8 replies to this topic

[Jonn Cotter_33853]

Hello,

just wondering, if I have had my PCQI training am I covered for FSMA for Intentional Adulteration?  Or do I need to take an additional course for IA?

[Ryan H.]

Check out the website link below under FSPCA IA CONDUCTING VULNERABILITY ASSESSMENTS COURSE. There is an attachment too. The attachment really lays out the training requirements nicely. You will need to take the "Conducting Vulnerability Assessment" 1-day course. There are not many "certified" trainers for these courses yet since they are new, so you will have to search around a little to find one. 

 

Unless you can prove you are qualified to conduct vulnerability assessments through other training and/ or experience (much like the PCQI requirements) you will need this course. 

 

 

https://www.ifsh.iit...al-adulteration

 

Good luck, 

Attached Files

•  FSPCA_FORM_0035_IA-Course-Cheat-Sheet_19-05-20.pdf   170.27KB   82 downloads

[LachelleOMP]

Do you know if that course is available online?  If not, who would you recommend for it.

[Ryan H.]

The organizations that typically have great classes/ instructors that I use, do not yet carry this class. Please know that other companies, like AIB International - https://www.aibonline.org/en/ - and Alchemy Training Solutions - https://academy.alch...isor-awareness/ - do have online courses for food defense, they MAY be suitable, just not specifically recognized by the FDA as compliant to the FSMA regs. Also, note some of the courses are FREE of charge: FSPCA FOOD DEFENSE AWARENESS FOR THE IA RULE, FSPCA OVERVIEW OF THE INTENTIONAL ADULTERATION RULE (IA RULE) - https://www.ifsh.iit...al-adulteration -

 

For the 1 day course I was referring to in post #2, this is currently only offered in person, much like the PCQI course. A provider I found after searching for a bit is below. Go to their "class schedule" for dates/ times. Again, these courses are rather new as the instructors have only been recently trained. 

 

https://www.pastertr...essments Course

[KMA]

The organizations that typically have great classes/ instructors that I use, do not yet carry this class. Please know that other companies, like AIB International - https://www.aibonline.org/en/ - and Alchemy Training Solutions - https://academy.alch...isor-awareness/ - do have online courses for food defense, they MAY be suitable, just not specifically recognized by the FDA as compliant to the FSMA regs. Also, note some of the courses are FREE of charge: FSPCA FOOD DEFENSE AWARENESS FOR THE IA RULE, FSPCA OVERVIEW OF THE INTENTIONAL ADULTERATION RULE (IA RULE) - https://www.ifsh.iit...al-adulteration -

 

For the 1 day course I was referring to in post #2, this is currently only offered in person, much like the PCQI course. A provider I found after searching for a bit is below. Go to their "class schedule" for dates/ times. Again, these courses are rather new as the instructors have only been recently trained. 

 

https://www.pastertr...essments Course

 

Myself and the Supervisory team all took the FSPCA  Food Defense for the IA Rule  free online course Ryan H. mentioned

I also found these 3 webinars very helpful  https://www.ifsh.iit...al-adulteration

We did not use it but the FDA has a plan builder you can use to walk through step by step  here https://www.fda.gov/...s/ucm410909.htm

 we went through our process steps with this USDA Industry Self Assessment Checklist https://www.fsis.usd...pdf?MOD=AJPERES

[mgourley]

Unless they reversed course, the FDA said they were pulling their Food Defense Plan Builder for overhaul, because it did not meet the intent of the IA rule.

 

Marshall

[Charles.C]

Check out the website link below under FSPCA IA CONDUCTING VULNERABILITY ASSESSMENTS COURSE. There is an attachment too. The attachment really lays out the training requirements nicely. You will need to take the "Conducting Vulnerability Assessment" 1-day course. There are not many "certified" trainers for these courses yet since they are new, so you will have to search around a little to find one. 

 

Unless you can prove you are qualified to conduct vulnerability assessments through other training and/ or experience (much like the PCQI requirements) you will need this course. 

 

 

https://www.ifsh.iit...al-adulteration

 

Good luck, 

 

Hi Ryan,

 

Thks for the fascinating  document. Acronyms Rule !!

 

Nicely propogates the US-inspired confusion over the terminology "Vulnerability Assessment"

[mgourley]

Charles,

 

Without getting into detail, the VA basically determines if a step or process at your facility fits into one of the "Key Activity Types" that the FDA identified several years ago as being most at risk for intentional adulteration. 
Bulk liquid onload/offload. Bulk liquid storage. Mixing. Secondary ingredient handling.

I have no idea why they consider bulk raw material (i.e. flour) as good to go.

For the four KAT's you have to determine risk of adulteration, how you will mitigate the risk, and how you will document that you have mitigated said risk. There is also a secondary bit where you can use, or not, for how many people and/or economic problems will be affected by an  intentional adulteration at that specific step.

 

It's all a bunch of BS, IMHO. 

FDA went way overboard in this part of FSMA, because they have no clue.

OK...Bulk receiving of HFCS for example..generally this accomplished by a bulk storage vessel pulling up to your facility, a guy hooks up a hose and pumps the material into your bulk storage vessel. Why is this something you need to assess? I doubt the bad guy is going to dump something into the bulk trailer.

The more logical thing would be that a bad guy would dump something in the trailer, or the raw material before it got to you for unloading. And what are you supposed to do about that?

Marshall

[Ryan H.]

Hi Marshall, 

 

From the latest information I received, the FDA is suppose to be releasing the new version of the Food Defense Plan Builder at any time. But based on their new requirements, it will certainly be one heck of a overhaul. 

 

I also can understand the feelings that these requirements are unreasonable and unnecessary, but the FDA, apparently has done years of research in determining the most vulnerable areas (the Key Activity Types for example, which is one method for conducting the vulnerability assessment that they approved of). Either way, we must be compliant..