Standard 2 Breakout Session
Training Programs
March 11, 2014
1:30 – 5:00 pm
Morgan Poloni, MS, REHS
Program Coordinator
Alaska Department of Environmental
Conservation
Food Safety and Sanitation Program
Mark M. Reed, R.S., MPA, MPH
Branch Manager
Kentucky Department for Public Health
Food Safety Branch
Dawn Smith
Food Program Manager
Oregon Department of Agriculture
Food Safety Division
Timothy Weigner
Staff Director
U.S. FDA Office of Regulatory Affairs
Office of Partnerships
Standards Implementation Staff
Agenda
Strengthening Training Foundation
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Welcome and Introductions
Current Status of Standard 2 Implementation
Developing a State Training Plan
Building a State Field Training Plan
Q&A
Summary and Challenge
Housekeeping
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Honor time schedule
Stay on topic
Get input from everyone
Be willing to share
Respect different program cultures
Do not reference specific audits
Be creative, ask questions – parking lot
Facilitators – responsible for process
Participants – responsible for content
Focus for Change
• 47% - State programs have a training plan that ensures all
inspectors received training adequate to perform their work
assignments. (Ref. MFRPS 2.2)
• 55% - Each inspector completes a minimum of ten joint
inspections or audit inspections with a qualified trainer of food
plants in the establishment inventory and receives two
acceptable evaluations (basic level field training). (Ref. MFRPS
2.3.a)
• 38% - Each inspector completes a minimum of three joint
inspections with a qualified trainer of food plants representing
specialty area PRIOR to performing independent inspections
(advanced level training). (Ref. MFRPS 2.3b)
Objectives (Building a Training Plan)
• Identify the components of a Training Plan to support the
requirements of MFPRS Standard 2.
• Describe various resources needed for implementing basic
food inspection training, advanced food inspection training
and continuing education.
• Develop a model state training plan template to support
manufactured food inspections conducted by the State
program.
“Tell me and I forget.
Teach me and I remember.
Involve me and I learn."
- Benjamin Franklin
Training Plan Development Exercise
Foundation and Resources
For this group exercise, use the
provided Training Plan template.
Identify Foundation and Resource
components necessary for a state
program to consider for inclusion
within your training plan framework.
Populate Section 1 with additional
components.
Timeframe for exercise: 15 minutes
Section 1 – Foundation and Resources
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Training Plan Objective or Statement of Purpose
Definitions
Resources (Staffing, Funding, IT Support)
Staff/trainee information
Records (What, who, how, access and control)
Policies and Procedures (Additional training,
corrective action, poor performers)
• Career paths
• Others ?
Training Plan Development Exercise (cont.)
Basic Food Inspection Training
Using the Training Plan template, within your group
identify the components necessary for inclusion
within your basic food inspection training plan
(Section 2 of the template).
Populate Section 2 with additional
components.
Timeframe for exercise: 15 minutes
Section 2 – Basic Food Inspection Training
(Coursework)
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10 coursework areas (MFRPS)
Sources of distance or on-line training
Sources of classroom training
Staff notification process
Staff accessibility to training
Verification process for training completion, and within
required time frames
• State unique or required training
• Integration with other programs
• Others ?
Training Plan Development Exercise (cont.)
Advanced Food Inspection Training
Using the Training Plan template, within your group
identify the components necessary for inclusion
within your advanced food inspection training plan
(Section 3 of the template).
Populate Section 3 with additional
components.
Timeframe for exercise:
15 minutes
Section 3 – Advanced Food Inspection
Training (Coursework)
• 8 coursework areas (MFRPS)
• Sources of training
• Other Training
– Commodity
– Program specific
• Others ?
Training Plan Development Exercise (cont.)
Continuing Education
Using the Training Plan template, within your group
identify the components necessary for inclusion
within your continuing education training plan
(Section 4 of the template).
Populate Section 4 with additional
components.
Timeframe for exercise:
10 minutes
Section 4 – Continuing Education
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Types of Training
Classroom
Contact time and verification
Sources of training
Joint inspections or audits
Timeframe for meeting requirements
Others ?
"The only kind of learning which significantly
influences behavior is self-discovered or selfappropriated learning - truth that has been
assimilated in experience.“
- Carl Rogers
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
BREAK
Objectives (Field Training)
• Identify frequency and time requirements for field training
(basic and advanced food inspection, and continuing
education) to support successful implementation of MFRPS
Standard 2.
