Food defense programs continue to evolve as the food industry deals with the requirements of the Food Safety Modernization Act (FSMA). Like any new regulatory rollout, there has been a learning curve for both government and industry, as the nuances and sometimes contrasting interpretations of requirements were tested in both directions (business and government) and then modified by the real-world realities that are inherent in the making of the food supply.

The COVID-19 pandemic has substantially affected the food industry in ways not previously anticipated. Where planning assumed as a given that food safety or food defense personnel would always be present, the actualities were often found to be much more complex. Food companies of all sizes and product types have, and continue to experience, COVID-19 cases in real time and probably will be doing so beyond 2022, if the illness becomes seasonal.