Preventive Controls for Animal Food: Training Requirements
By definition, a Qualified Individual is “a person who has the education, training, or experience (or a combination thereof) necessary to manufacture, process, pack, or hold safe animal food as appropriate to the individual’s assigned duties.” A qualified individual may be, but is not required to be, an employee of the establishment. A qualified individual must also receive training on animal food hygiene and safety, including the importance of employee health and personnel hygiene as appropriate.
Basically, anyone who takes part in the process of producing animal food is required to be a qualified individual. The FDA has not mandated any specific training to fulfill this requirement. Therefore, it is up to each establishment to document the training offered to employees and decide (and be able to defend) if it is “adequate” according to the rule.
Preventive Controls Qualified Individuals (PCQI)
On the other hand, a Preventive Controls Qualified Individual (PCQI) is a qualified individual who has 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 is otherwise qualified through job experience to develop and apply a food safety system. It is important to remember that a PCQI for a facility is not required to be an employee of that facility, but it is highly recommended to have someone at the facility during an inspection who is prepared to answer questions about the food safety plan.
A PCQI is responsible for*:
1. Preparation of the food safety plan
2. Validation of the preventive controls
3. Determination that the validation is not required
4. Review of records
5. Reanalysis of the food safety plan
6. Written justification for the validation to be performed in a timeframe that exceeds the first 90 calendar days of production
7. Written justification for review of records of monitoring and corrective actions within a time frame that exceeds 7 working days
8. Determination that reanalysis can be completed and additional preventive controls validated as appropriate to the nature of the preventive control and its role in the facility’s food safety system, in a timeframe that exceeds the first 90 calendar days of production
*Must be completed by OR under the direction of the PCQI
PCQI Training at NC State
PCQI training is offered at NC State University on an as-needed basis. If you are interested in completing the course, please contact Marissa Herchler for more information or to be placed on the list.