The Food Safety Preventive Controls Alliance (FSPCA), a public/private alliance of key industry, academic and government stakeholders, recently presented its winter update on a live webinar. The FSPCA provides trainers and processors with educational courses on four sections of FSMA. These include Preventive Controls (Human Food) and Preventive Controls (Animal Food) rules, both finalized by FDA on September 17, 2015; the Foreign Supplier Verification Program (FSVP), finalized on November 27, 2015; and the Intentional Adulteration rule, to be finalized on May 31, 2016. (For an introduction to FSPCA, see “FSMA HARPC update,” FE, October 2014.)
“Earlier this year, we moved [our] training effort into a pilot phase in which we did a number of pilot training sections to get more feedback from the community,” says Robert Brackett, vice president of the Illinois Institute of Technology and director of the Institute for Food Safety and Health. The alliance has been developing curricula (Phase 2) and moving into the pilot phase (3) as FSMA rules are finalized. Implementation of courses (Phase 4) began in late 2015 with the finalization of Preventive Controls rules and FSVP and continues through 2017.
To be aligned with FSMA, FSPCA has adjusted the structure of its organization to reflect the finalization of FSMA rules, says Brackett. “We have an overall steering committee that directs FSPCA, as well as how we organize the training and involve stakeholders.” Subcommittees now include Implementation/Operations (formerly Continuation), Outreach/Website, International/FSVP, Human Food Curriculum, Animal Food Curriculum and Intentional Adulteration.
Version 1.1 course material for the Preventive Controls (Human Food) rule currently is being offered in train-the-trainer and participant courses (2.5 days in person or online with one day in person), explains Katherine Swanson, FSPCA project manager, curriculum development. “The standardized curriculum also is being used to train lead instructors. These sessions are organized by the alliance through the International Food Protection Training Institute.” Lead instructor courses last three days, including a one-day participant course as a prerequisite.
“The FSPCA Preventive Controls for Human Food course is the ‘standard curriculum’ recognized by FDA,” states Swanson. “The agency reviewed this material to ensure it’s consistent with the regulatory requirements and/or highlights areas that are optional, which might be useful to help meet the requirements of the regulation.”
In this course, lead instructors have access to instructor notes to assist with delivery and interpretation, exercise guides and instructions to reinforce key learning objectives, simplified model foods for exercises consistent with regulatory requirements and access to all current resources and information the alliance provides. Lead instructors can add information to the slides; add slides, photos or graphics; and customize training to suit a particular audience, as long as the existing information is not deleted or edited.
“There was a little more than a month between the final rule being published and the first training session taking place,” recalls Swanson. New exercise model foods have been added; FSPCA’s website is being tailored for those who need help with scientific and technical questions, especially small- and medium-sized businesses, says Brackett. Those with questions are invited to submit a web form at www.iit.edu/ifsh/alliance.
FDA has its own FSMA Technical Assistance Network and a Knowledge Management System that will help processors with questions regarding FSMA regulations, interpretations, policies and implementation. Processors may access the system at www.fda.gov/fsma.
“We’re in the process of building the network in terms of food safety experts, and have contacted a group of extension specialists who have worked with the regulated industries for many years,” says Brackett. Still under development, the communications portal will be managed by human and animal food experts with broad professional and technical expertise over a wide geography.