I have been asked quite a bit about food-safety training, for production employees and for quality assurance and other food-safety monitors. What should they be trained on, how often, etc.?
While there have been attempts to establish industry baselines for minimal training by different organizations, USDA-FSIS has been quiet on the subject, at least so far.
To establish some sort of baseline, I thought I would simply submit a FOIA request and use FSIS training data as support for my recommendations. The idea was, since those inspectors are in the food-safety/inspection business, they would be a good example to use. Unfortunately, we won’t be using the data from FSIS to establish any sort of baseline for training. Having worked as a DDM with FSIS just more than three years ago, I am very aware of its systems and how to get data from them. My initial FOIA request was denied because the agency claimed it would take too long to get the information put together. I pushed the issue by filing appeals, etc. Finally, I was sent the data I requested.
After reviewing it, I think you will understand why FSIS didn’t want to share it — and why we can’t use it to establish any sort of baseline for food-safety training.
We have two data sets from the FOIA request: training completed by Grade 8 HIMP employees at swine plants and training completed by non-HIMP GS 5 and 7 inspectors at all other swine plants. The vast majority of training is Web-based — HIMP inspectors take 97 percent of their courses online.
For HIMP inspectors, approximately 1 percent of courses are related to humane handling, 5 percent are related to exports, 9 percent are related to food safety and 73 percent is “other training” (see below). In comparison, for the non-HIMP inspectors, 2 percent of courses are related to humane handling, 2 percent are related to food safety and 86 percent are related to other training. I wouldn’t expect to see much, if any, export training at the traditional plants, as those inspection personnel don’t have much to do with the export process.
“Other training” taken by USDA-FSIS inspectors was typically based on getting along in the workplace or personal employee improvement. Some of the classes taken included:
- Reasonable accommodation
- Diversity and inclusion
- Alternate dispute resolution
- Weight loss tips
- Mom-tested super tips
- Accounting for sales returns
- Equal Employment Opportunity
- Workplace safety and health
By moving the training from predominately classroom to a Web-based training format, FSIS is saving huge sums of money; however, why is the majority of the training focused on topics other than food safety?
None of this helps us with our baseline. So what is my recommendation? I go back to my time in the U.S. Army as a food inspector. The Army has a very robust training regimen that is focused on creating food inspectors who are knowledgeable in all aspects of food safety and quality assurance, and it helps make sure they stay that way.
Training can and should be presented in a variety of ways, be it lectures, on-the-floor correlations, outside sourced, etc. All employees should be tested for knowledge and have areas that need improvement identified.
For production employees, I recommend an initial basic food-safety training that covers your GMPs, SSOPs, etc., sufficient for them to do their jobs in a sanitary manner. I recommend quarterly training focused on potentially risky areas — cross-contamination prevention, for example — followed by an annual refresher that again covers your basic sanitation programs.
For QA personnel, it is a bit more complicated as it depends on their actual job functions; however, a basic food-safety course with special emphasis on record-keeping requirements on initial training and, as with production employees, quarterly training focused on problem areas. Annual refresher training that covers your programs and how they fit into your system would be appropriate.
For HACCP managers or QA managers that have food-safety program development responsibilities, I recommend the International HACCP Alliance basic training regimen of SSOP, basic HACCP, then advanced HACCP. I also recommend they attend some sort of annual training to keep up with advances in technology, processes, regulations and science. There are many opportunities hosted by the different industry trade associations. For example, the AAMP Validation Seminars or NAMI’s outlook conference are both good choices.
Based on your testing feedback, I also recommend focused individual training if an employee is weak in an area. The supervisor or trainers can retrain to ensure the employee understands what he or she needs to know.
As an industry, we need to establish a basic industry standard that outlines initial training and refresher training. It would be a useful tool for the industry and help us avoid government-mandated training.
The industry simply needs to do it before FSIS mandates, “Do as I say, not as I do,” with regard to food-safety training. NP