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Sprout Safety Alliance UPCOMING TRAINING Kaiping Deng Institute for Food Safety and Health (IFSH) Illinois Institute of Technology (IIT) 1

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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 Slide Example-1 5

SSA Training Slide Example-2 6

SSA Training

• Education/Outreach Working Group

- ~20 Members

- Discussion topics

- Identifying sprout growers and trainers

- SSA course delivery strategies

- Trainer qualifications

- SSA timeline

7

8

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

Courses Delivery

• Train-The-Trainer (TTT) course

- Classroom training

• Sprouter course

14

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

Sprouter Course

• Sprouter course

- Classroom training

- Classroom training + Online training

16

Tentative SSA Timeline

SSA Course Delivery Begins

• Curriculum v1.0 finalized- August 2016

• TTT pilot- September 2016

• Sprouter training- October 2016

17

SSA Course Delivery Begins

FDA Regulatory Inspection Training

Michelle Smith Ph. D, FDA

NEXT 18

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)

Thank you!

http://www.iit.edu/ifsh/sprout_safety/

[email protected]

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