We are a manufacture of paper based food trays for the ready serve and baking markets. We recently had our Level 3 SQF desk audit and came out of it with several minors. One of them being, we had not shown verification of the training we had done. A lot of this training was completed by a consultant we hired to help us implement the system and most of it was pretty general and basic. We had previously completed some of the more specific job training as we always do when we hire someone for a specific job. Our consultant told us verification can simply be done by watching employees complete certain task and also by asking them some questions over a certain topic. I understand this method, but in reviewing the code and the items our consultant trained all employees on, I'm finding a little disconnect. There were several items our consultant said "ALL" Employees must be trained in (SQF, HACCP, Pest Control) When I started to look at ways I could verify some of the training I dug into the code a little more and I'm having a hard time finding any specifics on "ALL" employee training requirements. For HACCP it states "HACCP training shall be provided for staff involved in developing & maintaining Food Safety & Food Quality Plans." I do not consider the typical employee working on our line to be involved with developing & maintaining these plans, unless "maintaining" is interpreted as "Following". I also do not see a specific requirement for "SQF" Training for all employees. I would consider what our consultant did as more of an Overview of "SQF" and of "HACCP" as well as some other areas, which makes sense for all, but would not require it to be on our training register or be verified.
The code General guidance document states the following (The Food Packaging Guidance Draft does not include the items in purple):
The following programs are considered the minimum required elements for employee training. Type and
depth of training will depend upon the employee’s Work Designation. Minimum Requirements:
• Job/Task Performance
• Company Safety and Quality Policies and Procedures
• Good Manufacturing Practices
• Cleaning and Sanitation procedures
• HACCP
• Bio security and Food Defense
• Product Quality and Grading
• Chemical Control
• Hazard Communication
• Blood borne Pathogen
• Emergency Preparedness
• Employee Safety
• Safety Regulatory Requirements/Quality Regulatory Requirements
The guidance doc. states that these are minimum requirements, but it does not specify minimum for all employees. Does anyone have more information regarding what some true minimum training requirements are for all employees (if any)? If you are a few packaging producer, as we are can you following the "Food Packaging Guidance Doc." even though it is considered to be a draft?
Any help or additional info on this would be greatly appreciated.
Thanks
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