Food Safety
search
Ask Food Safety AI
cart
facebook twitter linkedin instagram youtube
  • Sign In
  • Create Account
  • Sign Out
  • My Account
Food Safety
  • NEWS
    • Latest News
    • White Papers
  • PRODUCTS
  • TOPICS
    • Contamination Control
    • Food Types
    • Management
    • Process Control
    • Regulatory
    • Sanitation
    • Supply Chain
    • Testing and Analysis
  • PODCAST
  • EXCLUSIVES
    • Food Safety Five Newsreel
    • eBooks
    • FSM Distinguished Service Award
    • Interactive Product Spotlights
    • Videos
  • BUYER'S GUIDE
  • MORE
    • NEWSLETTERS >
      • Archive Issues
      • Subscribe to eNews
    • Store
    • Sponsor Insights
    • ASK FSM AI
  • WEBINARS
  • FOOD SAFETY SUMMIT
  • EMAG
    • eMagazine
    • Archive Issues
    • Editorial Advisory Board
    • Contact
    • Advertise
  • SIGN UP!
RegulatoryFDAFSMA

Who Is “Qualified” to Implement FSMA?

June 17, 2014

Are you prepared to implement the new requirements of the Food Safety Modernization Act (FSMA) and do you have the appropriate staff to help you do so? The answer is that no one knows—not even the U.S. Food and Drug Administration (FDA). Two of the key pillars of FSMA are the proposed rules relating to the manufacture of human food and the manufacture of animal food. While both require current Good Manufacturing Practices (cGMPs), the new and somewhat foreboding process that is being required for both is referred to as a Hazard Analysis and risk-based preventative controls. And it’s still not clear who is qualified to perform that process.  

Under the proposed rules for both human food and animal food, each covered facility would be required to prepare and enforce a Hazard Analysis and risk-based preventative controls process—also called a “written food safety plan” (which sounds a little friendlier). The written food safety plan would be required to include the following:

• A Hazard Analysis that identifies and evaluates known or reasonably foreseeable risks for each type of food manufactured, processed, packed or held at the facility. This analysis looks for potential hazards beyond the critical points-type of analysis.

• Preventive controls must be identified and implemented in response to any risks identified in the Hazard Analysis to prevent or significantly minimize those risks.

• Monitoring procedures must occur and be overseen to provide assurance that the risk-based preventive controls are consistently performed and records must be maintained to document that monitoring has occurred and its results.

• The safety plan must identify corrective actions that would be taken if preventive controls are either not properly implemented or fail. Corrective actions must also include a written recall plan.

• Verification activities must occur to ensure that preventive controls are effective. If verification indicates that the preventive controls are not effective, or if new products or procedures are introduced, a new Hazard Analysis is necessary.

• Facilities would be required to keep written records of their food safety plan, including the underlying Hazard Analysis. They also would be required to keep records of preventive controls, monitoring, corrective actions, recall plans and verifications.

• “Qualified Individual(s)” must prepare and oversee the entire process.

Perhaps the most ambiguous term in any of the new FSMA proposed rules is the term “qualified individual.” Both the human food and animal food manufacturing rules mandate that a “qualified individual” (or individuals) must prepare the food safety plan, develop the hazard analysis, validate the preventive controls, review records and conduct any reanalysis of the food safety plan (or oversee these activities). The definition of a qualified individual is someone who has successfully completed training in the development and application of risk-based preventive controls under a standardized curriculum recognized as adequate by the FDA, under a program that is at least equivalent to that standardized FDA-approved curriculum, or be otherwise qualified through job experience.

Thus, a qualified individual must have completed a standardized FDA-approved curriculum or be equally qualified through other training or job experience. Unfortunately, no standardized FDA-approved curriculum has yet been created or approved for FSMA. Likewise, with no FDA-approved curriculum it is not possible to determine what constitutes equivalent training or job experience.

FDA has entrusted the responsibility for creating the standardized curriculum to the Food Safety Preventative Controls Alliance (FSPCA), a private alliance of leaders in the industry, academia, and state and local food protection agencies. FSCPA is funded as part of an existing grant to the Illinois Institute of Technology (IIT). FDA will offer ongoing input as the curriculum is developed and will review the final product so that it can become an FDA-approved curriculum.

