IDFA has played a critical role in the Food and Agricultural Sector Coordinating Council (FASCC), a presidentially mandated partnership between government and the private sector, since the council was formed by the Department of Homeland Security in 2002. The council works to protect the nation's food supply by encouraging communication and planning between the private sector and DHS, the Food and Drug Administration and other government entities and organizations.

Occasionally, the government groups ask council members to distribute information or alerts to their members for widespread coverage. DHS recently extended its current National Terrorism Advisory System Bulletin, a one-pager that details the department’s assessment of the terror threat to the U.S. homeland, and asked council members to share it. The Bulletin, which is different than an alert, is informational and offers ways companies can help, be prepared and stay informed.

This marks the sixth time the Bulletin has been reissued since it first was released in 2015.

Food Defense Rule Compliance

According to John Allan, IDFA vice president of regulatory affairs and international standards, the Bulletin is a good reminder as members shore up their food defense plans before the Final Rule for Mitigation Strategies to Protect Food Against Intentional Adulteration comes into force in July 2019. FDA is expected to issue draft guidance on the rule soon.

Under the rule, which stems from the Food Safety Modernization Act (FSMA), facilities must identify and implement strategies that address significant vulnerabilities, establish and maintain food defense monitoring procedures and corrective actions, maintain records monitoring these actions and ensure that employees are properly trained.

Businesses with 500 or more employees must comply by July 26, 2019, and small businesses, with fewer than 500 employees, will have to comply by July 27, 2020. Very small businesses, that average less than $10 million in food sales per year, will have until July 26, 2021 to comply.

Members with questions may contact Allan at jallan@idfa.org. FDA’s list of Frequently Asked Questions related to this and other FSMA-related rules can be found here.