I would like to request clarification regarding the training requirements for becoming a Food Defense Qualified Individual (FDQI) under the FSMA Intentional Adulteration (IA) Rule. According to FSPCA, there are four IA training courses, each aligned with specific regulatory responsibilities: (1) IA Food Defense Plan Preparation and Reanalysis – supports §121.126 and §121.157; (2) IA Conducting Vulnerability Assessments Using KAT – supports §121.130; (3) IA Conducting Vulnerability Assessments (full VA method) – supports §121.130; (4) IA Mitigation Strategies – supports §121.135. My question is: for one individual to be considered a fully qualified FDQI responsible for preparing the food defense plan, conducting the vulnerability assessment, identifying mitigation strategies, and performing reanalysis, does FDA expect that person to complete all four courses, or is there a minimum combination that satisfies the competency requirements in 21 CFR 121? Additionally, if training is taken from a non-FSPCA provider in Vietnam, but the curriculum fully matches the official FSPCA IA materials and covers all FDQI responsibilities in §121.126, §121.130, §121.135, and §121.157, would FDA consider this acceptable for FDQI qualification during inspection, especially in cases where English presents a significant language barrier?
