Standard 2 Breakout Session
Building a State Training Plan
Mark M. Reed, R.S., MPA, MPH
Branch Manager
Kentucky Department for Public Health
Food Safety Branch
March 11, 2014
First Things First…Greetings from the
Bluegrass State!
Background: KY DPH Food
Manufacturing Section
Natasha Collins
(502) 484-3412
Food Manufacturing Inspector Areas
• Some 1100 Firms +/• Team of 5 (plus 1)
Field Inspectors
• Small Program
Jay Fillman
(270) 684-2047
Paul Rice
(606) 638-0770
Raquel Rouse
(502) 382-6312
Annhall Norris
(859) 236-8159
Initial Self-Assessment – Standard 2
Purpose –To Build a Strong Foundation
From the Ground UP
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From Self-Assessment
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– Good Job Capturing Staff
Training, but
– No formal, written, standardized
plan
To establish formal Food Safety
Branch administrative policy
regarding the training plan/pathway
for Food Manufacturing Section Staff
To ensure that all inspectors receive
basic and advanced food inspection
training as well as continued training
and education in order to adequately
perform their work assignments and
continue to develop professionally
Highly Trained and competent
inspection team essential in building
a solid foundation for a highly
functional and strong food protection
program
Staff Training and Development Plan—
Level I Web Courses
• FDA ORA-U Courses:
– Complete Registration w/in
30 days from employment
– Complete Manufactured
Foods Curriculum w/in 90
days of employment (some
30+ courses)
– Forward
Certificates/Transcript to
Designated Training and
Compliance Officer
• FEMA Incident Command:
Complete w/in 180 days from
employment:
– IS-100.b Introduction to
Incident Command System
– IS-200.b ICS for Single
Resources and Initial Action
Incidents
– IS-700.a National Incident
Management System (NIMS)An Introduction
– IS-800.b National Response
Framework – An Introduction
Staff Training and Development Plan —
Level I Web Courses
• FDA Food Defense 101
– Food Defense Awareness
for the Food Professional
– Food Defense Awareness
for the Front-Line
Employee
– Food Defense Regulations
– ALERT for Owners and
Operators of Food Facilities
• Complete w/in 180 days of
Employment
• Certificates forwarded to
Designated Training and
Compliance Officer
Staff Training and Development Plan —
Level I Live Classroom
Complete w/in 24 Months of
Employment:
• FD152 Food Processing
Technology
• FD170 Application of the Basics of
Inspection and Investigation
• FD180 Application and Evidence
Development (Replaces Both 150
and FD151)
• Segment One Seafood HACCP
Alliance Course and Segment Two
Live Training
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*Better Process Control School
*AIB International Labeling of FDA
Regulated Foods (or Equivalent
Course Approved by Management
The asterisked (*) courses shall be
considered optional where agency travel
restrictions or funding limitations are
encountered.
Escape Clause: It shall be understood
that, under extenuating circumstances
(including but not limited to class
availability, and program funding/travel
restrictions), an extension of these time
limits may be granted by the employee’s
direct line supervisor.
Staff Training and Development Plan —
Level I Joint/Audit Field Inspections
• 10 field-level, Joint/Audit
Inspections with Qualified
Trainer to be Completed w/in
18 Months of Employment
• Field Inspector Must Receive at
least Two Acceptable
Evaluations
• If Competency is Demonstrated,
Lower Number than 10
Inspections May be Completed
(Must Still Receive Two
Acceptable Evaluations)
• Field Training to be Captured on
Appropriate Forms and
Submitted to Designated
Training and Compliance Officer
• Successful Completion of this
Requirement, Along with Level I
On-Line and Live Trainings
Qualifies Inspector for GMP (nonSpecialty Area Inspections)
Level II Advanced (Specialty Area) Food
Inspection Classroom Training
To Be Completed w/in 36 Months
of Employment:
• FD202 Conducting Acidified
Food Inspections
• FD304 Low Acid Canned Food
Inspections (*Replaces FD203)
• FD203 Conducting Low Acid
Canned Food Inspections
• FD219 Juice HACCP and
Conducting Juice Inspections
• FD249 Conducting Seafood
Inspections
Additionally, FDA StateStandardized Shellfish Officer
(SSO) and Shellfish Program Field
Inspectors to Complete:
• FD245 Shellfish Plant
Standardization (*Replaces
both FD140 Basic Shellfish
Plant Sanitation and FD241
Shellfish State Standardization
Officer)
Level II “Specialty Area” Joint Field
Inspection/Audit Inspections
To be Completed Within an
Additional 18 Months and Prior to
Independently Conducting an
Inspection of a “Specialty Area”
Plant:
• Successful Completion of each
“Specialty Area” Live Training
• Field Inspector to have
Conducted Minimum of 3 Joint
Inspections of Each “Specialty
Area” firm with Qualified Trainer
• Field Inspector Shall Have
Received a Total of 2 Successful
Evaluations for each “Specialty
Area” firm.
