Mandatory Compliance Requirement by FDA for Training in HARPC and HACCP

Readers of these blogs may be aware that we had intimated that FDA had issued a final notice in Docket # FDA-2011-N-0920 dated 15th September 2015 on compliance requirements for covered facilities manufacturing, handling or storing food for human consumption. Now they have posted a summary of the Final notice reproduced below.

“The Food and Drug Administration (FDA or we) is amending our regulation for Current Good Manufacturing Practice in Manufacturing, Packing, or Holding Human Food in two fundamental ways. First, we are modernizing the long-standing current good manufacturing practice requirements. Second, we are adding requirements for domestic and foreign facilities that are subject to our regulation for Registration of Food Facilities to establish and implement hazard analysis and risk-based preventive controls for human food. We also are revising certain definitions in our regulation for Registration of Food Facilities to clarify the scope of the exemption from registration requirements provided for “farms” and, in so doing, to clarify which domestic and foreign facilities are subject to the requirements for hazard analysis and risk-based preventive controls for human food. We are taking this action as part of our announced initiative to revisit the current good manufacturing practice requirements since they were last revised in 1986 and to implement new statutory provisions in the FDA Food Safety Modernization Act. The rule is intended to build a food safety system for the future that makes modern, science- and risk-based preventive controls the norm across all sectors of the food system.”—Source FDA web site posted at 80 FR55908 on Sept’ 17, 2015

Attention is drawn to the highlighted point that every facility must have hazard analysis risk based preventive control plan in place. Compliance to this final rule begins in September 2016 and very few small companies have been exempted up to September 2018 after which it becomes mandatory for all. In addition to this FDA has announced that every facility should have a trained and qualified person for FSPQI (Food safety Product Quality Initiative) which includes trained professionals for HACCP and HARPC (revised 21 CFR 110)

According to David Walpuck a certified professional in Food safety and an administrator of Food Safety Professionals,  it is not only essential to train a person in food safety but it is also imperative to refresh, test and retrain all food safety professionals for safety in food for Human consumption.

Quality Systems Enhancement Inc. (QSE) has been in the business of training, coaching and consulting over 25 years and has helped several organizations in achieving their goals of certifications and training. QSE trains people for competence in doing the job they are assigned. QSE’s expertise lies in training and coaching people in all GFSI recognized standards Such as FSSC 22000, BRC, SQF, HACCP and HARPC plans. QSE ensures intent comprehension of standards and FDA compliance requirements Training at QSE are interactive and motivational

FDA is holding 3 Public meetings on FSMA final rule as follows:

First Public Meeting: June 7, 2016, 8:30 am – 3:00 pm

The Hilton Costa Mesa 3050 Bristol Street Costa Mesa, CA 92626

Please note the following important dates:

  • May 25, 2016: Closing date to request special accommodations due to a Disability
  • May 26, 2016: Closing date for Registration

Second Public Meeting: June 15, 2016, 8:30 am – 3:00 pm

Renaissance Meadowlands Hotel 801 Rutherford Avenue Rutherford, NJ 07070

Please note the following important dates:

  • June 2, 2016: Closing date to request special accommodations due to a Disability
  • June 3, 2016: Closing date for Registration

Third Public Meeting: June 21, 2016, 8:30 am – 3:00 pm

Double Tree Suites by Hilton Hotel Detroit-Downtown Fort Shelby 525 W Lafayette Boulevard Detroit, MI 48226

Please note the following important dates:

  • June 9, 2016: Closing date to request special accommodations due to a Disability
  • June 10, 2016: Closing date for Registration

Registration and Additional Information