On July 13 – 14 I attended the first FSPCA Annual Conference for Lead Instructors of the Preventive Controls for Human and Animal Food courses. The conference included a series on presentations and panel discussions focusing on Industry needs for information, training and support to implement the Food Safety Modernization Act. If I tried to convey all I learned in this blog post you would likely not read it so here are the highlights:
- FDA representatives spoke about the status of inspections.
- In Animal food facilities there are 250 inspections of large facilities planned in this Federal Fiscal Year (ends in October). Only 47 have been completed. This is a slow process.
- Animal food inspections have not been funded at the state level.
- Inspections are being conducted by a core team of FDA inspectors using an OJE (On the Job Experience) model. When an inspection occurs, the lead FDA inspectors have a team of FDA inspectors that assist and are in training. State inspectors have been permitted to observe.
- FSMA’s flexibility has led the FDA to a paradigm shift. In the past inspections have been largely observational. Inspectors are given a checklist and they observe and record the results. FSMA shifts the focus of inspection to a systems review of the facility food safety system. There is no checklist. This requires extensive training for all inspectors.
- Inspectors cannot be experts in all aspects of the industry. It is unlikely that “hazards will be determined” in the field. FDA has set up a team of subject matter experts (SME’s) to assist inspectors in evaluating the situations they encounter prior to issuing a report or a finding. It is my opinion that this approach supports the FDA goal to “educate while they regulate” and applies to both Industry and the cadre of inspectors in the field.
- Version 1.2 of the FSPCA Preventive Controls for Animal Food Course will be out in the fall of this year. If you have taken a course with me in the past year I will be communicating those changes to you once I receive them.
- More good news, FSPCA is developing a blended course for Animal Food. The first part of the course will be on-line and taken at your own pace. Upon completion you must attend a shorter in-person classroom based course to obtain your certificate.
- CFD, Cornell and NEAFA will likely begin offering the blended course at Cornell in 2018.
- Need a refresher? The PCAF course provides a great deal of information. If you have taken it before and feel overwhelmed by all you learned, the blended course may be a great way to take a refresher. Fee structure is unknown at this time.
- Sanitary Transportation of Human and Animal Food – the FDA is developing a free course to address more specifics on this rule. I will let readers know when this is available.
- FSVP (Foreign Supplier Verification) was a big topic of discussion. FSPCA has released a training module to be given at the end of the PCAF class. I will attend training on this soon and I will provide opportunities for past PCAF students to attend a webinar on this module.
- Technical Assistance Networks have been set up by both the FDA and FSPCA to answer facility specific questions. FDA response has been slow. FSPCA TAN is made up of volunteer SME’s that with extensive industry knowledge. This is an additional resource to industry.