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The limitations on in-person visits brought about by COVID-19 negated the ability of facilities to add a Food Defense Qualified Individual who was certified to conduct Intentional Adulteration Vulnerability Assessments (IAVA-FDQI) because of the requirement for in-person classes.

With the pandemic not showing signs of abatement any time soon, the Food Safety Preventive Controls Alliance (FSPCA) has instituted a limited-time pilot policy allowing for virtual registration and delivery of course by an IAVA Lead Instructor.

The IAVA-FDQI course, for which TAG has two qualified lead instructors, provides participants with the knowledge to implement the requirements of conducting a vulnerability assessment under the Intentional Adulteration (IA) rule of FSMA. The course is the standardized curriculum recognized by the FDA, and provides one way of meeting the requirements for a food defense qualified individual responsible for conducting a vulnerability assessment or reviewing food defense plans.

The pilot allowing for virtual classes extends through March 31, 2021, with some caveats, such as:

  • A class can have only 8 students per instructor, with the recommendation that no more than 16 students/2 instructors be involved in a single class.
  • The virtual course must include at least 6.5 contact hours.
  • The course can be delivered in a single day, but holding the course over two days is highly recommended by FSPCA.
  • The course is designed to use the same agenda template as would be used for in-person courses.

In order to assess the efficacy of the virtual courses, FSPCA is requiring that participants complete an online course evaluation within 72 hours, which will be returned directly to FSPCA. The lead instructor is required to inform participants of the requirement, and FSPCA’s delivery of course certificates will be delayed 72 hours to allow for the submission of the evaluations. According to FSCPA, “This is an opportunity to receive feedback on the instructor as well as identifying what did/didn’t work well during the virtual course and is one of the ways to identify best practices.”

FSPCA will also conduct announced audits of some courses. When these occur, participants will be made aware that auditor(s) are observing the course, but they are not there to answer questions or weigh in as instructors.

The IAVA-FDQI course — which focuses primarily on intentional adulteration issues of the entire food system, provides information on creating and analyzing the food defense plan and evaluates processes, vulnerabilities, actionable process steps, based on the three elements — is intended for those who will be conducting their facility’s food defense vulnerability assessments using the three elements or a hybrid approach that uses the key activity types and the three elements; those who are leading a food defense team to do so; and auditors (internal or external) who evaluate food defense plans.

With an additional requirement for courses to be registered with AFDO at least two weeks in advance to enable review and approval, TAG will be working on getting its virtual course up and running for you. Keep an eye on this space for an announcement of TAG’s upcoming virtual classes, led by its two lead instructors Christopher Snabes and/or Rolando Gonzalez — or give us a call today for more information!


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