In order to achieve effective food safety systems, it is imperative to prioritize food safety training for all employees, regardless of their position in the facility. By doing so, we can guarantee that the food produced or processed is safe for consumption and the facility operates in a manner that ensures food safety regulations are never compromised.
Current Regulatory Requirements
It is worth noting that the training regulations established by the United States Department of Agriculture Food Safety Inspection Service (USDA-FSIS) and the Food and Drug Administration (FDA) share a remarkable similarity. Both demand that those responsible for Hazard Analysis and HACCP/HARPC plan development complete training programs that fully define the principles of these analyses.
Current FDA Training Regulations
To comply with FDA regulations, all personnel who handle produce covered by the Produce Safety Rule must receive training. This training should cover personnel and visitor training, food hygiene, and safety principles. Employees must also be trained on the importance of hygiene, reporting any health conditions that could contaminate produce, and their job responsibilities. Furthermore, individuals who engage in harvesting activities for covered produce must receive training to identify potentially contaminated products, assess the functionality and cleanliness of harvest-related equipment, and understand how to report or address any concerns to a supervisor or responsible party.
All sites under the FDA’s jurisdiction must provide a training program for all those involved in producing, processing, packing, or holding food. These requirements apply to both temporary and seasonal staff, with additional requirements for supervisory roles.
Also, all individuals involved in the processes mentioned above must be considered qualified individuals, which is defined by 21 CFR § 117.3 as “A person who has the education, training, or experience (or a combination thereof) necessary to manufacture, process, pack, or hold clean and safe 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.” The training for these individuals must be appropriate to their specific job function, facility, and types of food they handle, as well as cover food hygiene, food safety, personal health, and personal hygiene principles.
Furthermore, supervisors of FDA-regulated sites must possess education, training, experience, or a combination of these qualifications. Supervisors are responsible for ensuring that employees adhere to food safety practices while carrying out their job duties. Therefore, these leaders should thoroughly know the required procedures for promoting food safety.
Current GFSI Requirements
The Safe Quality Food Institute (SQFI) has established a GFSI scheme that many food processors volunteer to implement for certification. One significant component of this is training for employees across the site. The training program is a mandatory element of any SQF food safety system. Requirements of this element include:
- Accredited HACCP training for staff involved in developing and maintaining food safety plans.
- Monitoring and corrective action procedures for all staff engaged in monitoring critical control points (CCPs).
- Personal hygiene for all staff involved in the handling of food products and food contact surfaces.
- Good Manufacturing Practices and work instructions for all staff engaged in food handling, food processing, and equipment.
- Sampling and testing methods for all staff involved in sampling and testing of raw materials, packaging, work-in-progress, and finished products.
- Environmental monitoring for relevant staff.
- Allergen management, food defense, and food fraud for all relevant staff.
Additionally, SQF mandates that sites employ both a primary and substitute SQF practitioner who must complete an accredited HACCP Training course before serving in their role. Furthermore, contract service providers, such as pest control or contractors, who visit the site and perform activities that could impact food products must receive training in food safety practices specific to the site.
What to Train for
When considering what to include in your site’s training program, there should be a considerable focus on your specific needs and goals regarding their application to regulatory requirements. It is imperative to carefully evaluate and adhere to regulatory and third-party guidelines pertaining to training, as they serve as a crucial foundation for the success of a training program. Considering these requirements can ensure the training is comprehensive, compliant, and impactful for all stakeholders.
Beyond regulatory, customer, or third-party requirements, site history is also relevant when creating more training improvement opportunities. Developing and implementing training that addresses previous concerns can be beneficial if a department has a history of inefficiency or errors. Likewise, taking your equipment use and operations into account for your site training program is notably helpful when hiring new employees or moving current employees to another facility area, as everyone must understand how to use equipment safely, especially if the equipment is a Critical Control Point (CCP) or Preventive Control (PC) component.
Frequency of Training
When implementing a Food Safety Training Program, all site employees should undergo training relevant to their specific job function. Immediately upon hire, facilities should train new employees before they work with food products or materials. Reviewing, updating, and presenting training programs is the minimum recommendation. Yet many facilities benefit from increasing the frequency of specific training programs, such as GMP training. Likewise, personalized retraining and corrective action can be necessary in the case of a supervisor or manager observing an employee doing a task incorrectly or not adhering to personal hygiene standards.
Determining Training Effectiveness
The purpose of training is to provide employees with the skills and information necessary to perform their job functions in a manner that preserves product safety. Management can evaluate employee comprehension through direct observation to determine the effectiveness of observable training (GMP, Personal Hygiene, etc.). For example, if hairnets and beard nets were a component discussed during GMP training and you observe employees the following day improperly wearing their PPE, the requirements discussed during training were likely not well understood.
Another powerful way to evaluate training program comprehension is by administering a written or verbal form quiz before and after training. These assessments help determine the employees’ baseline understanding while later tracking their progress. The examination method is less significant than how the trainer utilizes and analyzes the results.
If a training program is deemed ineffective, it is imperative to prioritize retraining. Before proceeding with the retraining, assess both the training materials and delivery method for any possible areas of improvement that could enhance effectiveness.
Training Related Records
The records related to training are not only a requirement but crucial to a successful training program. Records are a facility’s means for tracking who has had training and when the refresher training is due for each employee. It is helpful for businesses to have a “training matrix” highlighting the necessary training programs for all applicable employees and noting the completion date. This matrix makes it simple to identify when annual training is due.
At the same time, keeping records of training effectiveness verification activities is vital. When observing, make sure to take detailed notes. If using a quiz or assessment, keep records of all results or initial and final scores. Records prove that you did what you said you would do within your training program. As regulatory and third-party inspectors and auditors require training, it is necessary to maintain adequate records.
Overall, implementation and continuous attention to a training program is the ideal recipe for maintaining an employee base that feels empowered to make sound food safety judgments as they carry out their job responsibilities.
Conducting On-Site or Third-Party Training Programs
Many training programs can be developed and implemented by on-site personnel. However, many businesses can benefit from, or may even require, a third-party entity to conduct the training.
If training is specific to your site, such as equipment operation, it makes sense to take that on as site training (except if the equipment is new, in this case, the manufacturer should provide initial training). In contrast, training programs that arise from regulatory, customer, or third-party audit requirements are applicable for seeking expertise from external firms with the credentials needed for obtaining training that requires accreditation, such as HACCP Training.
The HACCP Assurance Services team of highly experienced and specialized food safety consultants is prepared to bring your training programs to the next level! With a comprehensive portfolio of training options and customized offerings, we can exceed your site’s specific needs. Discover how food safety training can be simple with our experts at www.haccpassurance.com/training/
9 CFR § 417.7 – Training in Regulatory Requirements Under the Federal Meat Inspection Act, the Poultry Products Inspection Act, and the Egg Products Inspection Act
21 CFR § 112.22 What minimum requirements apply for training personnel who conduct a covered activity? In Food for Human Consumption
21 CFR § 117.4 Qualifications of individuals who manufacture, process, pack, or hold food.
SQF. Edition 9 Checklist: Food Manufacturing 2.9.2
SQF. Edition 9 Checklist: Food Manufacturing 18.104.22.168
SQF. Edition 9 Checklist: Food Manufacturing 22.214.171.124