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4 Critical First Steps to a Successful Food Defense Plan

Updated: Apr 16, 2021

By: Forward Food Solutions Team

Date Published: 4/12/21

The term “Food Defense” is common jargon amongst most people in the Food Safety industry. Unfortunately, it can get “tossed around” casually, without understanding the deeper dynamics, ramifications, requirements, and overall impact it has on the success of the company.

So, what exactly is Food Defense?

And why is having an established Food Defense plan in your facility important?

In this article, we’ll cover the “what, why and how” when it comes to understanding the role of Food Defense in your food safety systems as a recipe for success.

What is Food Defense?

Modern food supply chains are becoming increasingly large and complex. Trade is no longer conducted exclusively with the neighboring supplier; instead, modern companies are sourcing ingredients from across the globe.

Did you know that just one ingredient can be sourced from multiple suppliers who are located in different countries? And the more ingredients in a single product means that more countries tend to be involved.

While this is not inherently problematic, it does come with risks and it is the job of both Food Safety and Food Defense Plans to address them. The key difference in the way each addresses these risks lies in one thing: motivation.

Intentional Adulteration Rule (IA Rule)

The FDA defines Food Defense as: “The protection of food products from contamination or adulteration intended to cause public health harm or economic disruption”.

Food Defense comes into play when the goal is to intentionally cause harm to the public.

Two of the more common IA threats include, but are not limited to:

  • Intent to Contaminate Food as Acts of Terrorism with Political Motivation

One of the risks for IA is the potential for terrorism. The attacks on September 11, 2001, made it clear that there are individuals out there who want to harm U.S. citizens and the food supply chain is vulnerable. After all, everyone needs to eat, which means a contamination event could affect many people.

  • Intent to Contaminate Food to Cause Harm to the Public in Order to Damage a Company’s Brand

Disgruntled employees are a potential risk when it comes to IA. As recently as 2018, Australian strawberry growers were impacted when an employee placed needles in strawberries. This resulted in injuries and a significant amount of strawberry inventory loss due to disposal mandates.

4 Critical First Steps to a Successful Food Defense Plan

While the FDA has determined that companies need to address the risks laid out above, the expectations of which companies fall under the Intentional Adulteration Rule (IA Rule) are different.

So, here’s what you need to know in order to determine what the FDA expects of your company:

1. Identify whether your company is required to have a Food Defense Plan

The size of your company is an important factor when determining which regulations apply. Click here to find out where your company fits into the complex compliance puzzle.

2. Make sure you know the compliance date that applies to your company.

Again, the size of your company plays a key part, so ensure you know where your company stands. For example:

  • Very Small Businesses - July 26, 2021

  • Small businesses (defined as business with fewer than 500 full-time equivalent employees) - July 27, 2020

  • All other businesses - July 26, 2019

Once you have determined whether your company falls under the IA Rule regulation, it is important to get informed and proactively implement a rock-solid Food Defense plan.

3. Good training

Training is the foundation you need to ensure your Food Defense plan is implemented in an efficient and effective way. There are training materials available online as well as more in-depth, on-site trainings available.

4. Commitment

At the end of the day, a Food Defense system only works if you have invested the time and effort accordingly. It is critical for companies to invest in their Food Defense plans, without exception, because the risks are high when the food supply is not protected properly.


It is important to remember that, while Intentional Adulteration (IA) is relatively rare, the potential effects of a successful attack of sabotage or terrorism on the food supply could be devastating in a variety of ways.

Not only does it result in loss of public trust, but it also damages the economy, creates financial loss for companies and impacts victims who have encountered or consumed the dangerous food supply.

Therefore, it is important for companies to have robust Food Defense Systems in place. Forward Food Solutions is equipped with 20+ years of experience to help your organization with their Food Defense Plan, whether you’re starting from scratch or need a tune-up to your current Food Defense Plan, we can help you reduce your risk.

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Keywords: Forward Food Solutions, Food Safety Consulting, Food Defense, Contamination, Regulation, Food Service, Food Safety Industry, Food and Drug Administration, FDA, Intentional, Adulteration Rule, Adulteration, Compliance, Training, Sabotage,Terrorism

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