What I Learned by Taking the
FSPCA Preventive Controls
for Human Food Course
Ten important take-aways
from the Preventive Controls
for Human Food course
Having recently completed the Food Safety Preventive Controls Alliance (FSPCA) Pre- ventive Controls for Human Food (PCHF) course, I wanted to try to demystify the xperience for those who are contemplating
(or maybe procrastinating) taking it. What follows are 10
important points I took from the course that make the
case for attending the training.
1. Taking the FSPCA course is more efficient than reading
and applying the regulations on your own, even if you
already are familiar with risk-based approaches such as
Hazard Analysis and Critical Control Points
The PCHF final rule itself is daunting, and the regulations themselves require impeccable concentration
(and knowledge of context) to understand and eventually apply them.
But is it really worth your organization’s money for
you to attend the 2.5-day training course?
The training course was developed by a public-pri-vate partnership that included a large team of industry
and academic experts along with U.S. Food and Drug
Administration (FDA) officials (including those who
wrote the regulations and who are now crafting the
“tantalizingly close” PCHF guidance documents, some
drafts of which are now available).
Taking the FSPCA PCHF course involves more than
having the regulations spoon-fed to you.
In fact, you probably won’t even really
look at the regulations until the very
end of the course. The benefits of the
course mainly derive from being forced
(in a kindly way) to work through many
group exercises. You will get to spend a
lot of time working on a particular food
item (broccoli, carrot and pecan salad,
anyone?). You’ll do a Hazard Analysis.
You will discuss preventive controls and
decide how to monitor them. You’ll de-
bate the best verification and validation
procedures and the kinds of supporting
documentation you’ll need to keep.
Your working group will feel like family,
arguments and all. Even as an introvert,
I found the exercises actually fun.
There is no test at the end of the
course, but attendance and participation are required (hence, no online version of the course, although a blended,
partially online version of the course is
undergoing development). Class sizes
are small, so you cannot sit in the back
and quietly play Candy Crush on your
smartphone or multitask continuously
on the fires back at the plant. And if
you sleep in late and miss the morning
session, don’t expect to receive a certificate at the end of the course (see #3 for
why you need the certificate).
There is certainly a benefit to having the material presented in a focused,
well-caffeinated environment by a good
instructor. Not just anyone can become
a lead instructor. Before someone is
allowed to even take the 2-day lead
instructor training course (which also
requires prior completion of the regular
course itself in most cases), a selection
committee will review the individual’s
employment and education background
The course manual (available in the
public domain in a well-edited version
1.2 at the FSPCA website, www.ifsh.iit.
edu/fspca) includes a large number of
sample forms that can be used in the