10 replies to this topic

[Danielle D]

Hello, 

 

I am the only one that has gone through PCQI training and our Managment will not send anyone else to official training. I have put slides together and some documentation for internal training since I am not the only one that signs off on verification activities. 

 

Does anyone have some examples of internal quizzes if you did your own PCQI training?

 

I could ask the basic questions, but it is similar to HACCP for our process, so  I don't know if I just repeat myself or ask more of "what's the difference questions" to show that they have successfully been trained? 

[tintfen]

Hi, 

As what i known, only person who went through PCQI official training can sign off the verification records. That's why our management arrange in-house training and conducted by qualified trainer.

[MsMars]

Have you taken the PCQI Lead Instructor class as well? Otherwise I don't believe you could technically "certify" someone as a PCQI.  The FSPCA course is not required to be a PCQI, but it is the easiest way to satisfy the requirement and avoid a lot of further questioning by an inspector unless one has extensive experience and industry knowledge.  

[Danielle D]

Have you taken the PCQI Lead Instructor class as well? Otherwise I don't believe you could technically "certify" someone as a PCQI.  The FSPCA course is not required to be a PCQI, but it is the easiest way to satisfy the requirement and avoid a lot of further questioning by an inspector unless one has extensive experience and industry knowledge.  

 

I have not taken the course, but I have been told by many that as long as I do internal training on Preventive Controls , those individuals are then qualified to sign verification documents. 

 

Thanks for your input. 

[Brendan Triplett]

The actual books states it as this:

 

A Preventive controls qualified individual “means a qualified individual who has successfully completed training in the development and application of risk-based preventive controls at least equivalent to that received under a standardized curriculum recognized as adequate by FDA or is otherwise qualified through job experience to develop and apply a food safety system.” This is the definition is from Current Good Manufacturing Practice, Hazard Analysis, and Risk-based Preventive Controls for Human Food regulation § 117.3 and the Current Good Manufacturing Practice, Hazard Analysis, and Risk-based Preventive Controls for Food for Animals regulation § 507.3

 

With that being said, the PCQI can be someone  "through job experience to develop and apply a food safety system", There may not be a specific course to take but the auditor will feel better if someone has taken some kind of recent standardized training.

 

Cheers!

[Danielle D]

The actual books states it as this:

 

A Preventive controls qualified individual “means a qualified individual who has successfully completed training in the development and application of risk-based preventive controls at least equivalent to that received under a standardized curriculum recognized as adequate by FDA or is otherwise qualified through job experience to develop and apply a food safety system.” This is the definition is from Current Good Manufacturing Practice, Hazard Analysis, and Risk-based Preventive Controls for Human Food regulation § 117.3 and the Current Good Manufacturing Practice, Hazard Analysis, and Risk-based Preventive Controls for Food for Animals regulation § 507.3

 

With that being said, the PCQI can be someone  "through job experience to develop and apply a food safety system", There may not be a specific course to take but the auditor will feel better if someone has taken some kind of recent standardized training.

 

Cheers!

 

Thanks, Again I have personally taken this training and have overseen the Food Safety Plan since; however, I have employees that sign off on daily verification activities that need "training" to be able to sign off on those. I guess now I am wondering if they need to have certified training or if they are considered qualified based on internal training that I give. Auditors have suggested I do internal training but it appears people have other views that they need to have official training. 

[Brendan Triplett]

Are they just signing off on verification activities?  I have my guys go through internal training because I don't send everyone to PCQI training, as there only needs to be one.  The internal training on food safety and verification procedures should be enough to get by in any audit as the person conducting the verification activity only really needs to know the CLs and that the CCP or activity is functioning.  Your internal training should be fine, just make sure you have a record of the training and copy of the quizzes or paperwork that you sign off on so that the auditor can see it if they want to review who was trained and how.  You can keep this in your training record.

 

Cheers!

[Danielle D]

Are they just signing off on verification activities?  I have my guys go through internal training because I don't send everyone to PCQI training, as there only needs to be one.  The internal training on food safety and verification procedures should be enough to get by in any audit as the person conducting the verification activity only really needs to know the CLs and that the CCP or activity is functioning.  Your internal training should be fine, just make sure you have a record of the training and copy of the quizzes or paperwork that you sign off on so that the auditor can see it if they want to review who was trained and how.  You can keep this in your training record.

 

Cheers!

 

Yes, they are just signing off on daily verification activities. I was under this impression as well! Appreciate the input! 

[kettlecorn]

Yes, they are just signing off on daily verification activities. I was under this impression as well! Appreciate the input! 

 

If you're just doing training for signing off on verification, all you need is a Qualified Individual. Such individual does not need to be PCQI, either through certification or training or work experience, but they do need training to perform their role. It sounds like the training you are doing is more than sufficient. Moreover, unless they are part of the Food Safety Team (none of which, necessarily, except the Food Safety Team Leader, needs to be PCQI), I don't see a reason to train them on the differences between HACCP and HARPC. 

 

You should still convince your boss you need two PCQIs though. Vacations are nice. 

Edited by kettlecorn, 03 March 2020 - 07:29 PM.

[TimG]

Yeah, I was going to suggest what Kettle did. A backup PCQI is pretty important for those surprise FDA visits (they're all surprise visits).

[MsMars]

I'm probably just repeating what everyone else said, but yes if they are only signing off on verification activities, then you just need to do training with them and document it as they will be Qualified Individuals.  However, you do need a backup PCQI unless you never plan on being sick, taking a vacation, etc. etc. 

 

Edit: Also, in case you haven't deduced this, Qualified Individuals and Preventive Controls Qualified Individuals are two different things.     I was slightly confused by your original post. 

Edited by MsMars, 03 March 2020 - 10:03 PM.