sprout safety alliance - institute for food safety and health · sprout safety alliance (ssa)...
TRANSCRIPT
Sprout Safety Alliance
UPCOMING TRAINING
Kaiping Deng
Institute for Food Safety and Health (IFSH)
Illinois Institute of Technology (IIT)
1
Agenda
- SSA curriculum overview
- How to become a SSA Trainer
- Training delivery and timeline
- FDA regulatory inspection training
- Q & A
2
Sprout Safety Alliance (SSA)
• Goal- to enhance the sprout industry's
understanding and implementation of the
Produce Safety Rule and best practices
- Develop a core curriculum
- Establish training and outreach programs
3
SSA Curriculum
Welcome and Course Objective
Hazards
1. Sprout Safety Hazards
Sanitary Practices and Food Safety
Fundamentals
2. Safe Sprout Production Environment
3. Employee Practices
4. Cleaning and Sanitizing of Buildings and
Equipment
5. Environmental Monitoring: Sanitation
Verification
6. Environmental Monitoring: Listeria
Control
Food Safety Guidance Specific for Sprout
Production
7. Seed Purchasing, Receiving and Storage
8. Seed Treatment
9. Spent Irrigation Water and Sprout Testing
Other Operation-Related Programs
10. Additional Control Programs
11. Recordkeeping Procedures
Outline of FDA Regulation
12. Overview of the Produce Rule
Appendix
4
SSA Training
• Education/Outreach Working Group
- ~20 Members
- Discussion topics
- Identifying sprout growers and trainers
- SSA course delivery strategies
- Trainer qualifications
- SSA timeline
7
Trainer Qualifications Overview
• Five competency areas
• Completing the SSA Train-The-Trainer
course
• Application being reviewed by the SSA
Trainer Selection Committee
9
Five Competency Areas
• Knowledge of Food Science and Microbiology
• Working Experience in Food Safety
• Knowledge of Sprout Operation
• Knowledge of the FSMA Produce Safety Rule
• Adult Training Experience
Video: Safer Processing of Sprouts
http://postharvest.ucdavis.edu/libraries/video/
10
SSA Trainer Development Process
SSA Trainer Development Process Flowchart
Interested individual fills out SSA Trainer
Application Form using the link on SSA website
SSA Trainer Selection Committee receives
notification to review candidate
The interested
individual will be
encouraged to
resubmit
The system sends notice to approved
candidates
Certificate issued to Lead
Instructor via LMS
Instructor list on SSA
website will be updated
via LMS link
Approved
Not
Approved
Legend
SSA
IFPTI
Trainer Candidate
Interested individual attends SSA Train-The-Trainer (TTT) course
18
4, 3, 3, 4, 4
SSA committee members (A, B, C, D) score
the application on 5 competency areas
(scale 1-5)
A D C B
3, 2, 4, 3, 3 4, 3, 2, 2, 3 1, 3, 4, 3, 5
14 16 15
Avg. 15.75
Cut-off score 15
IFPTI creates new
instructor profile in LMS
11
FSPCA Lead Instructor Application
Website
https://fspca.force.com/FSPCA/s/li-public-
guidance
SSA Trainer Application website is under
construction
12
SSA Trainer Responsibilities
• Notifying SSA of a scheduled course
• Obtaining all necessary course manuals for
each participant
• Collecting participant fees and submitting
certificate fees to SSA
• Compiling the course evaluations and
preparing a Course Completion Report
• Attending mandatory training held by SSA
13
TTT Course
DAY 1
Chapter 1 -5
DAY 2
Chapter 6 -10
DAY 3
Chapter 11-12
Instructions to SSA trainers
• SSA trainer application
• How to use LMS
• Procedure of hosting a SSA course
• Rules for course modifications
15
Tentative SSA Timeline
SSA Course Delivery Begins
• Curriculum v1.0 finalized- August 2016
• TTT pilot- September 2016
• Sprouter training- October 2016
17
Regulatory Inspections 19
Approach – inspections are just one tool to promote compliance
Scope of inspection program - sprout operations subject to the Produce Safety Rule and operations that are exempt from the Produce Rule but still subject to the Food, Drug and Cosmetic Act (the Act)
Comprehensive Inspections: covering all relevant provisions of the Produce Rule / the Act.
Targeted Inspections: focus on specific provisions, practices, conditions or sprout type.
Regulatory Inspection Objectives 20
Facilitate compliance with the relevant provisions of
the Produce Rule and the Act
Measure compliance and identify issue areas to
help focus future efforts (e.g., education, outreach,
training, guidance development and implementation
efforts) and prioritize future inspections
Initiate compliance actions when necessary
Regulatory Inspections 21
Common Principles:
Drive compliance through education and implementation of corrective actions when noncompliance is identified
Establish constructive relationships between industry and regulators
“Educate while we regulate”
Apply a standardized approach to inspection and compliance strategies that results in consistent decision making
Regulatory Inspections 22
Differences:
FDA will likely perform the majority of the routine
surveillance inspections at sprout operations
FDA will participate in joint inspections with State
counterparts and/or provide technical expertise
when requested by the State
May also leverage inspections conducted by States
that are interested in conducting sprout inspections
Sprout Inspection Cadre 23
Specific skill set needed to perform inspections at sprout
operations
Use a specially trained cadre from FDA District Offices
and States participating in sprout operation inspections;
ideally, with familiarity with sprout operations
SSA training would be a prerequisite for Regulatory
Sprout Inspection training
Cadre limited in number and strategically located
Cadre would do other food safety inspections as well
Regulator Training Timeline 24
October 2015: Workgroup to identify competencies needed for conducting sprout inspections
March 2016: Job Task Analysis to outline the associated duties, tasks, and steps
April – October, 2016: Develop training content - DHRD, University of Tennessee (with external SMEs)
September 2016: Walk-through draft on-line and face-to-face sprout inspection training content
Early 2017: Pilot/deliver training in strategic locations
Mid 2017: Begin inspections at largest sprout operations
Staggered Compliance Dates 25
January 2017:
Large Sprout Firms (average annual produce sales > $ 500,000)
January 2018:
Small Sprout Firms (>$ 250,000 but < $ 500,000)
January 2019:
Very Small Firms (> $25,000 but < $ 250,000)