Actionable Process Steps and Focused Mitigation Strategies

http://www.fda.gov/fsma

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Actionable Process Steps

• Defined as:– “a point, step, or procedure in a food process

at which food defense measures can be applied and are essential to prevent or eliminate a significant vulnerability or reduce such vulnerability to an acceptable level.”

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History of FDA Vulnerability Assessments

Using Vulnerability Assessments to Identify Key Activity Types

• Distill individual processing steps down to the basic activity being conducted– Standardize diverse processing steps for

analysis

• Use information gathered in vulnerability assessments to target mitigation strategies to most vulnerable areas

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Using Vulnerability Assessments to Identify Key Activity Types

• Results of this analysis show:– Certain processing steps repeatedly ranked

high across vulnerability assessments, regardless of food

– Focus on the activity being conducted at high ranking processing steps

– Common vulnerabilities can be organized into broad activity groups = key activity types

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Proposed Requirements

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Key Activity Type I: Bulk Liquid Receiving and Loading

• Likelihood of uniform mixing (sloshing and turbulence)

• High volume of food is at risk• Activity where an “outsider” could gain

access (e.g. truck driver)

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Key Activity Type II:Liquid Storage and Handling

• Likelihood of uniform mixing – Tanks are frequently agitated

• High volume of food is at risk – Especially in bulk storage or ingredient

metered tanks• Frequently located in isolated areas,

increasing the likelihood an attacker could gain access without being observed

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Key Activity Type III:Secondary Ingredient Handling

• Likelihood of uniform mixing– ingredient handling is likely immediately prior

to a mixing step

• High volume of food is at risk• Ingredients are open and accessible

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Key Activity Type IV:Mixing and Similar Activities

• Likelihood of uniform mixing • High volume of food is at risk• Food is typically accessible• Extended mixing times may present

opportunity for the attacker to “choose the best moment” to introduce a contaminant

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Sample Processes not Considered Key Activity Types

• Conveyer belts, augers, flumes, etc.• Bulk storage of dry ingredients• Finished ingredient storage (containerized)• Packaging• Baking, frying, pasteurization, etc.• Dry ingredient receiving/loading• Frozen storage

Perform a Facility-Specific Vulnerability Assessment

• Perform a vulnerability assessment using appropriate methods and qualified individual(s)

• Identify and prioritize points in food operation that are vulnerable to intentional adulteration

• Identify actionable process steps for significant vulnerabilities

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Elements of a Facility-Specific Vulnerability Assessment

• Evaluate agents of concern• Assemble vulnerability assessment team• Develop process flow diagram

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Elements of a Facility-Specific Vulnerability Assessment cont.

• Identify significant vulnerabilities, consider:– Public health impact– Downstream processing– Physical access to product– Ability of aggressor to contaminate product– Volume of product impacted

• Identify actionable process steps

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Actionable Process Steps

• Requirements:– Identified using key activity types, or– Identified by vulnerability assessment– Identification and assessment must be written

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Proposed Requirements

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1. Actionable Process Steps

Option 1

Option 2

Assess whether your facility has one or more of these FDA-identified key activity types*:1. Bulk liquid receiving and loading2. Liquid storage and handling3. Secondary ingredient handling4. Mixing and similar activities

Identify actionable process steps for each applicable key activity type

Perform a vulnerability assessment using appropriate methods and qualified individual(s)

Identify actionable process steps for significant vulnerabilities

Identify and prioritize points in food operation that are vulnerable to intentional adulteration

2. Focused Mitigation Strategies• Identify and implement focused

mitigation strategies at actionable process steps

3. Monitoring• Establish and implement procedures

for monitoring focused mitigation strategies

4. Corrective Actions• Establish and implement procedures

for corrective actions if focused mitigation strategies are not properly implemented

5. Verification• Verify that monitoring is conducted• Verify that appropriate decisions

about corrective actions are made• Verify that focused mitigation

strategies are consistently implemented and are effective

• Conduct reanalysis of the food defense plan, as appropriate

*FDA identified these key activity types using findings of vulnerability assessments of over 50 food products and processes.  These activity types commonly rank high in vulnerability based on various factors, including the ability to physically access the food or process and the potential to adulterate a sufficient quantity of product in order to cause massive public health harm. 

