As the date for compliance with the Food Safety Modernization Act (FSMA) looms near, many companies are taking a closer look at their food safety practices and the personnel they have employed to carry out new testing procedures and the documentation requirements that follow.
One of these requirements calls on a “qualified individual” to prepare the food safety plan, develop the hazard analysis, validate the preventive controls, review records and conduct a reanalysis of the food safety plan (or oversee these activities). But what exactly is meant by the term “qualified individual?” Food Safety Magazine explains that it may not be as cut and dry as some may think.
According to FMSA, to be qualified, “an individual would be required to successfully complete training in accordance with a standardized curriculum or be otherwise qualified through job experience to develop and apply a food safety system.” Based on this definition, the article suggests a few points that senior management should evaluate first and foremost. These include an employee’s ability to:
- Understand the requirements of the law and how to implement it
- Search and find all the regulations that are applicable in their specific industry
- Read and understand the requirements
- Develop documentation and procedures that can be validated
- Effectively train employees using those validated procedures
- Verify they are capable of performing the activities according to such procedures
While the qualified individual should successfully be able to perform the tasks mentioned above, there is no specific qualified individual training, test or certificate, or even an exact process, that would deem an individual as qualified.
Used as an example in the article, is the fact that many people obtain degrees in college. However, when they start working, they are not found to be able to deliver the results expected. On the other hand, many people don’t have a college degree and they excel in their jobs. Their point here is, there is more to determining someone’s capabilities than the training or education they may have. In the case of food safety, attitude is another major factor and one that senior management should take into consideration when evaluating their personnel and selecting a qualified individual.
The article explains that having a good attitude is crucial for a qualified individual because it will be what keeps them motivated to continue trying even after failing. Having the right attitude towards their responsibilities as a qualified individual is also very important and senior management can assist in this effort by promoting positive change around the implementation of FSMA in their facility.
There are other qualities suggested for a qualified individual including the ability to monitor their procedures and maintain evidence that they were performed. If there is a deviation in their process, they also must be able to identify, isolate, assess and decide the final disposition of product that might be affected and develop an action to prevent reoccurrence. In all, it is senior management who is responsible for evaluating their employees, appointing a qualified individual, and deciding how they will appropriately adhere to the new guidelines of FSMA.
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