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112.22 - Produce Safety Rule Training and Certificate

Started by , Jun 27 2018 02:26 AM
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Hi, Everybody! We´re a foreign supplier and some questions and doubts about Produce Safety Rule training offered by Produce Safety Alliance. As we can see at FSMA Requirement 112.22 ©

"At least one supervisor or responsible party from the farm must have successfully completed food safety training at least equivalent to the standardized curriculum recognized as adequate by the FDA". 
Is it mandatory that the supervisor to have a FSA certificate? Or may this supervisor has a agronomic diploma, with experience and  courses on GAP, and also had studied all the "PSR resourses" avaiable to download on PSA and FDA sites? And with all this knowlegde, he´s able to implement the Produce Safety Rule. How does FDA see this situation? It seems to me that the PSR training by PSA is not mandatory, since the supervisor complies with all PSR requirements. Thanks a lot!
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I think it would be arguable against SQF, BRC auditors about the justification of skills/experience that sits in place of the standardized course recognized by the FDA. The FDA clause actually states that it is possible to be explained through other experience and training ("at least equivalent" part of the clause); however, the FDA has been very lackluster in defining what that criteria would look like. From what I have seen from other members of this forum, the best course of action is to take the standardized course as most FDA auditors haven't been giving wiggle room (maybe others here have different experiences?)

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