SCR Criteria Modification

SRC Criteria Modification: 1.6.2 - NOAA Training Requirements

To continue to meet oversight objectives while providing the industry greater flexibility in meeting NOAA Approved Establishments training requirements, SIP has updated section 1.6.2 of its Systems Rating Checklist Criteria (see revised text below).

Each firm must have available one individual who has met the NOAA Training requirements by 1) fulfilling 21 CFR Part 123.10 and 2) taking and passing the NOAA HACCP Examination. While this person is responsible for oversight of the firm’s overall implementation of the NOAA Approved Establishment program, this individual is not required to be present during all operational hours; further, for vessels, this NOAA Trained individual is not required to be on-board.

As indicated by 21 CFR Part 123.10, only individuals who meet 21 CFR Part 123.10 are allowed to perform a) HACCP plan development b) HACCP Plan Reassessment and/or Modification and c) Records Review functions. Individuals meeting 21 CFR Part 123.10 and who perform these functions at each processing location are not required to meet NOAA Training requirements.

NOAA SIP has determined that this approach will continue to meet organizational objectives while providing industry participants greater flexibility in managing their system.

Below please find the new language to be added to the manual release on the subject. This policy is to be implemented immediately.

1.6.2 Personnel have not received documented training necessary for the proper function of the food system.

The organization shall: a) identify the necessary competencies for personnel whose activities have an impact on food safety, b) provide training or take other action to ensure personnel have the necessary competencies, c) ensure that personnel responsible for monitoring, corrections, and corrective actions of the management system are trained, d) evaluate the implementation and the effectiveness of a), b), and c), e) ensure that the personnel are aware of the relevance and importance of their individual activities in contributing to food safety, f) ensure that the requirement for effective communication is understood by all personnel whose activities have an impact on food safety, and g) maintain appropriate records of training and action s described above.

Training must include the areas of HACCP, good manufacturing practices, and allergens to appropriate personnel. Each firm must have available a person who has met the training requirement by NOAA for this program. The training requirement 1) fulfills the 21 CFR part 123.10 training requirement and, 2) personnel must pass the NOAA HACCP Exam with an 80% or better. In addition, copies of all trained personnel’s certificates must on file with the firm. Per 21 CFR part 123, these duties are assigned only to properly trained personnel. For the IQA and QMP Program, properly trained will be any person who has passed the NOAA Certification Exam. However, failure of this element will not likely cause an immediate hazard or defect. Therefore it is rated as a Serious deficiency. Per 21 CFR part 123, these duties are assigned to only properly trained personnel. Failure of this element could lead to an immediate hazard or defect.

At a minimum, the following functions shall be performed by an individual who has successfully completed training in the application of HACCP principles to fish and fishery product processing at least equivalent to that received under standardized curriculum recognized as adequate by the U.S. Food and Drug Administration or who is otherwise qualified through job experience to perform these functions. Job experience will qualify an individual to perform these functions if it has provided knowledge at least equivalent to that provided through the standardized curriculum.