• OTJ Training Inspections to be
Properly Documented and
Submitted to Training &
Compliance Officer
“Escape Clause” for Experienced
Inspection Staff
• Signed Affidavit Utilized to
Affirm Inspector’s
Experienced inspectors hired
Competence to Conduct Initial
before KY Food Safety Branch
(GMP) and “Specialty Area”
enrollment in MFRPS (2011) will
Inspections
be granted an exemption from
“initial” and “specialty area” field • Does Not Eliminate
training provided they remain
Requirement for Standard 4
proficient in their inspectional and
Field Inspection Audits
documentation duties…
• No Exemption for Web-Based
or Live Classroom Training
Qualified Trainer…
• Successfully Completed
KY Definition: Any Food
Advanced Food Inspection
Manufacturing Section Inspector
Training Coursework and Field
(or Qualified FDA Inspector)
Training in Any Areas Where
Recognized by the Food Program
the Trainer Performs Advanced
Manager as Having Field
Training
Experience and Communication
Skills Necessary to Train Other
• See MFRPS Interpretation
Investigators, and Who Has:
• Demonstrated Competency for
Basic food Inspection Training
to the Food Program Manager
(or FDA District Office); and
Level III Advanced (Response) Training
To Be Completed in a Timely
Manner, as Class Space and
Funding are Available:
• ER220 Traceback
Investigations
• ER321 Produce Farm
Investigations
• FD325 Foodborne Illness
Investigations
• PER-273 NCBRT (LSU) A
Coordinated Response to Food
Emergencies
• PER-298 NCBRT (LSU) Team
Approach to Foodborne
Outbreak Response
And Just When You Think You’ve Reached
the Finish Line..
Continuing Education and
Training Requirements:
• Each Manufactured Foods
Inspector to Complete a
Minimum of 36 Contact Hours
of Classroom/Continuing
Education Every 36 Months
• Mostly Satisfied by KY
“Registered Sanitarian”
Requirement of 10 Contact
Hours Per Year
• R.S. Renewal Card to Training
and Compliance Officer
• In Reality No Finish Line
• Continuous Learning &
Professional Development
Examples of Continuing Education and
Training
• Completion of Additional
Web-Based or Live Training
Courses
• Attendance at Professional
Association
Meetings/Conferences
– KAMFES
– AFDOSS
– AFDO
– NEHA
• In-House Staff Development
and Training
IMPORTANT: Maintain Agendas,
Certificates, and other Proof of
Attendance
Training Records and Documentation
• Affidavits for
• Training and Compliance
Courses/Continuing Education
Officer’s Responsibility to:
with Missing Documentation
– Maintain History of Training
• Each Employee Responsible
Provided to Each Inspector
for Promptly Forwarding to
Designated Training and
– Maintain Pertinent Training
Compliance Officer:
Records for Each Inspector
– Agendas
– Certificates of Completion
– Joint Inspection
Documentation
– Certificates of Attendance
– Current R.S. Renewal
Certification
that Document Completion of
Standard 2
Staff Included in Training Policy
• Policy Applies to Food
Manufacturing Section Field
Staff Whose Job Duties
Include:
– Federal/State Food
contract Inspections
and/or
– State-Level Inspections of
Food Processing, Storage
or Distribution Firms
• Section Supervisor to
Complete all Online/Live
Classroom and Continuing
Education Provisions (Exempt
From Field Training)
Failure to Comply
• Consider Adding FTC Clause
May Result In:
• Reassignment of Employee
• Ineligibility for FDA-Sponsored
Training
• Other Disciplinary Action in
Accordance with Office of
Human Resource
Management (OHRM)
Provisions, Depending Upon
Circumstances
“Hardship Clause”
Meant to Address:
• Employee Fiscal
Hardship (Up Front
Expenses, Hotel, Per
Diem, etc.)
– “Company Card,” etc.
• Other Employee Issues
(Family, Medical), etc.
It is understood that in situations where
an employee’s up-front expenses
(mileage, meals, lodging), prior to agency
reimbursement, would create a severe
economic hardship on the employee,
exceptions may be made to this policy,
including the granting of additional time
to complete live training requirements.
Such situations will be evaluated on a
case-by-case basis by the employee’s
direct line supervisor and Branch
Manager…
Considerations & Lessons Learned
(In No Particular Order)
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Beg, Borrow or “Steal” from Colleagues
Expect Multiple DRAFTS, Reviews
Revisions
Must Have Leadership Buy-In
Must be Sustainable
Include Time Frames
Exceptions for Seasoned Staff
Where are Records Maintained
Who is Responsible for Training and
Continuing Educational Records
How Will Records Be Maintained (Hard
Copy or Electronic)
Compile Course Descriptions
Expiration Date on Courses
Course Pre-Requisite Challenges
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Will Plan Create a Career Ladder for
Employee Advancement/Can It
Include Hyperlinks in Training Plan
PHAB Accreditation Documentation
MFRPS Requirements
• Written, Documented
Training Plan
– We’ve Got One Now!
• Plan Implemented
– Effective January 1, 2014
– Ask Us Next Year How
Well Its Working
– Some Recalibration or
Adjustments May be in
Order
Contact Information
Mark M. Reed, R.S., MPA, MPH
Branch Manager
Kentucky Department for Public Health
Food Safety Branch
Email: Mark.Reed@ky.gov
Phone: (502) 564-7181