As FDA resumes its routine domestic inspections, facilities are likely to notice a new add-on to the inspection: a Q&A Food Defense “Quick Check.” Are you prepared? In the August FSMA Friday webinar, co-sponsored by SafetyChain, TAG Director of Food Safety, Christopher Snabes presented an overview of the requirements of the FSMA Intentional Adulteration (IA) Rule, new compliance dates, training options … and possible Quick Check questions.
Key takeaways from the webinar include:
The Rule. Did you know that you are subject to the IA Rule – even if you are exempted from other rules of FSMA?
Food Defense Training. The rule has a number of training requirements – From Food Defense Awareness, required for all workers, for which a free online course is available. To the much more complex fee-based trainings for qualified individuals, such as Conducting Vulnerability Assessments, which can be taught only by an FSPCA/AFDO-approved Lead Instructor (of which TAG has two), for which participants receive a certificate of training.
The Food Defense Plan (FDP). Although FDPs are facility-specific (and required for each facility), there are some very distinct aspects that are required for each FDP. This includes pre-plan prep steps, three vulnerability assessment writing options (based on KATs, 3 Elements, or a hybrid), mitigation strategy development and management, and regular reanalysis.
The Quick Checks. To “educate while we regulate,” FDA is beginning with Quick Check questions, designed to check the preparedness of facilities. An investigator may ask: Do you have a written FDP? Was it written by an FDQI? Have you identified and KATs? How are you verifying? …
Throughout the presentation Snabes provides expert insight and recommendations on IA Rule compliance, training, writing the FDP, and “passing” a Quick Check.