December 12, 2016

Understanding FSMA Training Requirements

The Food Safety Modernization Act (FSMA) has required the U.S. Food and Drug Administration (FDA) to issue several new food safety regulations, now in effect.

Throughout the new regulations are various requirements for training that personnel in fresh produce operations must undergo as part of their implementation.  Because there are different requirements across several rules and a broad selection of training programs being developed and offered to assist growers, shipper, processors and others to comply, it is imperative that Western Growers members have a clear idea of which course or training offering is right for them.  With this basic knowledge, WG members will be better equipped to manage costs and logistics associated with getting teams trained by ensuring the right people are in the right training at the right time at an affordable price.

This article focuses on training requirements relevant to the Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption, often referred to as the FSMA Produce Safety Rule.  This rule requires producers other than those defined as “small” and “very small” to be in compliance with most of the rule’s provisions by January 26, 2018.  Training is a key component of this rule and has increased interest about training opportunities as well as confusion about actual requirements.  So, what are the training requirements of this rule?

The FSMA Produce Safety Rule requires training for all personnel (including temporary, part-time, seasonal, and contracted personnel) who handle (contact) covered produce during covered activities or supervise the conduct of such activities.  Training must be executed upon hiring and periodically thereafter—at least once per year.  The following topics must be included in 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.  While producers can develop or customize their own training programs for individuals with different job responsibilities, the rule requires that at least one supervisor or responsible party complete training at least equivalent to the Produce Safety Alliance (PSA) training, the only training curriculum recognized and developed under FDA supervision.  Subpart C of the rule provides more detailed information about requirements related to personnel qualifications and training.

It is helpful to understand what type of training is needed for implementing a successful FSMA Produce Safety Rule program.  In addition to meeting the rule requirements, it would also help producers in revising and strengthening current training programs.  For example, the rule does not require PSA training for every single supervisor or responsible party, yet a company may determine PSA training for growers may be valuable for more than one supervisor.

Related to this topic, the terms FSMA training and PSA training are not interchangeable.  While FSMA training could include information about several rules, PSA training is specific to the FSMA Produce Safety Rule.  There are currently two types of training offered by the Produce Safety Alliance.  These are PSA Grower Training and PSA Train-the-Trainer classes, now available.

PSA training for growers satisfies the FSMA Produce Safety Rule requirement that at least one supervisor or responsible party for the farm successfully completes food safety training at least equivalent to that received under standardized curriculum recognized as adequate by the FDA (§ 112.22(c) of the Produce Safety Rule).  The PSA Train-the-Trainer class is meant for produce safety educators and others who work with fruit and vegetable growers who are interested in becoming PSA Trainers or PSA Lead Trainers. Those who become a PSA Trainer or PSA Lead Trainer are able to conduct the PSA training for growers.  The PSA website at  contains more details about the application process to become a PSA trainer or Lead Trainer and conduct PSA training.

Growers do not need to attend the PSA Train-the-Trainer class unless you desire to train other growers.

Although this article does not cover training requirements related to other rules, WG members should be aware that there are also several training offerings for the FSMA Preventive Controls Regulation: Current Good Manufacturing Practice and Hazard Analysis and Risk-Based Preventive Controls for Human Food.  This regulation applies to registered facilities, unless an exemption applies.  While growers are exempt from this regulations if they meet the FDA’s farm definition (§ 1.227 of the 21 CFR, Part 1), some operations that manufacture, process, pack or hold produce may be subject to some or all of the requirements of this rule if they do not fall under this definition.  In those cases, one way to meet the requirements for a “preventive controls qualified individual” is to complete the Food Safety Preventive Controls Alliance (FSPCA) Preventive Controls for Human Food Course developed by this Alliance; this is currently the only “standardized curriculum” recognized by FDA. A FSPCA Train-the-Trainer course is meant for those interested in becoming a Lead FSPCA and conduct FSPCA training.  Growers (that meet the farm definition) do not need to attend a FSPCA training class.

Western Growers believes that robust training programs play a key role in developing and maintaining a food safety culture and will be offering several PSA training sessions next year.  These sessions will include PSA training for growers and also practical solutions to implement and deliver customized in-house training for produce operations whose employees have different job responsibilities.  If you are interested in receiving more information about upcoming opportunities, contact Sonia Salas at [email protected] and also visit Western Growers’ FSMA portal to access FSMA Produce Safety Rule resources and much more at