ILTA comments on mitigation strategies to prevent food tampering
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Cathy Landry
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ILTA comments on mitigation strategies to prevent food tampering


Washington, D.C., August 17, 2020—The International Liquid Terminals Association recently filed comments on the Food and Drug Administration’s supplemental draft guidance for industry on mitigation strategies to protect against food tampering. Many liquid terminals store food products, including vegetable oil and molasses, in their tanks. Read the full comments here. Highlights from the comments can be found below:

  • “ILTA and its members are committed to FDA’s goal of preventing all forms of purposeful contamination.”


  • "ILTA agrees with FDA's proposed approach to allow food defense plans to be individualized for a each facility. Type of product, facility location, company procedures, and other facility details should determine best practices for protecting against intentional adulteration. Facility-specific food defense plans will maximize the overall security of the food supply while minimizing regulatory burdens.”


  • “ILTA is concerned that the supplemental guidance establishes requirements for a food defense plan (intentional adulteration) but that a similar approach is already used in 21 CFR Part 117 for a food safety plan (unintentional adulteration). It would be difficult for a company to integrate both plans, but the proposed guidance implies that there is no choice but to maintain two while separately validating, verifying, maintaining, and creating corrective actions for both documents. FDA should where possible utilize the already existing regulatory framework around food safety plans and incorporate any new or unique requirements for a food defense plan rather than replicating what is already in the food safety plans. FDA could also allow food defense plans to refer to the already vetted and approved food safety plans at individual facilities so long as they meet all requirements.”


  • “ILTA suggests FDA more explicitly state in the guidelines that all portions of the food supply chain carry risks, but that no step is inherently more dangerous than another.”


  • “ILTA agrees with FDA’s requirement that a facility’s food defense plan be kept secured on-site… [but believes] FDA’s requirement that a facility present its food defense plan and other food defense materials within 24 hours is unreasonable.  A period of 72 hours would give terminal operators adequate time to ensure that all materials provided are sufficient, accurate and protected.”



Founded in 1974, the International Liquid Terminals Association represents more than 85 companies operating liquid terminals in all 50 states and in over 40 countries. Our members’ facilities provide critical links between all modes of transportation for liquid commodities, such as crude oil, petroleum products, chemicals, renewable fuels, fertilizer, vegetable oils and other food-grade materials that are central to the U.S. economy. Terminals provide essential logistics services that spur trade both within the United States and connect the U.S. economy with overseas markets. ILTA’s membership also includes about 400 companies that supply equipment and services to the terminal industry.


International Liquid Terminals Association 

Cathy Landry 


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