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Standard 2 Breakout Session Training Programs

Standard 2 Breakout Session Training Programs. March 11, 2014 1:30 – 5:00 pm. Morgan Poloni, MS, REHS Program Coordinator Alaska Department of Environmental Conservation Food Safety and Sanitation Program. Dawn Smith Food Program Manager Oregon Department of Agriculture

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Standard 2 Breakout Session Training Programs

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  1. Standard 2 Breakout Session Training Programs March 11, 2014 1:30 – 5:00 pm Morgan Poloni, MS, REHS Program Coordinator Alaska Department of Environmental Conservation Food Safety and Sanitation Program Dawn Smith Food Program Manager Oregon Department of Agriculture Food Safety Division Timothy Weigner Staff Director U.S. FDA Office of Regulatory Affairs Office of Partnerships Standards Implementation Staff Mark M. Reed, R.S., MPA, MPH Branch Manager Kentucky Department for Public Health Food Safety Branch

  2. 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

  3. 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

  4. 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)

  5. 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.

  6. “Tell me and I forget. Teach me and I remember. Involve me and I learn." - Benjamin Franklin

  7. Training Plan Development Exercise 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

  8. 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 ?

  9. Training Plan Development Exercise (cont.) 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

  10. 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 ?

  11. Training Plan Development Exercise (cont.) 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 additional components. Timeframe for exercise: 15 minutes

  12. Section 3 – Advanced Food Inspection Training (Coursework) • 8 coursework areas (MFRPS) • Sources of training • Other Training • Commodity • Program specific • Others ?

  13. Training Plan Development Exercise (cont.) 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 4with additional components. Timeframe for exercise: 10 minutes

  14. Section 4 – Continuing Education • Types of Training • Classroom • Contact time and verification • Sources of training • Joint inspections or audits • Timeframe for meeting requirements • Others ?

  15. "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

  16. Standard 2 Breakout Session Building a State Training Plan Mark M. Reed, R.S., MPA, MPH Branch Manager Kentucky Department for Public Health Food Safety Branch March 11, 2014

  17. First Things First…Greetings from the Bluegrass State!

  18. Background: KY DPH Food Manufacturing Section • Some 1100 Firms +/- • Team of 5 (plus 1) Field Inspectors • Small Program

  19. Initial Self-Assessment – Standard 2

  20. 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

  21. Staff Training and Development Plan—Level I Web Courses • 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 • 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

  22. Staff Training and Development Plan —Level I Web Courses • Complete w/in 180 days of Employment • Certificates forwarded to Designated Training and Compliance Officer • 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

  23. Staff Training and Development Plan —Level I Live Classroom • *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. 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

  24. Staff Training and Development Plan —Level I Joint/Audit Field Inspections • Successful Completion of this Requirement, Along with Level I On-Line and Live Trainings Qualifies Inspector for GMP (non-Specialty Area 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

  25. Level II Advanced (Specialty Area) Food Inspection Classroom Training 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) To 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

  26. Level II “Specialty Area” Joint Field Inspection/Audit Inspections • OTJ Training Inspections to be Properly Documented and Submitted to Training & Compliance Officer To 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.

  27. “Escape Clause” for Experienced Inspection Staff • 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 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

  28. Qualified Trainer… • Successfully Completed Advanced Food Inspection Training Coursework and Field Training in Any Areas Where the Trainer Performs Advanced Training • See MFRPS Interpretation 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

  29. Level III Advanced (Response) Training • PER-298 NCBRT (LSU) Team Approach to Foodborne Outbreak Response To 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

  30. And Just When You Think You’ve Reached the Finish Line.. • In Reality No Finish Line • Continuous Learning & Professional Development 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

  31. Examples of Continuing Education and Training • In-House Staff Development and Training IMPORTANT: Maintain Agendas, Certificates, and other Proof of Attendance • Completion of Additional Web-Based or Live Training Courses • Attendance at Professional Association Meetings/Conferences • KAMFES • AFDOSS • AFDO • NEHA

  32. Training Records and Documentation • 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 • 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

  33. Staff Included in Training Policy • Section Supervisor to Complete all Online/Live Classroom and Continuing Education Provisions (Exempt From Field Training) • 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

  34. Failure to Comply Consider Adding FTC Clause May 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

  35. “Hardship Clause” 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… Meant to Address: • Employee Fiscal Hardship (Up Front Expenses, Hotel, Per Diem, etc.) • “Company Card,” etc. • Other Employee Issues (Family, Medical), etc.

  36. 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

  37. 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

  38. Contact Information Mark M. Reed, R.S., MPA, MPH Branch Manager Kentucky Department for Public Health Food Safety Branch Email: Mark.Reed@ky.gov Phone: (502) 564-7181

  39. BREAK

  40. 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.

  41. Training Plan Development Exercise (cont.) 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

  42. 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

  43. Standard 2 Breakout Session Training Programs March 11, 2014 1:30 – 5:00 pm Morgan Poloni, MS, REHS Program Coordinator Alaska Department of Environmental Conservation Food Safety and Sanitation Program Dawn Smith Food Program Manager Oregon Department of Agriculture Food Safety Division

  44. Audits and Joint InspectionsWhat does the standard say?

  45. Audits and Joint InspectionsWhat does the standard say?

  46. 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

  47. Field Training Oregon and Alaska • Is done by experienced staff • Trainer does have to be a qualified trainer • Counts toward their 10 joint manufactured food inspections

  48. 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

  49. 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

  50. 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

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