BRCGS 4.2.1 - Food Defense Training Requirements for Issue 9
Hello-
Section 4.2.1 discusses the need for the food defense team to be trained (depending on legislative requirements). With the production plant being under USDA (in the United States), I'm not sure what the specific requirements would be.
Does the entire food safety team need to receive a 3rd party training, or could the food defense team coordinator be trained and then conduct an "internal" food defense training with the other management staff on the food defense team? Would that be sufficient???
The entire team does not need to be third party trained. Train them on your food defense policy and your food defense plan so they know what their roles and responsibilities are.
Hi Audrey,
The team should have food defence awareness training (the type of which is not specified so could be internal but meeting the requirements of section 7.1 Training) and the qualified individual responsible for developing the site’s food defence plan must have completed training recognised by FDA or be otherwise qualified through job experience to conduct the activities.
Relevant references are below.
BRCGS Global Standard for Food Safety Issue 9 clause 4.2.1 states:
Where personnel are engaged in threat assessments and food defence plans, the individual or team responsible shall understand potential food defence risks at the site. This shall include knowledge of both the site and the principles of food defence.
Where there is a legal requirement for specific training, this shall be in place.
BRCGS Global Standard Food Safety Issue 9 Module 13: Meeting FSMA Requirements for Food Guidance:
The qualified individual responsible for developing the site’s food defence plan must have completed training recognised by FDA for implementing requirements of the Food Defence rule. At present, the only recognised course is the Food Safety Preventive Controls Alliance (FSPCA) Intentional Adulteration training course.
Qualified individuals responsible for implementing mitigation strategies may be in addition to the qualified individual responsible for developing the food defence plan. These individuals must receive training in food defence awareness.
You need to comply with Food Defence: 21 CFR PART 121 Section § 121.4 Qualifications of individuals who perform activities under subpart C of this part:
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.
Kind regards,
Tony