by Elise Forward, EAS Independent Consultant
I will admit to being biased on the many benefits of becoming your food firm’s Preventive Controls Qualified Individual (PCQI). It’s an important position, one required by FDA for ALL food manufacturing and warehouse facilities. The PCQI has responsibility for design, implementation and oversight of every aspect of a facility’s food safety:
- Written food safety plan (compliant with all parts of the FDA Preventive Controls regulation)
- Supplier management (what protocols are in place to ensure they meet your stringent requirements?)
- Employees (do they understand the food safety culture and how to execute their duties?)
- Facilities (the best laid plans are foolhardy without equally diligent attention to storage, equipment maintenance, cleaning and sanitation).
- Transportation (once your safely produced product is for retail-ready, how safe are the conditions under which it will be shipped?)
So, why should you register for the next Preventive Controls for Human Foods (PCHF) virtual course offered by EAS and earn a PQCI certificate? You’ll get a solid foundation for food safety knowledge by an experienced Food Safety Preventive Controls Alliance Lead Instructor and receive FDA recognized training on becoming a PCQI.
Prior to PCHF and PCQI, most food safety knowledge was garnered through on-the-job experience or HACCP training and there was little consistency, with some HACCP training not addressing food safety fundamentals such as human pathogen microbiology or other food science areas. Because of this, some of those responsible for food safety had an incomplete understanding of microbiology, sanitation, chemical contaminants, physical hazards, completing a risk-based hazard analysis, environmental monitoring, supplier management, laboratory results, etc. PCQI training gives everyone a broad-based, strong, comprehensive, consistent food safety starting point–a foundation.
PCQI builds on previous knowledge. Many people come to PCQI classes with previous experience in HACCP. To help them bridge the gap between the HACCP model and the Preventive Controls model, I ask them to think about the training as “HACCP on steroids” or for international students, “HACCP plus, plus, plus.” Preventive Controls takes into consideration reasons for some of the industry’s major recalls: environmental contamination and allergen contamination, recognizing that in many cases, manufacturers “inherit” the problems from their suppliers. Therefore, Sanitation, Allergen, and Supply Chain controls were needed in addition to the traditional Process controls (CCPs plus prerequisite programs). The PCHF training walks through the important paradigm shifts needed for to incorporate and implement the “preventive control” concept and required building blocks for a better and more effective food safety program that is cohesive and sensical.
Who do the fundamentals of PCQI apply to? Everyone!
Food safety and quality teams – This is an obvious one but all food safety/quality professionals, both seasoned and new, benefit from diligent and regular food safety trainings. But, what about the less obvious such as…
Sanitation teams – A company cannot produce safe food without appropriate cleaning and sanitation. A sanitation team trained in PC will ultimately benefit the company through an understanding of “hows” and “whys” of cleaning and sanitation as well as how they fit in with the overall food safety plan.
Executive team – The responsibility for the overall food safety of a product falls on the shoulders of the “owner, operator, or agent-in-charge.” In other words, the most senior level person at the facility. FDA is serious about this and the Preventive Controls rule requires that the food safety plan be signed by this individual. An in-depth understanding of PCHF, as well as the responsibilities of the PCQI, is imperative. In addition to the overall oversight of the Food Safety Plan, it is the responsibility of the owner, operator, agent in charge to take a lead role in setting the food safety culture of the organization/site. Being armed with this appropriate knowledge enables support to the food safety teams and ensures appropriate resources are available to prevent food safety issues.
Research and Development – Similar to Purchasing department, R&D teams are involved in food safety early in the process. From qualifying new ingredients, suppliers, etc. they can help to prevent the need to “red light” a project in its last stage of development for quality or food safety violations.
Purchasing teams – Supply chain work is hard enough… and it is time-consuming. A purchasing team’s understanding of the necessary documentation and traceability required by the food safety/quality department is beneficial, as well as understanding the reasons purchasing must not be finalized until all documentation is in order. Flow, efficiency and a team approach are fostered when the purchasing team and food safety/quality goals are aligned.
Financial team – Having the financial team’s support when a supplier is not providing the necessary information or meeting the company’s food safety/quality requirements is key. The financial team lead works alongside the food safety and quality departments to mitigate risk. Discussions about “cost of quality” principles are important, with prevention always more cost effective than Failure Costs (whether internal or external).
Maintenance – A food manufacturing facility’s maintenance staff are critical to keeping the equipment operational and the finished product being shipped. However, without an understanding of food safety, considering their access to equipment product contact surfaces as well as to all parts of the facility, the maintenance team may not understand the hows and whys of maintenance to a high state of hygiene. In such cases, maintenance staff can inadvertently easily become a primary source of food contamination. Adequate food safety training is a must.
Food Safety is everyone’s business, from purchasing to distribution and everyone in between. Becoming your company’s PCQI is an important responsibility and one that sets the tenor for the entire operation. Ensure you have the necessary knowledge and skills to be a positive contributor to your company’s food safety efforts by registering for the EAS virtual PCQI Training. Upon successful completion, you’ll receive the Food Safety Preventive Controls Alliance (FSPCA) PCQI certificate, recognized by FDA. Our next training begins April 27, 2021, and we offer discounts to companies who register multiple attendees and to EAS clients.
Posted in Foods, Issue of the Month.