Intentional Adulteration Rule Compliance, Vulnerability Assessment and Food Defense Plans

Food Defense Plans are required under the Food Safety Modernization Act (FSMA) Intentional Adulteration Rule (IA Rule). For more information, view this short training video on the FDA’s Intentional Adulteration Rule.

What you need to do now:

Prepare an IA Rule compliant food defense plan which must include...

  • A written vulnerability assessment
  • Written mitigation strategies, including require explanations
  • Written procedures for
    • Monitoring
    • Corrective actions
    • Verification
  • Training
  • Records

FDA inspections will start in July 2019 where FDA food safety inspectors will conduct phase one “Quick Check” Inspections to confirm that you are aware of the IA Rule and have a food defense plan in place with all of the required components as described above. Read more information on Inspector Violation Reporting Facts.

What BPS can do to get you ready for your upcoming Food Defense Inspection:

BPS has a team of qualified food defense and physical security experts who can facilitate a “key activity type” vulnerability assessment at your site to identify any significant vulnerabilities and actionable process steps as required by law. Our process typically takes 1.5 to 3 days on site (not including prep time) depending on the size and complexity of your operation.

Contact Us! to discuss your IA Rule compliance requirements. We can provide a fixed proposal to you within 24 hours.


    Frank Pisciotta, CSC has been a practicing independent security consultant for over 28 years. Frank has the following relevant education, training and experience:

    • Master’s Degree in Public Administration
    • Bachelor’s Degree in Criminal Justice
    • FSPCA Food Defense certified
    • FPDI Trained/Certified in Food Defense
    • AIB Certified Food Defense Coordinator
    • Achieved Certified Protection Professional with ASIS International in 1994
    • Achieved the Certified security Consultant designation with the International Association of Professional Security Consultants (IAPSC)
    • Conversant with security and food defense requirements of BRC and SQF
    • Serves on ASIS International Food Defense and Agricultural Security Council for over eight years
    • Written hundreds of security plans
    • Conducted hundreds of vulnerability assessments include many under the Bio Terrorism Act of 2002
    • Assisted in the development of the ASIS Security Risk Assessment Guidelines (2015)
    • Conversant with multiple counterterrorism regulations (e.g., FSMA IA Rule, CFATS, MTSA, Pipeline Security, Bio Terrorism Act of 2002, Transportation of Hazardous Materials)
    • Conducting food defense assessment for over 10 years


    • A stronger partnership between security management, quality and food safety personnel
    • Potential enhancements to HACCP process flow charts
    • Practical mitigation strategies to reduce the risk of IA
    • Safeguard against brand integrity matters not addressed by FSMA’s IA Rule
    • Raise security awareness among all plant personnel to prevent a variety of security incidents.

Food Defense Plan Preparation Made Easy

Compliance with the Intentional Adulteration Rule will never be easier.
Contact BPS today to determine how we can work together to comply with the FSMA.
(919) 758-8058