Hazard Analysis - add to existing or create new?

Morning everyone - I've been away for a while between maternity leave and then accepting another job opportunity.  It's been nice to finally catch up! Anyway... I'm now wading through my first month at a new facility specializing in animal feed.  I'm working on making sure everything is up to speed in regards to FSMA requirements and also an ISO 22000 cert.  

Two questions, and apologize if the first one has been asked before:

 - At past facilities it's been better for me to keep HACCP hazard analyses and FSMA PC hazard analyses separate.  However now that I'm only dealing with one federal jurisdiction, could I successfully combine my PC hazard analysis with the HACCP hazard analysis for the ISO cert? Has this caused issues for anyone else? 

 - Is it an issue that I have PCQI in Human Food and not Animal Food? I would say that I have enough education and experience that I wouldn't need either, but have heard it's easier just to present the FDA investigator with a certificate than go through individual qualifications such as education and experience. Would they raise questions if my certificate is not in animal food?

I wish I could assist but alas I cannot (we don't export) but Welcome Back!!

You've been missed!!!!

I hope your bundle of joy is well!

MsMars,

For your PCQI question - PCQI initially was set up by the FDA specifically to address safe food actions for food that is tagged for human consumption.  Animal consumption often has a lower standard and the general process on the two programs would be almost identical (barring a few difference in the food processing).  I would argue that your PCQI in Human Food more than qualifies you to be trained to create and maintain a food safety program in an animal food facility.

Also you can quote the ruling on what determines a PCQI - "...successfully completed training in the development and application of risk-based preventive controls, or is otherwise qualified through job experience to develop and apply a food safety system."

Your experience and your Human Food PCQI more than makes you eligible.

Cheers

I wish I could assist but alas I cannot (we don't export) but Welcome Back!!

 

You've been missed!!!!

 

I hope your bundle of joy is well!

Thank you Scampi - he is happy, healthy, and growing like a little weed. :)

MsMars,

 

For your PCQI question - PCQI initially was set up by the FDA specifically to address safe food actions for food that is tagged for human consumption.  Animal consumption often has a lower standard and the general process on the two programs would be almost identical (barring a few difference in the food processing).  I would argue that your PCQI in Human Food more than qualifies you to be trained to create and maintain a food safety program in an animal food facility.

 

Also you can quote the ruling on what determines a PCQI - "...successfully completed training in the development and application of risk-based preventive controls, or is otherwise qualified through job experience to develop and apply a food safety system."

 

Your experience and your Human Food PCQI more than makes you eligible.

 

Cheers

Brendan - Thanks, this was along my line of thinking as well. 

 - Is it an issue that I have PCQI in Human Food and not Animal Food? I would say that I have enough education and experience that I wouldn't need either, but have heard it's easier just to present the FDA investigator with a certificate than go through individual qualifications such as education and experience. Would they raise questions if my certificate is not in animal food?

MsMars, welcome back to the forums.

I am not an expert in this area/Animal Food, however, based on my interpretation in the past PCQI readings, Hazards to Animal Foods are different than to Human Foods. Yes, they are a low standard (as compared to Human Foods), but requires Hazards to be directed to the specified species. Following is a good (brief) reading about this issue.

https://www.tracegai...ans-and-animals

However, based on your experience and education, you can judge better if you are capable of satisfying the requirement, but IMO if you are planning to be in this industry (Animal Feed) for longer time, why not to get a certificate and overcome any regulatory issue related to training and understanding of the hazards and preventive controls related to Animal Foods(just my 2 cents).