FSPCA Vulnerability Assessments

The Mitigation Strategies to Protect Food Against Intentional Adulteration 21 CFR 121 regulation of FSMA (referred to as the IA rule) is aimed at preventing intentional adulteration from acts intended to cause wide-scale harm to public health, including acts of terrorism targeting the food supply. 

The regulation requires creation and implementation of a food defense plan by a “food defense qualified individual” or FDQI who has successfully completed training in the conduct of FSPCA vulnerability assessments. In addition to creation and implementation of the Food Defense Plan, the FDQI is responsible for conducting the vulnerability assessment to identify actionable process steps, identification and explanation of mitigation strategies, and re-analysis of the Food Defense Plan. Vulnerability assessments may be performed using one of three methods: Key Activity Types, Three Fundamental Elements, or the Hybrid Approach. 

Avert’s IAVA course focuses on conducting vulnerability assessments using the 3 fundamental elements and educates participants on the value of the hybrid approach. This course, developed by FSPCA and presented by Avert, is the “standardized curriculum” recognized by FDA; successfully completing this participant course is one way to meet the requirements for conducting a vulnerability assessment by a “qualified individual.” This course is web-based with a live instructor via the ZOOM platform.

Avert’s IAVA course is one of several courses offered by the FSCPA under the IA rule and is the only instructor-led course in the FSPCA’s suite of food defense courses. The other courses are delivered in pre-recorded online formats directly through the FSPCA website. Courses are broken down to allow for role specific training of your staff. You can view these online courses here:

• FSPCA FOOD DEFENSE AWARENESS FOR THE IA RULE
• FSPCA OVERVIEW OF THE INTENTIONAL ADULTERATION RULE (IA RULE)
• FSPCA IA CONDUCTING VULNERABILITY ASSESSMENTS USING KEY ACTIVITY TYPES
• FSPCA IA IDENTIFICATION AND EXPLANATION OF MITIGATION STRATEGIES