• Discuss various tools and resources used to conduct joint
inspections or audit inspections.
• Identify records or forms currently used for field training
(joint inspections and inspection audits).
• Evaluate the application of contract audit inspections in
support of field training requirements in MFRPS Standard 2.
Training Plan Development Exercise (cont.)
Field Training (Joint Inspections and Inspection
Audits)
Using the Training Plan template, within your group
identify the field training components necessary for
inclusion within your training plan for basic and
advanced food inspection, and continuing education
(Section 5 of the template).
Populate Section 5 with additional components.
Timeframe for exercise: 15 minutes
Section 5 – Field Training (Joint Inspections
and Inspection Audits
 Definitions and Types of Inspections/Audits
 Basic Food Inspection Field Training
• Minimum number to conduct, number of acceptable, timeframes
• Exceptions for Experienced/Seasoned Staff
 Advanced Food Inspection Field Training
• Minimum number to conduct, number of acceptable, timeframes
• Exceptions for Experienced/Seasoned Staff
 Continuing Education
• Minimum number to conduct, timeframes
 Audit tools, records or forms used
 Association with other Standards
Standard 2 Breakout Session
Training Programs
March 11, 2014
1:30 – 5:00 pm
Morgan Poloni, MS, REHS
Program Coordinator
Alaska Department of
Environmental Conservation
Food Safety and Sanitation
Program
Dawn Smith
Food Program Manager
Oregon Department of
Agriculture
Food Safety Division
Audits and Joint Inspections
What does the standard say?
Audits and Joint Inspections
What does the standard say?
Touch Points
Oregon and Alaska
• Standard 3
– Evaluating staff on manufactured food inspection protocol
– Section 3.3b (1-22)
– Oregon also incorporates 3.3b (1-22) into our field training plans
• Standard 4
– Use Appendix 4.6 (3610) for field audit
– Summary: Worksheet 4.2
Field Training
Oregon and Alaska
• Is done by experienced staff
• Trainer does have to be a qualified trainer
• Counts toward their 10 joint manufactured food
inspections
Trainer vs Trainee Led
Oregon
• Starts with trainer led retail inspections and progresses to training
in manufactured foods as the position description and readiness
allows
• Trainee leads the inspection towards the end of the training
• Sign off to do independent inspections when trainee has
demonstrated competency in key performance elements
• Joint or audit inspections are conducted in firms representative of
the food plants in the inspector’s inventory.
• Plan to conduct more joint inspections with FDA in the future
Trainer vs Trainee Led
Alaska
• Starts with trainer led inspections
• FDA may take Alaska staff out in the field
• Trainee may lead the inspection when
comfortable
• Sign off to do independent inspections
when trainee has completed two state
audits
• Joint inspections are representative of
our manufactured inventory
Smoke
Joint Inspection Log
Oregon
• Minimum of 10 Joint Inspections with a QT recorded in training
log
• At least 2 of the 10 inspections must be acceptable prior to
conducting independent inspections in basic manufactured
foods
• Field Training Plans signed by QTs
• Inspectors that were hired prior to July 1, 2011:
– For basic manufactured foods, all inspectors have been
audited using 3610
– For advanced food inspections, experience working
towards sign off on field training plans
Joint Inspection Log
Alaska
• Minimum of 10 Joint Inspections of
inventory representative of our state
• Two successful audits are required for
independent inspections
• Released to do specific types of
contract inspections
• Inspectors that were hired prior to
enrolling in the standards:
– Old audits (to recreate the 10 joint
inspections)
Helicopter ride in Dillingham, AK
Records
Oregon
• Maintain copies of the 3610 (field audit), App. 4.3 (report
audits), and App. 4.6 (worksheet) in our Salem office
• Training logs are maintained on Filemaker database
• Field Training Plans
– Basic Manufactured Foods
– FDA Contract Inspections
– Acidified Foods
– LACF
– Juice HACCP
– Seafood HACCP
Oregon Training Log
• Each employee maintains a training log to record all
trainee-led, trainer-led, joint, and audit inspections.
