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Download Intentional Adulteration and Food Defense Inudustry Preparedness Report Here

The Mitigation Strategies to Protect Food Against Intentional Adulteration Rule (IA Rule) of the Food Safety Modernization Act (FSMA) is the first regulation requiring food facilities to train employees in food defense and develop a Food Defense Plan (FDP). With the first compliance date of July 26, 2019 quickly approaching, The Acheson Group (TAG) and the Food Protection and Defense Institute (FPDI) collaborated on a survey of food industry representatives to determine the extent of the food industry’s knowledge about, and preparedness for, the IA Rule.

The assessment of the 184 responses from self-identified food processors, manufacturers, and distributors who responded to the survey revealed several trends in the companies’ food defense training needs, occurrence of intentional adulteration incidents, and knowledge and use of Food Defense Plans, as reported in the TAG/FPDI Intentional Adulteration & Food Defense – Industry Preparedness Report(PDF).

A majority (71%) of these respondents hold roles typically associated with responsibility for overseeing and implementing food safety regulations. Additionally, they represent a fairly equal distribution of company size, with small companies (fewer than 100 employees) representing 38% of respondents: medium (100-500 employees), 26%; and large (more than 500 employees), 37%.

Key takeaways from the survey included:

  • 77% of the respondents who said their company is covered by the IA Rule were fully aware of the rule’s requirements, with 92% at least partially aware. Of those same respondents, 78% were aware of the IA Rule Draft Guidance. And, of those, 62% had reviewed or commented on it. This indicates that a significant number of facilities would benefit from additional education about the IA Rule.
  • While only 8% of the respondents stated that their organizations had experienced an IA incident, the vast majority of those took steps to prevent a recurrence by retraining employees (87%) and/or revising their Food Defense Plan (73%),
  • About 80% of those who responded that they have a Food Defense Plan had it in place prior to the release of the IA Rule and, of those, about half have not updated it or developed a new one. This indicates that many facilities may not have a Food Defense Plan that meets the requirements of the IA Rule.
  • The IA Rule requires specific training for various roles in the food facility. While more than three-fourths (78%) indicated conducting employee awareness training, only about half (52%) had employees attend Food Defense Plan training.

“Such statistics from the TAG/FPDI survey indicate that the food industry has conducted some work toward food defense, but many still have a ways to go to be compliant with the IA Rule – and to ensure they are protecting themselves from the risk of intentional adulteration,” said TAG President and CEO David Acheson. “Our goal in conducting the survey and its assessment was, not only to determine industry awareness and practices, but to provide relevant recommendations for both developing and assessing one’s food defense program and plan.”

“Understanding the food industry’s current level of preparedness helps identify gaps that can be filled through educational programs,” said FPDI Associate Director Jennifer van de Ligt. “As the leader in food defense education, FPDI offers many programs to help the industry understand the IA Rule and gain the knowledge to draft Food Defense Plans.”

About FPDI

Food Protection and Defense Institute’s research, innovation, and education program is aimed at reducing food system disruption. With a keen eye for disruption, FPDI focuses on reducing the potential for contamination at any point along the food supply chain and places a high priority on addressing potential threats to the food system that could lead to catastrophic damage to public health or the economy. Contact FPDI at

About TAG

Led by Former FDA Associate Commissioner for Foods Dr. David Acheson, TAG is a food safety consulting group that provides guidance and expertise worldwide for companies throughout the food supply chain. With in-depth industry knowledge combined with real-world experience, TAG’s team of food safety experts help companies more effectively mitigate risk, improve operational efficiencies, and ensure regulatory and standards compliance. Contact TAG at


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