Investing in robust training can result in measurable business impact, beyond reducing liability or checking the FDA’s regulatory boxes. The FSMA regulation requires Preventive Control Qualified Individuals (PCQIs) “have successfully completed training in the development and application of risk-based preventive controls at least equivalent to that received under a standardized curriculum recognized as adequate by FDA or be otherwise qualified through job experience to develop and apply a food safety system.” (Subpart C Section 117.180 (c) (1)) Even when the person serving in the role of PCQI is qualified through job experience, FDA Investigators will expect adherence to development and use of risk-based controls as contained in the standardized PCQI curriculum material or the alternative training allowed in the regulation.
Employees serving in the role of PCQI come from a range of food safety plan experience. Many are training new members as Qualified Individuals on the food safety team; others are building a whole new team from scratch. Team members may be specialized department heads in more established companies. In newer companies, a PCQI may hold several titles and job duties within a manufacturing facility. A PCQI is tasked with managing the development and analysis of the food safety plan. The PCQI needs a team that has had sufficient training in the language and procedures of the new rules and how best to support the PCQI’s charge.
Beyond meeting the regulation, companies should train at the PCQI level to safeguard a company’s product quality, brand, and customer base. The fewer food safety-related claims you have the more that can be saved in costly recalls, loss of current or potential customers, and brand reputation. A company with a robust safety culture has a competitive advantage over competitors who are laxer in their food safety and may suffer financially and reputationally from recalls and customer quality assurance complaints. In an era when customers are increasingly seeking more information about the food they consume, being a trusted food safety brand can make a company stand above the crowd.
In addition, consistent training can help with internal culture change and worker productivity. Working on hazard analysis and defining preventive controls requires that employees show critical thinking and problem-solving skills. Team members taking a curriculum with standardized material and consistent learning objectives can reflect together to identify and document gaps and corrections to practices or processes. They can quickly apply their learning for more accurate analysis of the components of the food safety plan. This is the true impact from investment in high quality instruction – motivating employees to learn updated food safety practices, alter their behavior to reflect these practices, and make more efficient and effective decisions to keep the quality and safety of products. Well-trained food safety employees are a key factor in the protection of customers, company’s brand, and the prevention of costly food recalls. In other words, a relatively small financial investment in training at the PCQI level can have a multiplier effect on the returns on that investment. It is a strategic move on all fronts.
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