6 replies to this topic

[irheavyd]

Say I write an SOP.  Do I have to train in something I wrote?  We received an NR for the writer not having a signed training document for my self.  Makes no sense to me.  Is there a regulation that addresses this?

[TimG]

• Guessing the NR was from USDA?
• Did they give you a specific code when they gave you the NR?
• Exact wording of NR?

Might have more questions or simple answers depending on the answers to the above. It sounds like you got dinged under a 'competency' loophole, which is all you should need to write SOP's. But then everyone who has to follow the SOP should also be trained on it, but that's not what it sounds like you got hit for.

[G M]

...But then everyone who has to follow the SOP should also be trained on it, but that's not what it sounds like you got hit for.

 

 

No, that's exactly what it sounds like.  It's rather pedantic, and logically the person writing the training can't be unacceptably competent if the training produced is adequate.

 

I will say that I sign the training docs too even when I'm the instructor and the person who wrote the training for just this kind of dumb reason.

[GMO]

Hmm.   I'm wondering if there's another way to approach this.  I'm not USDA experienced but what about if you turned it on its head and collected and presented evidence on why that person (or ideally people) are competent to write the procedure?  You could, say have a team who have a certain level of food safety knowledge but also knowledge of the process?  I agree it's meaningless to train someone on a procedure who created the procedure.  It takes a higher level of knowledge and skill to write something than to demonstrate competence with it.  So there the conversation should end.  But it wouldn't be bad practice to record your reasoning on why you consider yourself or a team etc competent.

[kfromNE]

One way around this - be the trainer. So have your name on the training document. 

 

Even though you wrote the SOP, is that noted somewhere. 

 

The NR should cite the code the USDA inspector is referring too. 

[irheavyd]

Never Mind they withdrew this NR

[irheavyd]

I do the writing and the training.  They realized the errors of there ways lol.