Food Defense Plans

“Food Defense” is the term used by FDA for food protection activities
against intentional adulteration.

Food companies have to develop a vulnerability assessment plan and define mitigation procedures.


This plan is necessary for the risk assessment , with a series of points to be checked in the production chain, according to Codex Alimentarius principles.

The FDA Food Safety Modernization Act (FSMA) added new sections to the Federal Food, Drug and Cosmetic Act referring to food intentional adulteration, implementing these provisions through a standard called “Mitigation strategies to protect food from intentional adulteration” ( AI standard ).

The AI standard applies to the owner , the operator or the agent responsible for a food facility that manufactures, transforms, packs or holds food for its intended consumption in the United States .

There may be several acts of intentional adulteration: they can be destined to cause large-scale damage to public health (e.g. terrorist acts focused on food supply), or be acts of employees disgruntled , consumers, competitors, or economically motivated adulterations (EMA) .

Analyzing risks about intentional adulteration of food, attacks intended to cause damage to public health on a large scale are classified as the highest risk. Therefore, the IA standard focuses on dealing with these acts and not those of disgruntled employees, consumers or competitors.

The FDA document is aimed at manufacturers subject to the intentional adulteration requirements (IA) of 21 CFR, part 121 . The identification of significant vulnerabilities in the structure and the implementation of a mitigation strategy allows the company to apply a proactive and systematic approach to the food defense program.

The FDA guideline draft represents the Organization’s current thinking. However does not establish obligations, and is not binding . An alternative approach can be used if it meets the requirements of the applicable statutes and regulations.


We support food companies in the implementation of an effective Food Defense plan, through the most appropriate methodology and with targeted verification inspections.

A well prepared Food Defense plan allows the company to prevent sabotage or potential production chain dangers.

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