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