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Will the FDA require someone certified in Food Defense?

FDA Food Defense Certification

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#1 larissaj

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Posted 20 May 2019 - 06:05 PM

Hello,

 

New manager here for the QA department at my company, I came in with a HACCP cert and just did PCQI training, I keep seeing something that FDA will get harder on Food Defense so im wondering if I should take a Food Defense training. I have been in the food industry for about 7 years so its not like I know nothing but still, just trying to figure out what they may want in a company. 



#2 kfromNE

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Posted 20 May 2019 - 06:50 PM

Yes, they will unless you are exempt.

 

https://www.fda.gov/...al-adulteration

 

https://www.ifsh.iit...019-03-22.pdf 

Notice the asterisk at the bottom of the page - *These courses satisfy the training requirements in section 121.4 of the IA Rule.


Edited by KfromIA, 20 May 2019 - 06:50 PM.


#3 nwilson

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Posted 20 May 2019 - 06:54 PM

https://www.ifsh.iit...al-adulteration .  You can always start here, some of these courses are free too.  


:coffee:


#4 tsebring

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Posted 20 May 2019 - 06:55 PM

It depends whether you fall under the guidance, but if so, yes, the FDA requires different levels of training (or experience) depending upon role, etc.  Ref: 21 CFR 121.4(b)(2))

 

A couple of resources for you:

 

FSMA's IA rule home (where you can get resources to determine if you are under the rule): https://www.fda.gov/...al-adulteration

 

Article from April 2019 outlining a lot of the FDA's current thinking, etc.: https://www.fda.gov/...-acts-terrorism

 

"The" authorized IA training source: https://www.ifsh.iit...al-adulteration

 

Some Food Defense specific FDA resources: https://www.fda.gov/...ional-materials

 

I hope that this helps somehow.

 

Good luck,

Todd

 

PS: Guess I need to type faster; answers above.   ;)


Edited by tsebring, 20 May 2019 - 06:55 PM.


#5 larissaj

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Posted 20 May 2019 - 07:03 PM

Thanks everyone!



#6 jalex194021

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Posted 20 May 2019 - 07:55 PM

FSPCA FOOD DEFENSE AWARENESS FOR THE IA RULE

  • Delivery Format: Online course.
  • Estimated Seat Time: 20-30 minutes. There is a 4-hour inactivity time-out, so once started,...
  • Certificate: An FSPCA Certificate of Completion is issued at the end of the course...
  • Cost: Free.
ucfoodsafety.ucdavis.edu/Upcoming_Training/?calitem=412640&g=88440

 

 

You can always take this course for free.



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#7 kfromNE

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Posted 20 May 2019 - 08:44 PM

 

FSPCA FOOD DEFENSE AWARENESS FOR THE IA RULE

  • Delivery Format: Online course.
  • Estimated Seat Time: 20-30 minutes. There is a 4-hour inactivity time-out, so once started,...
  • Certificate: An FSPCA Certificate of Completion is issued at the end of the course...
  • Cost: Free.
ucfoodsafety.ucdavis.edu/Upcoming_Training/?calitem=412640&g=88440

 

 

You can always take this course for free.

 

 

I did see this though my interpretation is if you are the individual in your facility responsible for conducting or overseeing the plan i.e. preparing the food defense plan, the vulnerability assessment, the identification and explanation of mitigation strategies and reanalysis  (see below or pg 20 - https://www.fda.gov/...105742/download) then you would need additional training and Food Defense Awareness wouldn't suffice .

 

From IFT's website - the Food Defense Awareness training is designed for "workers at actionable process steps and supervisors of workers at actionable process steps"  so not the individual(s) conducting or overseeing.

https://www.ifsh.iit..._2019-03-22.pdf

 

For them they'll need one of the other 4 courses mentioned on the IFT website under the heading "FSPCA Rule Standardized Curriculum Recognized by the FDA" or equivalent  -

Sources: see IFT course cheat sheet above and https://www.fda.gov/...113684/download - part C - pgs. 107-108



#8 Jpainter

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Posted 20 May 2019 - 09:29 PM

I have taken the course through the Illinois Institute of Technology, but I need to get this course to my operators. The issue is most of them only speak Spanish. Does anyone know if there is a version of this training available in Spanish? As some have said, this is the only FDA approved training so my employees will need this specific training.  