The first order of business of FSCPA is to develop a core curriculum and corresponding technical materials that will be designed particularly to help small and mid-size firms. Although the final rules are not anticipated to be published until sometime in 2015, FSCPA is proposing to finish the first draft of the curriculum in the third quarter in 2014. Once approved by FDA, FSCPA will run a pilot training program.

The ultimate goals are that the FSCPA will:

• Develop standardized Hazard Analysis and preventive controls training and distance education modules for food industry and regulatory personnel. It is planned that the first individuals who will receive the training are those individuals who will then go forth to train others. The second to receive the training will be federal and state regulatory inspectors. Finally, training will be made available to industry members.

• Design and deliver a state-of-the-art distance learning training portal at the IIT IFSH Moffett Campus in Bedford Park, IL. In addition to in-person training, it is anticipated that training will be offered online.

• Create a technical assistance network, such as a website community, where small- and medium-size food companies can go to for help with their preventative control or food safety plans.

• Develop commodity/industry sector-specific guidelines for preventive controls.

• Over time and as technology develops, assess knowledge gaps and research needs for further enhancement of preventive control measures.

• Identify and prioritize the need for, and compile, critical limits for widely used preventive controls

Once the curriculum is completed by FSCPA and then approved by FDA, it will be possible to actually determine who is a “qualified individual” for purposes of creating, implementing and overseeing a Hazard Analysis and risk-based preventative controls safety plan. Whether that individual is qualified by completion of an FDA-approved curriculum or is determined to be qualified due to training or job experience equivalent to that curriculum, human food and animal food manufacturers will then be able to effectively begin creating their required safety plans. 

Kathy Hardee, Esq., is co-chair of the Food & Agriculture Industry Group at Polsinelli, PC, which is comprised of a team of attorneys from every legal practice area and who each have a focused background in the food industry.

 

>
Author(s): Kathy Hardee, Esq.

Looking for quick answers on food safety topics?
Try Ask FSM, our new smart AI search tool.
Ask FSM →

Share This Story

Recommended Content

JOIN TODAY
to unlock your recommendations.

Already have an account? Sign In

  • people holding baby chicks

    Serovar Differences Matter: Utility of Deep Serotyping in Broiler Production and Processing

    This article discusses the significance of Salmonella in...
    Food Type
    By: Nikki Shariat Ph.D.
  • woman washing hands

    Building a Culture of Hygiene in the Food Processing Plant

    Everyone entering a food processing facility needs to...
    Management
    By: Richard F. Stier, M.S.
  • graphical representation of earth over dirt

    Climate Change and Emerging Risks to Food Safety: Building Climate Resilience

    This article examines the multifaceted threats to food...
    International
    By: Maria Cristina Tirado Ph.D., D.V.M. and Shamini Albert Raj M.A.
Manage My Account
  • eMagazine Subscription
  • Subscribe to Newsletters
  • Manage My Preferences
  • Website Registration
  • Subscription Customer Service

More Videos

Sponsored Content

Sponsored Content is a special paid section where industry companies provide high quality, objective, non-commercial content around topics of interest to the Food Safety Magazine audience. All Sponsored Content is supplied by the advertising company and any opinions expressed in this article are those of the author and not necessarily reflect the views of Food Safety Magazine or its parent company, BNP Media. Interested in participating in our Sponsored Content section? Contact your local rep!

close
  • Darkling Beetle
    Sponsored byElanco Animal Health

    Integrated Pest Management: Protecting Poultry Operations as Seasons Change

  • NEVIFIT 3 Compartment BPA-FREE
    Sponsored byCorbion

    The Risks of Ready-to-Eat: Five Ways to Protect Today's Prepared Meals

  • a group of workers in a food production facility
    Sponsored bySkillUp by Registrar Corp

    How to Build a Better Training Program: Data and Insights from the Global Food Safety Training Survey

