Food defence — protecting food from deliberate harm
Plain-language summary
A threat assessment and a food defence plan, built by competent people, integrated into the FSMS and kept current.
What the clause is really asking
Food defence is about intentional contamination — sabotage, extortion, ideologically motivated attack — rather than accidental hazards. Version 7 anchors the requirement to ISO 22002-100:2025 clause 16.2 and adds two things: the people who do the threat assessment and write the plan must have appropriate knowledge and competence (the classic TACCP approach is the usual route), and the plan must be implemented and supported by the FSMS, comply with the law, cover every process and product in your scope, and be kept up to date. Brokers and traders (FII) must additionally make sure their suppliers have a food defence plan.
What auditors look for
Auditors ask who did the threat assessment and what makes them competent to judge insider risk, access control and tampering. They check the plan is referenced from the FSMS rather than sitting in a separate binder, walk the vulnerable points (bulk intake, water, chemical stores, open product), and ask when the assessment was last reviewed.
Typical evidence
Threat assessment (e.g. TACCP) with date and reviewer; competence records for the assessment team; food defence plan cross-referenced in the FSMS; access-control and visitor records; review log after changes or incidents
How to comply — recommendations
Run the threat assessment with a small cross-functional team and record their competence — training, experience or an external specialist. Integrate the plan: link it from your hazard analysis, supplier approval and management review. Review it after any incident, site change or credible external threat, and keep the review date visible.
Common nonconformities
Assessment done by one person with no recorded competence; plan not integrated into the FSMS; scope gaps (a new line or product never assessed); no review since first issue; FII with no supplier food defence evidence
Related clauses
ISO 22002-100:2025 clause 16.2 (food defence); ISO 22000 8.2, 8.5.2 (hazard identification); FSSC 22000 2.5.4 (food fraud)
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