GENERAL FOOD SAFETY INQUIRIES
I am new to Food Safety, where should I start.
In order to build a strong Food Safety foundation, you will want to begin with a Good Manufacturing Practices (GMPs) course. GMPs serve as the building blocks for learning and implementing HACCP and FSMA. FIC offers a very comprehensive GMP course that has been designed to comply with GFSI schemes.
COMPLYING WITH THE FOOD SAFETY MODERNIZATION ACT
We already have GMPs and HACCP implemented in our plant, how do we comply with FSMA.
It is great that you have a good foundation already in place. When comparing the new requirements with HACCP, the first 5 steps are similar. You would only need to ensure the 5 preliminary steps are reviewed and up-to-date. These include:
1) Assembling the Food Safety team
2) Describing the product
3) Identifying the intended use
4) Constructing a flow diagram of all the significant manufacturing/production steps
5) On-site confirmation of the flow diagram
The main difference is the Hazard Analysis that you would need to redo. As a result you will identify significant Hazards and their Preventive Controls. You may take our class to learn how to conduct each step and obtain your PCQI Certificate. If you would like to learn and implement at your own pace, download our step-by-step Practical Guide to FSMA Implementation which includes several useful examples for your reference.
Why will complying with FSMA strengthen our Food Safety System.
Complying with FSMA means expanding your Food Safety program to include other Preventive Controls that are crucial to reducing or preventing significant hazards from occurring. With HACCP, we are mainly focusing on Process Preventive Controls (CCPs). Complying with FSMA means bringing attention to other critical Preventive Controls such as sanitation, supply-chain controls, allergen labeling and allergen cross-contact.
For example, if your facility receives peanuts as an ingredient and neither you or your customer apply any kill step, you will be relying solely on the supplier to control for Salmonella. Approval and ongoing verification of this supplier as well as receiving such a high-risk ingredient will require stringent management, which is covered under FSMA.
What is the difference between Sanitation as a GMP and Sanitation as a Preventive Control.
As a foundation for Food Safety, GMPs must be first set in place. Sanitation is one of the most important GMPs that needs to be set prior to beginning food production. Simply put, if you are going to make food, you will need a sanitizing program to ensure the overall condition of the plant, equipment and utensils are sanitary and suitable for the production of food. This is more of a general program that is applicable to the entire plant. Sanitation can be used to both control allergen cross-contact as well as biological contamination such as environmental pathogens.
Once all the necessary GMPs have been set in place, we conduct a systematic hazard analysis and risk assessment to find the significant hazards that require Sanitation Preventive Controls. For example, if a table is used to pack various allergens, sanitation of this table will be VERY important with ZERO room for error, therefore it will require a Sanitation Preventive Control. As part of the FSMA requirement, the management of the Sanitation Preventive Controls i.e the cleanliness of this table, should be verified prior to each use and must be recorded.
FSPCA PREVENTIVE CONTROLS FOR HUMAN FOOD COURSE
What are the benefits of FIC's live-virtual PCQI training.
There's no need for travelling or staying in hotels to receive training. You can learn the FSMA requirements and attain the same PCQI certification that you would receive from in-class training from home or the office.
Our online learning platform is very simple and easy-to-use. It is also highly interactive and allows for instructor-lead discussions.
You will be able to interact with students from various parts of the world with different Food Safety backgrounds and experiences.
What is a PCQI.
PCQI stands for a Preventive Controls Qualified Individual. A Preventive controls qualified individual “means a qualified individual who has successfully completed training in the development and application of risk-based preventive controls at least equivalent to that received under a standardized curriculum recognized as adequate by FDA or is otherwise qualified through job experience to develop and apply a food safety system.”
Under the Preventive Controls for Human Food rule, the PCQI must oversee or perform 1) preparation of the Food Safety Plan, 2) validation of the preventive controls, 3) records review, 4) reanalysis of the Food Safety Plan, and other activities as appropriate to the food.
How do I become a PCQI.
One way to become a PCQI, is to take the Preventive Controls for Human Food Course. This course, taught by a Preventive Controls for Human Foods Lead Instructor was developed by FSPCA in collaboration with the FDA. You will then receive your training certificate which is issued by the Association of Food and Drug Officials (AFDO).
Who needs to take this course.
The FDA Preventive Controls for Human Food regulation was published on September 17, 2015. It applies to Facilities required to register with FDA under section 415 of the Food, Drug, & Cosmetic Act must comply if they manufacture, process, pack or hold human food. Although there are some activities that are exempt from the preventive controls, most facilities will need to have a “Preventive Controls Qualified Individual” to complete certain activities.
Individuals who need to take this course include:
QA Directors and Managers
SQF/BRC Practitioners and Auditors