Focused Mitigation Strategies

• Defined as:– “those risk-based, reasonably appropriate measures

that a person knowledgeable about food defense would employ to significantly minimize or prevent significant vulnerabilities identified at actionable process steps, and that are consistent with the current scientific understanding of food defense at the time of the analysis”

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Focused Mitigation Strategies

• Applied in response to an identified significant vulnerability– Customized to the actionable processing step– Tailored to the facility– Depend on an evaluation of vulnerabilities

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Types of Mitigation Strategies

• FDA categorizes mitigation strategies into two buckets: – Broad mitigation strategies: general facility-

level measures not necessarily specific to the product or process, for example:

– Exterior fencing, periodic employee drug testing, visitor sign-in procedures, cyber-security, contractor or supplier audits

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Types of Mitigation Strategies cont.

– Focused mitigation strategies: • Specific and customized to the actionable

processing step where they are applied.• More effective at countering an attacker

who has legitimate access to the facility

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Mitigation Strategies

Broad• Facility or company

level measures• Broadly applied• Almost universally

applicable• Not required, though

still recommended

Focused• Specific measures

applied at an actionable process step

• Tailored to address an identified significant vulnerability

• Required under Proposed §121

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Focused Mitigation Strategies

• FDA giving facilities flexibility to determine appropriate focused mitigation strategies

• Preamble to Proposed §121 provides:– Examples of focused mitigation strategies for

reference and context for each key activity type– A series of hypothetical scenarios to illustrate the

decision-making process of identifying and determining appropriate focused mitigation strategies

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Focused Mitigation Strategies

• Designed to minimize chances of intentional adulteration at the specific process step by:– Minimizing the accessibility of an attacker to

the product– Reducing the opportunity for the attacker to

successfully contaminate the product– Or both

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Focused Mitigation Strategies Examples

• Control access to the actionable processing step and related equipment– Limit staff access, lock access hatches,

physical barriers

• Ensure the area is free of unrelated materials– Prohibit and monitor employees for personal

items in work areas

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Focused Mitigation Strategies Examples cont.

• Maximize visibility around actionable process step– Improve lighting or install cameras intended to

prevent an attacker from adding a contaminant

• Peer-monitoring or “buddy system” procedures– Prevents an attacker from operating in

isolation

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Focused Mitigation Strategies Examples cont.

• Make engineering enhancements to equipment– Install lids or other barriers to prevent

introduction of a contaminant• Reduce time products and ingredients are

accessible– Reduce the opportunity for an attacker to

introduce a contaminant

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Focused Mitigation Strategies Examples cont.

– Conduct inspections of equipment immediately prior to use• Inspections increase chances of detecting a

contaminant in tanks, hoses, and other equipment

– Use automated, self-contained, enclosed equipment• Prevents introduction of a contaminant into

the system

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Focused Mitigation Strategies

• Facilities will need to evaluate their situation to understand why and how their actionable process steps are significantly vulnerable– May be different in every facility

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Focused Mitigation Strategies

• Facilities would then need to identify and implement the appropriate focused mitigation strategies to reduce the significant vulnerabilities

• Document this decision and provide justification for how the strategy significantly reduces or eliminates the risk of intentional adulteration at the actionable process step

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Focused Mitigation Strategies

• Focused mitigation strategies must be:– Documented in the food defense plan with

justification– Monitored for consistent application, with

corrective actions as necessary• Monitoring procedures must be documented

– Verified to confirm they are implemented as planned through a review of records and periodic re-analysis of the food defense plan

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Focused Mitigation Strategies

• When identifying and implementing focused mitigation strategies, consider:– Do you already have a procedure in place that

protects this process step? – Modify or improve an existing practice?

• FDA tools and guidance to assist in identifying suitable and appropriate focused mitigation strategies: http://www.fda.gov/food/fooddefense/

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