Will the FDA require someone certified in Food Defense?

Hello,

New manager here for the QA department at my company, I came in with a HACCP cert and just did PCQI training, I keep seeing something that FDA will get harder on Food Defense so im wondering if I should take a Food Defense training. I have been in the food industry for about 7 years so its not like I know nothing but still, just trying to figure out what they may want in a company. 

Yes, they will unless you are exempt.

https://www.fda.gov/...al-adulteration

https://www.ifsh.iit...019-03-22.pdf 

Notice the asterisk at the bottom of the page - *These courses satisfy the training requirements in section 121.4 of the IA Rule.

https://www.ifsh.iit...al-adulteration .  You can always start here, some of these courses are free too.  

It depends whether you fall under the guidance, but if so, yes, the FDA requires different levels of training (or experience) depending upon role, etc.  Ref: 21 CFR 121.4(b)(2))

A couple of resources for you:

FSMA's IA rule home (where you can get resources to determine if you are under the rule): https://www.fda.gov/...al-adulteration

Article from April 2019 outlining a lot of the FDA's current thinking, etc.: https://www.fda.gov/...-acts-terrorism

"The" authorized IA training source: https://www.ifsh.iit...al-adulteration

Some Food Defense specific FDA resources: https://www.fda.gov/...ional-materials

I hope that this helps somehow.

Good luck,

Todd

PS: Guess I need to type faster; answers above.  

Thanks everyone!

You can always take this course for free.

 

FSPCA FOOD DEFENSE AWARENESS FOR THE IA RULE

• Delivery Format: Online course.
• Estimated Seat Time: 20-30 minutes. There is a 4-hour inactivity time-out, so once started,...
• Certificate: An FSPCA Certificate of Completion is issued at the end of the course...
• Cost: Free.

Upcoming Training - UC Food Safety

ucfoodsafety.ucdavis.edu/Upcoming_Training/?calitem=412640&g=88440

 

 

You can always take this course for free.

 

I did see this though my interpretation is if you are the individual in your facility responsible for conducting or overseeing the plan i.e. preparing the food defense plan, the vulnerability assessment, the identification and explanation of mitigation strategies and reanalysis  (see below or pg 20 - https://www.fda.gov/...105742/download) then you would need additional training and Food Defense Awareness wouldn't suffice .

From IFT's website - the Food Defense Awareness training is designed for "workers at actionable process steps and supervisors of workers at actionable process steps"  so not the individual(s) conducting or overseeing.

https://www.ifsh.iit..._2019-03-22.pdf

For them they'll need one of the other 4 courses mentioned on the IFT website under the heading "FSPCA Rule Standardized Curriculum Recognized by the FDA" or equivalent  -

Sources: see IFT course cheat sheet above and https://www.fda.gov/...113684/download - part C - pgs. 107-108

I have taken the course through the Illinois Institute of Technology, but I need to get this course to my operators. The issue is most of them only speak Spanish. Does anyone know if there is a version of this training available in Spanish? As some have said, this is the only FDA approved training so my employees will need this specific training.  

I have taken the course through the Illinois Institute of Technology, but I need to get this course to my operators. The issue is most of them only speak Spanish. Does anyone know if there is a version of this training available in Spanish? As some have said, this is the only FDA approved training so my employees will need this specific training.  

I have not seen one but this training by the FDA is in multiple languages. https://www.fda.gov/...employees-first

Is anyone aware of any other courses for employees that might be a bit shorter in length?

This class info was just announced earlier this week.  Their web site says a couple of hours.  I've not looked into it in detail as yet.  Just saved the email for later.  Link: https://www.ifsh.iit...al-adulteration

So our consultant said our combined experience would satisfy the need for anyone to get specific Food Defense Training.  Is that because as a small, low risk company they will likely go easy on us our first audit?  We are not "very small" as it says in the exemptions. ($1,000,000 in sales please correct me if wrong.)

Based upon your sales number, you should be exempt based upon my reading of the exemption logic.  You can (and should) verify that for yourself. 

Is your facility part of a very small business?

Reference:

FSMA IA rule: https://www.fda.gov/...al-adulteration

IA Rule Fact Sheet: https://www.fda.gov/.../98085/download

IA Rule Exemption PDF: https://www.fda.gov/.../97788/download

As for training, I will go ahead and answer that in case it is useful.  The training requirements come down to what the role someone is doing; basically, the rule requires different training levels for different activities.  For example, if you are conducting the vulnerability assessment, then you are to “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” (21 CFR 121.4©(2)).  The training site posted several times above will give you a good idea of what is needed for each role.  I would suggest, if you are doing it, to go through the FDA approved training curriculum, so that you would have one less possible issue if you were ever to interact with them.  

I hope that this helps. 

Good luck,

Todd 

PS: That's part 121.4c not a copyright symbol.