Standard 2 Breakout SessionTraining Programs

March 11, 20141:30 – 5:00 pm

Mark M. Reed, R.S., MPA, MPHBranch Manager

Kentucky Department for Public HealthFood Safety Branch

Dawn SmithFood Program Manager

Oregon Department of AgricultureFood Safety Division

Morgan Poloni, MS, REHSProgram Coordinator

Alaska Department of Environmental Conservation

Food Safety and Sanitation ProgramTimothy Weigner

Staff DirectorU.S. FDA Office of Regulatory Affairs

Office of PartnershipsStandards Implementation Staff

AgendaStrengthening Training Foundation

• 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• 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

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

Training Plan Development Exercise

Section 1 – Foundation and Resources

• 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 ?

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

Training Plan Development Exercise (cont.)

Section 2 – Basic Food Inspection Training (Coursework)

• 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 ?

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 additionalcomponents.

Timeframe for exercise: 15 minutes

Training Plan Development Exercise (cont.)

Section 3 – Advanced Food Inspection Training (Coursework)

• 8 coursework areas (MFRPS)• Sources of training• Other Training– Commodity– Program specific

• Others ?

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 additionalcomponents.

Timeframe for exercise: 10 minutes

Training Plan Development Exercise (cont.)

Section 4 – Continuing Education

• 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 self-appropriated learning - truth that has been assimilated in experience.“

- Carl Rogers

Standard 2 Breakout SessionBuilding a State Training Plan

Mark M. Reed, R.S., MPA, MPHBranch Manager

Kentucky Department for Public HealthFood Safety Branch

March 11, 2014

First Things First…Greetings from the Bluegrass State!

Background: KY DPH Food Manufacturing Section

• Some 1100 Firms +/-• Team of 5 (plus 1) Field Inspectors• Small Program

Raquel Rouse (502) 382-6312

Natasha Collins (502) 484-3412

Paul Rice (606) 638-0770

Food Manufacturing Inspector Areas

Jay Fillman (270) 684-2047

Annhall Norris (859) 236-8159

Initial Self-Assessment – Standard 2

Purpose –To Build a Strong Foundation From the Ground UP• From Self-Assessment

– 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

• *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 (non-Specialty Area Inspections)

Level II Advanced (Specialty Area) Food Inspection Classroom TrainingTo 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 State-Standardized 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 InspectionsTo 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

Experienced inspectors hired before KY Food Safety Branch enrollment in MFRPS (2011) will be granted an exemption from “initial” and “specialty area” field training provided they remain proficient in their inspectional and documentation duties…• No Exemption for Web-Based

or Live Classroom Training

• Signed Affidavit Utilized to Affirm Inspector’s Competence to Conduct Initial (GMP) and “Specialty Area” Inspections

• Does Not Eliminate Requirement for Standard 4 Field Inspection Audits

Qualified Trainer…KY Definition: Any Food Manufacturing Section Inspector (or Qualified FDA Inspector) Recognized by the Food Program Manager as Having Field Experience and Communication Skills Necessary to Train Other Investigators, and Who Has:• Demonstrated Competency for

Basic food Inspection Training to the Food Program Manager (or FDA District Office); and

• Successfully Completed Advanced Food Inspection Training Coursework and Field Training in Any Areas Where the Trainer Performs Advanced Training

• See MFRPS Interpretation

Level III Advanced (Response) TrainingTo 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 Courses/Continuing Education with Missing Documentation

• Each Employee Responsible for Promptly Forwarding to Designated Training and Compliance Officer:– Agendas– Certificates of Completion– Joint Inspection Documentation– Certificates of Attendance– Current R.S. Renewal

Certification

• Training and Compliance Officer’s Responsibility to:– Maintain History of Training

Provided to Each Inspector– Maintain Pertinent Training

Records for Each Inspector 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 ClauseMay 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)• 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

• 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 InformationMark M. Reed, R.S., MPA, MPH

Branch ManagerKentucky Department for Public Health

Food Safety Branch

Email: Mark.Reed@ky.govPhone: (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.

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

Training Plan Development Exercise (cont.)

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 SessionTraining Programs

March 11, 20141:30 – 5:00 pm

Dawn SmithFood Program ManagerOregon Department of

AgricultureFood Safety Division

Morgan Poloni, MS, REHSProgram CoordinatorAlaska Department of

Environmental ConservationFood Safety and Sanitation

Program

Audits and Joint InspectionsWhat does the standard say?

Audits and Joint InspectionsWhat does the standard say?

Touch PointsOregon 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 TrainingOregon 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 LedOregon

• 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 LedAlaska

• 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

Smoked Fish Workshop, 2013

Joint Inspection LogOregon

• 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 LogAlaska

• 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

RecordsOregon

• 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 PlanTrainer/Trainee Signature

• Basic Manufactured Foods

RecordsAlaska

• 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 LogAlaska

• Maintain copies of the 3610 in their training file (Anchorage office).• First 2 successful audits are documented on the Joint Inspection Log

Joint Inspection LogAlaska

• Page 2

AuditsOregon

• 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

AuditsAlaska

• 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 TrainersOregon

• 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 TrainersAlaska

Work Planning and FundingAlaska

• 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 FormsOregon 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

Dawn SmithFood Program ManagerOregon Department of

AgricultureFood Safety Division

dsmith@odo.state.or.us

Morgan Poloni, MS, REHSProgram CoordinatorAlaska Department of

Environmental ConservationFood Safety and Sanitation Program

Morgan.poloni@alaska.gov

Questions

Creating ChangeHow 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

Mark M. Reed, R.S., MPA, MPHBranch Manager

Kentucky Department for Public Health

Food Safety BranchMark.reed@ky.gov

Dawn SmithFood Program ManagerOregon Department of

AgricultureFood Safety Division

dsmith@odo.state.or.us

Morgan Poloni, MS, REHSProgram CoordinatorAlaska Department of

Environmental ConservationFood Safety and Sanitation Program

Morgan.poloni@alaska.gov

Timothy WeignerStaff Director

U.S. FDA Office of Regulatory Affairs Office of Partnerships

Standards Implementation StaffTimothy.weigner@fda.hhs.gov