FeedForward, Winter 2016
FEEDFORWARD It should be noted the definition of PCQI does not make mention of education which AFIA believes is an oversight as education can be an important part of training According to the regulations a PCQI would need to be in place when a facility is in compliance with 21 CFR part 507 Subpart C as detailed in Table 32 80 Federal Register at 56329 and below with the earliest date being September 18 2017 for large firms The PCQI unlike a QI is responsible for preparation or the oversight of the facilitys animal food safety plan It is very likely that a facility will 8 FEEDFORWARD Vol 3 WWW KEMIN COM need to have a PCQI in place well before the facilitys compliance date of September 2017 or September 2018 in order to properly prepare the animal food safety plan Title 21 CFR 50753 c 1 states the PCQI does not need to be an employee of the facility and in a it states one or more preventive controls qualified individuals must implying there could be more than one individual Most importantly a PCQI can be appointed based on experience alone before taking any FDA standardized course training However AFIA recommends PCQIs partake in such courses in the next couple of years Business Size Over the summer AFIA hosted FSMA Preventive Controls for Animal Food trainings in order to help companies and their designated PCQIs gain a better understanding Conclusion Moving forward AFIA recommends every plant employee should train as QIs Once a facility determines who will be the PCQIs AFIA hopes to provide additional training if needed to help them prepare a food safety plan For questions pertaining to this article please contact Richard Sellers at rsellers@ afia org Compliance date for Subpart B and related requirements Compliance date for Subpart C and 21 CFR 5077 Business other than small and very small Sept 19 2016 Sept 18 2017 Small business a business including any subsidiaries and affiliates employing fewer than 500 full time equivalent employees Sept 18 2017 Sept 17 2018 Very small business a business including any subsidiaries and affiliates averaging less than 2500000 adjusted for inflation per year during the 3 year period preceding the applicable calendar year in sales of animal food plus the market value of animal food manufactured processed packed or held without sale e g held for a fee or supplied to a farm without sale Sept 17 2018 Sept 17 2019 except for records to support its status as a very small business Jan 1 2017
You must have JavaScript enabled to view digital editions.