Popular Stories

half full baby bottle next to rubber duckie on white surface

Organic Infant Formulas Caused Back-to-Back Botulism Outbreaks—What Gives?

nara organics whole milk infant formula

Another Infant Botulism Outbreak Sickens Three, Nara Organics Formula Suspected Cause

smiling man with clipboard in front of bottling line at beverage manufacturing facility

The Evolving Role of the Quality Assurance Professional in Food Safety

Events

June 25, 2026

Rethinking Food Safety: Eliminating Biofilm and Building a Smarter Food Safety System

Live: June 25, 2026 at 2:00 pm EDT: Join this webinar to explore a modern approach to decontamination that goes beyond surface-level cleaning to combat biofilm and persistent pathogens.

June 30, 2026

FSMA 204 in Practice: Building a Traceability-Ready Operation

Live: June 30, 2026 at 11:00 am EDT: Attend this webinar to learn how food businesses can move from fragmented records toward a more reliable approach for recall response, FDA requests, and supply chain visibility.

July 21, 2026

Using AI Responsibly in Food Safety Management Systems

Live: July 21, 2026 at 2:00 pm EDT: This webinar will provide participants with guidance on how to effectively use generative artificial intelligence (AI) tools to develop key components of a food safety management system (FSMS).

View All

Products

Global Food Safety Microbial Interventions and Molecular Advancements

Global Food Safety Microbial Interventions and Molecular Advancements

See More Products

Related Articles

  • FDA Logo

    Lawsuit seeks to compel FDA to implement FSMA traceability provisions

    See More
  • Building Domestic Capacity to Implement the FDA Food Safety and Modernization Act (FSMA)

    See More
  • What Is a “Qualified Auditor?”…and Where Do I Get One?

    See More

Related Products

See More Products
  • 1119258073.jpg

    FSMA and Food Safety Systems: Understanding and Implementing the Rules

  • food-safety-making.jpg

    Food Safety: Making Foods Safe and Free From Pathogens

  • 1119053595.jpg

    Food Safety for the 21st Century: Managing HACCP and Food Safety throughout the Global Supply Chain, 2E

See More Products

Events

View AllSubmit An Event
  • December 11, 2025

    How to Develop and Implement an Effective Food Defense Strategy

    On Demand: From this webinar, attendees will learn common areas where companies encounter challenges in their food defense strategies and how to address them.
View AllSubmit An Event

Related Directories

  • Limble CMMS

    The #1 Highest Rated CMMS & Asset Management Platform, Limble’s modern software empowers food safety and maintenance professionals to implement preventive maintenance, easily manage assets, gain control of inventory, streamline workflows, report KPIs, organize work orders and realize millions in cost savings from reduced downtime, parts spend, and improved productivity.
  • enVista

    enVista is the leading supply chain and enterprise consulting firm and the premier provider of supply chain technology & strategy services, material handling automation & robotics, Microsoft solutions and IT managed services. With 20+ years of unmatched domain expertise, enVista serves thousands of leading brands. enVista’s unique ability to consult, implement and operate across supply chain, IT and enterprise technology solutions allows companies to leverage enVista as a trusted advisor across their enterprises.
×

Never miss the latest news and trends driving the food safety industry

Newsletters | Website | eMagazine

JOIN TODAY!
  • RESOURCES
    • Advertise
    • Contact Us
    • Directories
    • Store
    • Want More
  • SIGN UP TODAY
    • Create Account
    • eMagazine
    • Newsletters
    • Customer Service
    • Manage Preferences
  • SERVICES
    • Marketing Services
    • Reprints
    • Market Research
    • List Rental
    • Survey/Respondent Access
  • STAY CONNECTED
    • LinkedIn
    • Facebook
    • Instagram
    • X (Twitter)
  • PRIVACY
    • PRIVACY POLICY
    • TERMS & CONDITIONS
    • DO NOT SELL MY PERSONAL INFORMATION
    • PRIVACY REQUEST
    • ACCESSIBILITY

Copyright ©2026. All Rights Reserved BNP Media, Inc. and BNP Media II, LLC.

Design, CMS, Hosting & Web Development :: ePublishing