FIC Article - Preventive Controls for Human Food (PCHF) Compliance
Does PCQI Training Expire? Do You Need Refresher Training?
April 4, 2026
If your facility manufactures, processes, packs, or holds food for consumption in the United States, you’ve likely come across the requirement for a Preventive Controls Qualified Individual or PCQI. While the term is widely used, there is still a lot of confusion around what the requirement actually is, who needs to be a PCQI, and whether formal training is mandatory.
Understanding this properly is critical, because FDA expectations go far beyond simply “having someone trained.” The PCQI plays a central role in developing, implementing, and maintaining your food safety plan under the Food Safety Modernization Act (FSMA).
Understanding the PCQI Requirement Under FSMA
The requirement for a PCQI comes directly from 21 CFR 117.180, which states that certain key activities must be performed or overseen by a Preventive Controls Qualified Individual (PCQI). These activities include preparing the food safety plan, validating preventive controls, reviewing records, conducting reanalysis, and overseeing implementation.
This means the PCQI is not just a title or a certificate holder. It is a defined role tied to specific regulatory responsibilities. If those responsibilities are not properly fulfilled, the facility is not in compliance, regardless of whether someone has completed a course.
