I'm sure I'm joining a large group out there trying to understand the requirements of FSMA. My question at this time relates to the Preventative Controls Qualified Individual. From the FDA website:
PC.5 What is a preventive controls qualified individual?
This is a new term in the final rule. A preventive controls qualified individual is someone who has successfully completed certain training in the development and application of risk-based preventive controls or is otherwise qualified through job experience to develop and apply a food safety system. The written food safety plan required of food facilities must be prepared, or its preparation overseen, by one or more preventive controls qualified individuals. And the preventive controls qualified individual is charged with overseeing the validation that preventive controls are capable of controlling identified hazards and the records review.
So, is a training course required? Or, is our HACCP Coordinator already sufficiently qualified? We are a small, family owned and operated company. The HACCP Coordinator is one of the owners, was involved in the development of the product, and involved in daily production. We just don't want to spend the time and money on 2.5 days of training if it is not required.
We are BRC certified (AA on Issue 7). Our HACCP is already based on a risk analysis format. We are in Canada, but ship into the USA as the importer (the product goes to warehouses, from where it is further shipped to the final customer). I just want to be prepared so we don't have a surprise one day with a truck refused entry at the US border.
Also, does anyone know how we would show compliance? Thanks.