conferences and forums?
Has your provider contributed to the body of knowledge in food defense? Authoring, training and speaking, as mentioned above, all demonstrate contribution. Have they also contributed to new tools, methods or approaches in food defense? Have they contributed to expert panels, focus groups and testing of methods?
Has your provider created a number of food defense plan and conducted many vulnerability assessments. Are they competent with the use of the CARVER Plus Shock software and the Food Defense Plan Builder tool? Have they participated in table-top response exercises?
This is perhaps the most important measure. How long have they worked in the factory environment and are they familiar with the kinds of unit operations that make up your operation? Since the focus of the proposed rule is on specific process points (actionable) and the focused mitigation measures to address those points, a strong familiarity with food processing is critical.
While it is unlikely that any potential provider can affirm every one of these attributes, the one that claims only one or two may be underqualified. Interview prospective providers against this list and establish some threshold you can justify (5, 6, 7?). Document your selection process. Then you should feel comfortable that you have indeed found someone "prudent and knowledgeable in food defense."