Feeling uncertain about mitigation strategies? You're not the only one! There have been major changes in how the issue is approached from the proposed to the final FSMA rule. When the FDA issued the proposed rule on intentional contamination they initially defined two different types of mitigation strategies: broad and focused.

Broad mitigation strategies encompassed several distinct areas including physical security, personnel security, securing hazardous materials, secure management practices, and crisis management planning. 

Focused mitigation strategies were defined as specific to an actionable process step in a food operation where a significant vulnerability is identified, including appropriate measures necessary to reduce the likelihood of intentional adulteration. These strategies were customized to the processing step at which they are applied, tailored to existing facility practices and procedures, and dependent on an evaluation of the significant vulnerability associated with the actionable process step at which they are applied.

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