#9 kfromNE

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Posted 21 May 2019 - 01:30 PM

I have taken the course through the Illinois Institute of Technology, but I need to get this course to my operators. The issue is most of them only speak Spanish. Does anyone know if there is a version of this training available in Spanish? As some have said, this is the only FDA approved training so my employees will need this specific training.  

 

I have not seen one but this training by the FDA is in multiple languages. https://www.fda.gov/...employees-first



#10 sqflady

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Posted 18 December 2019 - 05:11 PM

Is anyone aware of any other courses for employees that might be a bit shorter in length?



#11 tsebring

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Posted 18 December 2019 - 06:15 PM

This class info was just announced earlier this week.  Their web site says a couple of hours.  I've not looked into it in detail as yet.  Just saved the email for later.  Link: https://www.ifsh.iit...al-adulteration

 

 

The Food Safety Preventive Controls Alliance (FSPCA) has made available another Intentional Adulteration (IA) online training course
December 16, 2019
 
A new intentional adulteration (IA) online training course has been made available, the “IA Food Defense Plan Preparation and Reanalysis” online course was developed through a partnership between FSPCA’s Intentional Adulteration Subcommittee and FDA.  The regulation requires that individuals preparing the food defense plan and performing reanalysis “have successfully completed training for the specific function at least equivalent to that received under a standardized curriculum recognized as adequate by FDA or be otherwise qualified through job experience to conduct the activities” (21 CFR 121.4©(2)). This training developed by the FSPCA is the “standardized curriculum” recognized by FDA; successfully completing this course is one way to meet this training requirement. 
 
This course is available on the Food Safety Preventive Controls Alliance website and can also be accessed through the FDA’s Food Safety Modernization Act (FSMA) website.
 


#12 Timwoodbag

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Posted 18 December 2019 - 06:47 PM

So our consultant said our combined experience would satisfy the need for anyone to get specific Food Defense Training.  Is that because as a small, low risk company they will likely go easy on us our first audit?  We are not "very small" as it says in the exemptions. ($1,000,000 in sales please correct me if wrong.)



#13 tsebring

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Posted 18 December 2019 - 07:04 PM

Based upon your sales number, you should be exempt based upon my reading of the exemption logic.  You can (and should) verify that for yourself. 

 

Is your facility part of a very small business?

I.e. a business (including any subsidiaries and affiliates) averaging less than $10,000,000, adjusted for inflation, per year, during the 3-year period preceding the applicable calendar year in sales of human food plus the market value of human food manufactured, processed, packed, or held without sale (e.g., held for a fee)?
 
If YES, you are exempt, except that you are required to provide for official review, upon request, documents sufficient to show your status as a very small business. Such documentation must be retained for two years.
[21 CFR 121.5(a)]

 

Reference:

 

FSMA IA rule: https://www.fda.gov/...al-adulteration

IA Rule Fact Sheet: https://www.fda.gov/.../98085/download

IA Rule Exemption PDF: https://www.fda.gov/.../97788/download

 

As for training, I will go ahead and answer that in case it is useful.  The training requirements come down to what the role someone is doing; basically, the rule requires different training levels for different activities.  For example, if you are conducting the vulnerability assessment, then you are to “have successfully completed training for the specific function at least equivalent to that received under a standardized curriculum recognized as adequate by FDA or be otherwise qualified through job experience to conduct the activities” (21 CFR 121.4©(2)).  The training site posted several times above will give you a good idea of what is needed for each role.  I would suggest, if you are doing it, to go through the FDA approved training curriculum, so that you would have one less possible issue if you were ever to interact with them.  

 

I hope that this helps. 

 

Good luck,

Todd 

 

PS: That's part 121.4c not a copyright symbol.  







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