Oregon Field Training Plan
• Performance elements for basic manufactured foods,
example
Oregon Field Training Plan
Trainer/Trainee Signature
• Basic Manufactured Foods
Records
Alaska
• Maintain hard copies of
audits and completed logs in
Anchorage office
• Completion of required logs is
documented in the Training
Database
Two surimi processing vessels, Dutch Harbor
Joint Inspection Log
Alaska
• Maintain copies of the 3610 in their training file (Anchorage office).
• First 2 successful audits are documented on the Joint Inspection Log
Joint Inspection Log
Alaska
• Page 2
Audits
Oregon
• Phase 3 audits
• Required to complete 35 audits per year or 7% of 500 contracts
– 27 manufactured food inspectors that conduct FDA contract
inspections
– Audited facilities may be acidified (if inspector is qualified
for acidified inspections) or general manufacturing
– Try to do at least one audit/person/year
• Use the audits to satisfy Standard 2 continuing education and
Standard 4
Audits
Alaska
• Phase 3 audits
• Required to complete 21 audits per year
– 20 manufactured food inspectors
– Vary the types of facilities (LACF, Smoked,
Direct Marketers, General Food, etc.)
– Try to do one audit/person/year
• Use the audits to satisfy both the Standard 4
and Standard 2
Sitka Harbor, AK
What to do with experienced staff?
Those hired prior to enrollment in the standards
Out of the 2010 MFRPS Interpretation Paper:
Qualified Trainers
Oregon
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Basic Manufactured Food Inspection:
– Completion of assigned ORAU courses
– Completion of a field training process for basic food inspections
– Completion of 25 independent inspections
– Completion of assigned classroom courses as they become available
– Completion of 36 contact hours of classroom training and participate in at
least two joint or audit every 36 months to meet the continuing
education requirements
Advanced Food Inspection Training Standard:
– Completion of 5 independent inspections in the advanced specialty area,
– Completion of required advanced classroom courses
– Completion of at least two joint inspections in the specialty area to meet
the continuing education requirements
Qualified Trainers
Alaska
Work Planning and Funding
Alaska
• LOTS of advanced planning
• Figure out who needs coverage
• Capitalize on as many
opportunities as possible.
• Talk with FDA
Trident Facility, St. Paul Island AK
How to implement?
• Start simple!
• Don’t overcomplicate it!
• Its ok not to have a
complete plan to begin
with.
Wizard returning to Dutch Harbor
Audit Forms in Use
• Oregon
– A non-contract inspection audit form has been
created
• Alaska
– Evaluate using the 3610 form for contract audit
inspections
• Both states use form 3610 for contract audit inspections
– No modifications to the form have been made
Other Audit Forms
Oregon and Alaska
• Both states
– A modified version of the Conference for
Food Protection Field Training Plan is used
– Items on form that pertain to both retail
and manufacturing have been identified
Contact Information
Morgan Poloni, MS, REHS
Program Coordinator
Alaska Department of
Environmental Conservation
Food Safety and Sanitation Program
Morgan.poloni@alaska.gov
Dawn Smith
Food Program Manager
Oregon Department of
Agriculture
Food Safety Division
dsmith@odo.state.or.us
Questions
Creating Change
How Do You Change These Statistics?
• 47% - State programs have a training plan that ensures all
inspectors received training adequate to perform their work
assignments. (Ref. MFRPS 2.2)
• 55% - Each inspector completes a minimum of ten joint
inspections or audit inspections with a qualified trainer of food
plants in the establishment inventory and receives two
acceptable evaluations (basic level field training). (Ref. 2.3.a)
• 38% - Each inspector completes a minimum of three joint
inspections with a qualified trainer of food plants representing
specialty area PRIOR to performing independent inspections
(advanced level training). (Ref. MFRPS 2.3b)
Contact Information
Morgan Poloni, MS, REHS
Program Coordinator
Alaska Department of
Environmental Conservation
Food Safety and Sanitation Program
Morgan.poloni@alaska.gov
Dawn Smith
Food Program Manager
Oregon Department of
Agriculture
Food Safety Division
dsmith@odo.state.or.us
Mark M. Reed, R.S., MPA, MPH
Branch Manager
Kentucky Department for Public
Health
Food Safety Branch
Mark.reed@ky.gov
Timothy Weigner
Staff Director
U.S. FDA Office of Regulatory
Affairs Office of Partnerships
Standards Implementation Staff
Timothy.weigner@fda.hhs.gov