Food Defence Procedure

Turn threat assessment into a documented food defence plan

The procedure requires a structured threat assessment to identify potential risks to products arising from deliberate attempts to contaminate or damage them. That assessment considers vulnerabilities within site operations, product exposure points and credible malicious contamination scenarios, including both internal and external threats from personnel, contractors, visitors or external individuals attempting to gain access to products or processing areas.

The output is a documented food defence plan prepared by the Food Defence Team and approved by Technical Management. The plan defines the controls used to prevent or detect malicious interference with products or raw materials, with document control and authorised amendment managed through the Suite’s document-control arrangements.

The procedure also requires the plan to remain aligned with the regulatory requirements of the markets where products are sold or intended to be used. This keeps legal applicability, site vulnerability and operational controls visible within the same food defence framework.

Assign clear responsibility for food defence governance and control

Food defence responsibility is distributed across the functions that govern, implement and use the controls. Senior management provides leadership, resources and organisational support for the implementation and maintenance of food defence controls across the site.

Technical or quality management governs the programme, including the threat assessment and food defence plan. This role reviews control effectiveness, monitoring outcomes and threat intelligence, investigates incidents or vulnerabilities identified through monitoring, review or reported concerns, and initiates corrective action where necessary.

Operations management implements the defined controls in operational areas and supports monitoring and communication of results. The Food Defence Team carries out structured threat assessments, develops and maintains the documented plan, and identifies vulnerable materials, products or locations. Employees are required to follow the controls in their work areas, remain vigilant to potential tampering, malicious contamination or unauthorised access, and report concerns promptly.

Build food defence competence around the site and its risks

The procedure recognises that effective threat assessment depends on personnel who understand both food defence principles and the characteristics of the manufacturing environment in which threats may occur.

Technical Management oversees threat-assessment activity and ensures the Food Defence Team has appropriate knowledge of site operations and relevant food defence risks. Where legislation in the markets where products are sold requires specific food defence training, that training must be completed before personnel take part in threat assessment or food defence planning.

Training requirements also extend to personnel who implement or monitor controls, review food defence risks or investigate potential tampering or product-security concerns. The training content covers food defence risks, implementation and monitoring of plan controls, recognition and reporting of potential tampering or unauthorised access, and escalation expectations where incidents or vulnerabilities are identified.

Control materials, products and areas with increased vulnerability

Where the threat assessment identifies raw materials or products with increased risk of deliberate contamination, the procedure requires the Food Defence Team to define controls within the food defence plan under Technical Management oversight. Where preventive controls alone cannot adequately reduce the risk, the procedure requires controls capable of identifying evidence of tampering so that compromised materials can be detected before entering the food chain.

The same logic applies to vulnerable locations. The food defence plan identifies and documents areas where a significant food defence risk exists, with Technical Management confirmation. High-risk areas include, as a minimum, external storage areas and intake points used for receiving products, raw materials or packaging where access or exposure could enable deliberate contamination.

Operations personnel apply operational controls in defined high-risk areas and monitor those controls to confirm that they remain in place and continue to meet the requirements of the food defence plan.

Keep controls current through monitoring, review and incident learning

The procedure requires routine monitoring of mitigation and tamper-detection controls, with results recorded as evidence that food defence controls are being applied and remain operational. Technical Management reviews the performance of these controls at least annually to confirm that they continue to protect identified vulnerable materials or products and remain appropriate for the risks present.

Food defence planning is not treated as a one-off exercise. Technical Management keeps the plan under review so that changes in site operations, emerging threats or relevant intelligence are assessed. A formal review is completed at least once every twelve months, and the plan is also reviewed when new threat information becomes available or when a product-security or food defence incident occurs.

Where an incident or review identifies weaknesses in existing food defence controls, the procedure links the response to corrective and preventive action. Verification of the implementation and effectiveness of the procedure may also be assessed through the internal audit programme.

Preserve evidence within the FSQMS

The procedure identifies the records that demonstrate food defence operation, including completed threat assessments, the documented food defence plan and revision history, monitoring records, records of identified risks, plan reviews, incident or tampering concern records, and training records for personnel involved in food defence activities.
Those records connect food defence with the wider FSQMS evidence structure. Document control governs the food defence plan, record completion and maintenance govern monitoring and review evidence, corrective and preventive action governs deficiencies, and internal audit may verify implementation and effectiveness.

A food defence procedure within the interconnected Suite

Within the Food Industry Hub FSQMS Policies and Procedures Suite, this procedure provides the operational framework for assessing deliberate contamination risks and maintaining the controls used to protect products, raw materials, premises and vulnerable site locations.

For technical, quality and operations teams, it provides a developed basis for showing how food defence responsibilities, threat assessment, plan approval, vulnerable-material controls, high-risk area controls, monitoring, review and evidence are brought together within the documented management system.