AIB Answers

Q.  We will be undergoing a third-party audit this year. One of the criteria of the audit is to have a trained food defense coordinator. Does the food defense coordinator have to be located on-site, or can this be a contracted person?

A. Let me answer this question on a couple of different fronts. First, I am not aware of any standards that require a food company’s food defense coordinator (FDC) to be a full-time or permanent employee of the company. As long as the individual is qualified and is able to direct the efforts of the food defense program and food defense team, this should meet the intent of the audit criteria.

However, from a practical standpoint, I would encourage your company to take a detailed look at how this would be managed and if it is practical to use a contracted individual that is not part of the operation on a regular basis.

A food defense coordinator is responsible for leading the efforts in establishing a food defense team, conducting vulnerability assessments, developing a food defense plan, training personnel on food defense initiatives, and managing daily food defense-related issues.

Food defense issues can happen at any time for any operation and your company and food defense team need to be prepared to respond to these events. I typically encourage companies to identify multiple FDCs so they have coverage at the facility on a 24/7 basis. There can be a lead FDC and other individuals identified as back-ups when the lead is not available.

FDCs may have to deal with a variety of issues from theft, intentional product contamination, workplace violence, threats, sabotage, etc. It would be in the best interest of any food company to have an on-site FDC that can immediately respond to and provide direction for such issues. That may be a challenge if a company is using a contracted individual that is not present.

Bottom line, your company needs to evaluate the complexities of your food defense program and determine how you can best manage it. 

Do you have a question for Lance Reeve? If so, e-mail him at lreeve@aibonline.org.

CORRECTION:
The author for the March/April ICE Chips article was Al St. Cyr, Industry Consultant.