4 Questions to Ask Your PCQI
The Food Safety Modernization Act (FSMA) brought about many changes in the food safety landscape over the past decade — including who is allowed to develop and implement a facility’s food safety plans. That’s where Preventive Controls Qualified Individuals (PCQI) come in — a role responsible for developing, implementing, and overseeing their company’s food safety plan. PCQI qualification ensures these food safety stakeholders have adequate training, experience, and knowledge to fulfill their responsibilities effectively and in compliance.
Since PCQIs play such a pivotal role in protecting both public health and your company’s reputation, it’s critical as company leaders to perform due diligence and ensure these stakeholders are up to standards. But what kind of questions should you ask to ensure your food safety program is in the right hands?
Why PCQI Qualification Is So Important
The Food Safety Modernization Act, passed in 2011, set a list of ambitious regulatory changes agencies needed to meet to bring America's food safety rules into the 21st century. Two resulting rules, 21 CFR 117 and 21 CFR 507, require every FDA-regulated food facility to have at least one PCQI-qualified employee on staff.
A PCQI might fill roles such as food safety manager, quality assurance manager, production manager, sanitation supervisor, or plant manager, but in all cases, they are the person entrusted with developing and overseeing the implementation of food safety plans. Their responsibilities include:
- Ensuring compliance with 21 CFR 117 and 21 CFR 507
- Conducting hazard analyses
- Managing preventive controls
- Maintaining accurate documentation and records
- Ensuring all employees with food safety responsibilities are trained and qualified
4 Questions Your PCQI Should Be Able to Answer
The results of a PCQI’s food safety plan often speak for themselves by how effectively they prevent contamination and food safety incidents. However, it’s still important to be proactive and ensure your company stays on the right trajectory of FDA compliance. These are questions you can ask your PCQI — or PCQIs can ask themselves — each year to help keep food safety plans on track:
1. How do you stay up to date on changes in food safety regulations and ensure our company remains compliant?
Food safety regulations and industry best practices are constantly changing, such as recent updates to the Food Traceability Rule. PCQI-qualified leaders must stay abreast of the latest updates, whether by subscribing to industry and regulatory publications, participating in webinars, attending food safety conferences, or participating in continued education and training opportunities like FSPCA V2.0 PCQI training. Professional networks and relationships with regulatory agencies are also key for staying in the loop on what’s changing.
2. How do you ensure all employees are adequately trained and understand their roles in the food safety plan?
Beyond initial employee onboarding and training, food safety managers and other PCQI-required leaders must ensure frontline workers are always up to date on the latest expectations and standards.
It’s ideal to develop clear, role-specific training materials and standard operating procedures (SOPs) that outline each employee's responsibilities within the food safety plan. Regularly scheduled refresher courses and hands-on training can go far to reinforce key concepts and procedures.
3. What are the most vulnerable areas of our current food safety plan?
Unfortunately, no food safety plan is 100% fool-proof. As food safety managers and other PCQI stakeholders become more experienced and in-tune with the hazards of their jobs, they can gain deeper insight into potential vulnerabilities to their plan — which could include anything from facility layout issues to inadequate supplier audits and more — before they allow for contamination or other breaches that would threaten public health. It’s important for leaders to periodically audit their food safety plan and consider new potential weaknesses based on their previous experience or industry-wide trends. Doing so not only keeps the food you produce safe but also keeps your organization compliant with any corrective action requirements you might have.
4. How would you respond to a hypothetical crisis?
By their nature, crises are unpredictable and sometimes impossible to prevent, making well-developed and executed responses just as critical as prevention. PCQI leaders should periodically assess potential risks threatening the industry, such as climate change and geopolitical conflicts, to determine whether these trending issues could result in potential food safety risks. If so, PCQIs must review and develop strategies to control hazards and mitigate risks by updating the food safety plan, determining if new controls are necessary, and ensuring employees are trained on new roles and responsibilities. Not only will this reduce damages, but it can also help ensure the company remains operational even in a time of crisis.
Bolstering Your PCQI Knowledge With AIB International
PCQI qualification is key to complying with the FDA’s FSMA mandates and building food safety plans that effectively protect consumer health. However, it’s just as important for stakeholders to regularly refresh their training and get hands-on experience with the latest best practices in food safety and evolving regulatory compliance.
AIB International has trained frontline and executive workers alike in food safety for over a century. Want to ensure your team is up to today’s standards? Learn more about our PCQI Online course today.
