On December 8-10, 2015, DFA participated in the first official [acronym_tooltip text=”FSMA”] “Preventive Controls Qualified Individual” (PCQI) Lead Instructor course.
Below are a few key subjects we wanted to share with you from the training – things you may not have known about the new rules.
What You Need to Know Most:
- The training will provide document templates that can be used in your documented food safety plan.
- FDA inspectors are already being trained according to the new programs and food companies would be wise will implement early.
- If you haven’t done so already, you need to identify and document your “FSMA Food Safety team”, conduct a gap assessment, and start updating your programs. (DFA can help you achieve this step)
- The new rules are heavily-focused on microbiological and allergen hazards.
- The rules require robust supply-chain controls.
- Many food companies may find that they need to implement an electronic recordkeeping system in order to maintain all of the required records.
Regarding your Food Safety Plan:
- There are many specifically designated activities that the “Preventive Controls Qualified Individual” is required to perform.
- FDA will now be looking for an assessment in your hazard analysis for radiological hazards, intentional contamination, and potential routes of environmental contamination. This leads logically to a review of your supplier management programs, food defense, and microbiological sampling programs (both environmental and product sampling).
- All Preventive Controls, not just CCPs, will require documented validation, monitoring, and corrective actions.
- The food safety plan must be signed by the person of highest authority on-site.
- The new regulations require a reassessment of your plan at least every 3 years (HACCP is annually).
- In some cases of electronic monitoring, such as refrigerated storage, electronic “exception” records are adequate, rather than complete second-by-second temperature data. However, these exception functions must be validated.
- Your company must use “qualified auditors” for certain functions.
As you search for available training, there will be courses offered that are not officially approved for FSMA and may not aid in compliance with the new regulation. Attend one of our approved FSMA courses as this is the official, approved FDA course that food companies will need to send members of their staff to in order to meet regulatory requirements.
Upcoming Preventive Controls Qualified Individual (PCQI) Trainings
- March 16-18, 2016 | Fresno, California
- March 22-24, 2016 | Modesto, California
- March 30-April 1, 2016 | Sacramento, California
If you would like to schedule an on-site training or consultation with someone from our food safety team, please contact email@example.com or call (916) 561-5900.
The DFA Food Safety staff also plan to attend the “Produce Safety” sessions as they become available. DFA is at your service to help prepare you for FSMA compliance, visit dfaofca.com for more information.