Under the proposed Food Safety Modernization Act rules governing animal feed and petfood, each covered facility must prepare and enforce a hazard analysis and risk-based preventative controls process (a written food safety plan). Among the items that must be included in such a plan is the requirement that a "qualified individual" prepare and oversee the entire process. Unfortunately, what makes someone qualified has not yet been fleshed out.
The definition of a "qualified individual" is someone who has successfully completed training in the development and application of risk-based preventive controls under a standardized curriculum recognized as adequate by the US Food and Drug Administration (FDA), under a program that is at least equivalent to that standardized FDA-approved curriculum, or be otherwise qualified through job experience. But, as of yet, there is no FDA-approved curriculum to either attend or compare job experience to.
The Food Safety Preventative Controls Alliance (FSPCA), a private alliance of leaders in the industry, academia and state and local food protection agencies, will be responsible for creating the standardized curriculum, with FDA offering input. The ultimate goals are that the FSCPA will:
Once the curriculum is completed and approved, the "qualified individual" will have much more solid measurements to meet.
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