Key Takeaways:
- A breach that manipulates or erases monitoring records can jeopardize compliance under the FSMA and turn safe product into suspect product.
- The average cost of a data breach is multimillion-dollar, with U.S. incidents being the most expensive globally—this does not account for recalls, scrap, and downtime.
- Aligning HACCP procedures with cybersecurity controls at digital critical control points is essential for both compliance and innovation.
Understanding the Cyber Risk in Food Safety
The Hazard Analysis and Critical Control Points (HACCP) system, along with the Food Safety Modernization Act (FSMA), aims to prevent potential hazards in food processing. However, today’s modern risks must include concerns about data integrity.
For example, if a cybercriminal alters temperature readings or disables sensors, this could lead to undetected deviations in the manufacturing process—a serious risk for food safety and compliance.
The Financial Impact of Data Breaches
According to IBM’s 2025 Cost of a Data Breach report, the global average cost of a data breach stands at $4.44 million, with the U.S. average soaring to $10.22 million. Most organizations experience operational disruptions and often take over 100 days to fully recover.
Interestingly, those employing AI and automation in security report an average cost saving of $1.9 million—suggesting that proactive investments in detection and response yield significant dividends.
Cyber Threats Targeting Food Manufacturing
According to Verizon’s 2025 Data Breach Investigations Report, the manufacturing sector faced 1,607 confirmed breaches, with organizations having fewer than 1,000 employees comprising over 90% of incidents. The rise of espionage-motivated attacks further complicates matters, threatening the intellectual property involved in recipes and formulations.
The Rising Trend of Food Recalls
While total recalled units saw a decline in Q2 2025, the number of recall events surged to 861, the highest total in over a year. These incidents demand extensive mobilization and create a reputational burden, even when individual volumes are smaller.
Cybersecurity as a Compliance Issue
Here are three common scenarios illustrating how cyber vulnerabilities intersect with HACCP compliance:
- Thermal Process Spoofing: Altering temperature readings during pasteurization creates a false sense of safety regarding food safety measures.
- Historian Tampering: Deleting environmental data can obscure vital monitoring periods, leading to regulatory scrutiny.
- Supplier Portal Breaches: Compromised supplier data can introduce unverified allergens into products, significantly increasing recall risks.
Protecting Your Innovation and Strategic Risks
The food manufacturing sector’s digital transformation, including the adoption of AI models and digital twins, introduces new cyber risks. A staggering 13% of organizations reported breaches involving AI, with 97% lacking adequate access controls.
Making Critical Control Points Cyber-Aware
It’s crucial to integrate cyber-awareness into each critical control point (CCP). This involves creating a digital critical control point (dCCP) aligned with HACCP procedures to mitigate cyber risks effectively.
Action Steps for Cyber Resilience
Here are five actionable steps for fortifying your cybersecurity framework within 90 days:
- Protect Monitoring Records: Implement tamper-evident logs and dual acknowledgments for deviations.
- Map Your Operational Technology (OT): Establish accurate asset inventories and segment networks to enhance security.
- Instrument Verification: Introduce independent verification sensors on critical monitoring lines.
- Conduct Tabletop “Cyber-Recall” Drills: Collaborate across teams to prepare for potential cyber-related recalls.
- Secure AI Utilization: Enforce strict access controls for AI systems that impact quality assurance.
Policy Frameworks to Codify
- A formal rule that states losses of trustworthy monitoring records trigger risk assessments.
- A “clean room” recovery protocol for OT systems.
- Data integrity clauses for suppliers requiring tamper-resistant certifications.
Essential Leadership Focus Areas
- The cost of breaches is escalating in the U.S., necessitating heightened focus on cybersecurity.
- Manufacturing vulnerability has intensified, with increased ransomware-related incidents.
- Regulatory expectations for digital traceability are rising—steps to ensure integrity must be taken promptly.
Frequently Asked Questions
Q: Can a cyberattack really create a FSMA violation?
A: Yes, tampered monitoring data can trigger compliance issues and lead to possible recalls.
Q: What does a “good enough” OT security look like for food manufacturers?
A: Basic security should include accurate asset inventories, network segmentation, and multifactor authentication.
For every known hazard in your HACCP, diligently examine potential digital failure modes that could obscure risks. In doing so, you’ll enhance not only cyber resilience but also food safety and brand trust.