- Inspection FY 2020:
|FDA Only||CGMP||HA/PC||Sanitary Transportation||FSVP|
|FY2020 Domestic Animal Food Inspections||Planned: 180 Completed: 91 50%||Planned: 360 Completed: 7 22%||Planned: 84 Completed: 30 36%||Planned 75 Completed: 67 89%|
The time period for the completed inspections was from October 1, 2019 – September 30, 2020, Since inspections were paused in March these were conducted during primarily the first 6 months of this period. The numbers are not surprising, except for FSVP, with almost 90% of the plan inspections completed. This is because the FSVP regulation allows for remote or desk inspections. The others require on-site inspections so COVID-19 had a bigger impact on these types of inspections. Many inspection violations were simply due to the facility not having a Feed Safety Plan and/or conducting the required hazard analysis.
FDA continues to respond to Mission Critical Food Safety Issues. When inspections resumed in July of 2020, FDA developed an Advisory Rating System. They look at the COVID risk in the facilities location and the location of inspectors. Although they did not provide a great deal of information on this process; they have made the unprecedented decision to give advance notice of inspections. They will call approximately 5 days in advance with scripted questions to determine the facilities readiness to safely conduct the inspection.
They are also conducting voluntary Remote Risk Assessments. If you were previously inspected on-site, you may be asked if you would like to participate in a remote assessment of your work towards resolving open issues.
- The future of training
This conference was for Lead Instructors of Food Safety Training Courses provided by FSPCA (Food Safety Preventive Controls Alliance). Therefore, there was much discussion on training and the opportunities FSPCA has provided to conduct remote training and the rules associated with doing so. As much as I would love to conduct zoom trainings there is much that needs to be done to gain compliance with the virtual training rules. I have consistently heard from CFD members it is very hard to get things like this done when they are in the mill. I think it would be very hard for students to comply with these new rules as well. As the vaccine has already begun to be distributed, we should be able to resume in-person training in the Spring. I will begin discussions with CFD on the criteria for an in person class.
- New Tool:
As I discussed last month, In October FSPCA released this “Abbreviated Guide to Creating a Livestock Food Safety Plan Under the Preventive Controls for Animal Food (PCAF) Rule”. This plan is just an example of a plan for a facility manufacturing Medicated and Non-medicated Feed for Swine and Broilers. Click on the title to view and download the public version of the document.
- Virtual Office Hours
One idea presented is that instructors are offering virtual office hours. I think this is a fantastic idea and I will be working next week to arrange a schedule for virtual office hours in 2021.
Coming next month… “A tale of Two Inspections”.