I just got back from a 2.5 day training seminar.
Unlike many training seminars, this one was full of applicable info and answered many of my questions as to what, exactly, the FDA will be requiring from a "qualified individual" and what the "food safety plan", is supposed to look like and what it is supposed to contain.
Quite honestly, it's very much like traditional HACCP, with some specific verbiage.
Hazards are controlled by four Preventive Controls. Process (usual HACCP things like GMP's), Sanitation, Allergen and Supply Chain.
I have come to the conclusion that the vast majority of your current HACCP Plan ingredient and process hazard analysis can be simply copied and pasted to the new "format" that the FDA is looking for in a food safety plan.
Preventive controls need to be summarized for each type of control measure.
That being said, there is still quite a bit of detail that is not yet available. FDA is apparently working on a comprehensive Food Hazard Guide (similar, I guess to the one that Canada already has) that will be, supposedly, published by the end of the year.
Allergen cleaning does not have to be verified, however a "visually clean" check should be done.
I won't specify who (company) provided the training, but they are certified by the FSPCA and more of these training opportunities are becoming available. I would highly recommend this training for companies that will be required to have a "Preventive Control Qualified Individual" on staff to create and verify the Food Safety plan required by "FSMA"
Marshall