May 3, 2016

FSMA Mandates New Training Procedures

The Food Safety Modernization Act (FSMA) is bringing changes to the food industry. Several months ago, the U.S. Food and Drug Administration (FDA) announced two key food safety rules impacting the produce industry.  The new FDA’s Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption—the Produce Safety Rule (PS rule)—went into effect on January 26, 2016.  The new Current Good Manufacturing Practice and Hazard Analysis and Risk-Based Preventive Controls for Human Food – the Preventive Controls Rule (PC rule)—went into effect on November 16, 2015.

If your company is subject to either one of these two rules, new training requirements will have to be in place—for some companies as soon as September of this year.  So, where does your company stand on training?

Under the PS rule, training must be provided to all personnel who handle or touch food contact surfaces or covered produce or who are engaged in the supervision thereof (including temporary, part-time, seasonal, and contracted personnel).  This training must be executed upon hiring and periodically thereafter, at least once per year.  The PS rule establishes the following topics as mandatory parts of this training: 1) principles of food hygiene and food safety; 2) the importance of health and personal hygiene; and, 3) the requirements of the PS rule applicable to their job responsibilities.  The rule allows individual companies to develop and customize training for all personnel subject to this requirement.  However, the PS rule does require FDA-recognized training for at least one supervisor or responsible party of a produce operation.

The Produce Safety Alliance (PSA) has developed a training curriculum that is currently under review by the FDA.  The launch of the PSA’s training was expected earlier this year, but it was delayed until the agency could complete its official review and recognition.  This is likely to take place in September 2016.  Once the FDA recognizes the PSA curriculum as adequate to meet the requirements of this rule, several entities, including Western Growers, are expected to provide training.  FDA-recognized training is only required for one responsible party of a produce operation; it is not required for employees working in other job positions.  However, while many in our industry have food safety training programs in place already, the content of current training will have to be evaluated to ensure it includes the topics listed above and explained in more detail in the full text of this rule.

Under the PC rule, the management or party responsible for a facility must ensure that all individuals (including temporary or seasonal) who manufacture, process, pack or hold food subject to one or more subparts of the PC rule are qualified to perform their assigned duties.  In order to be considered “qualified,” a person needs to have education, training, or experience (or a combination thereof) appropriate to the individual’s assigned duties as well as to receive training in topics listed in this rule.  These topics include principles of food hygiene and food safety as well as the importance of employee health and personal hygiene, as applicable to the facility and the individual’s assigned duties.  Designated supervisory personnel must ensure compliance with these requirements and have education, training or experience to supervise the production of safe food.

The PC rule allows for flexibility to utilize existing industry and third-party training programs that address the topics mentioned above.  However, in order to be considered a preventive controls qualified individual, FDA-recognized training may be required.  The FDA defines a preventive controls qualified individual as an individual who has successfully completed training in the development and application of risk-based preventive controls, equivalent to FDA-recognized curriculum or, who through job experience is able to develop and apply a food safety system.  The Food Safety Preventive Controls Alliance (FSPCA) is the only entity that has developed a nationwide curriculum recognized by the FDA. FSPCA lead instructors are currently providing training at different locations and dates.  This becomes relevant if a facility is subject to activities under the Hazard Analysis and Risk-Based Preventive Control’s section of the PC rule that must be conducted by a preventive controls qualified individual.

Joining the PSA and FSPCA email distribution list provides the opportunity to learn about periodic updates and upcoming training opportunities for FDA-recognized training through both Alliances.  For regional training utilizing FDA-recognized training stay tuned as Western Growers will also provide information about upcoming training in the next few months.  Robust training programs play a key role in developing and maintaining a food safety culture.  Visit Western Growers’ FSMA portal to access resources available to use in revising, developing or revamping your training program.