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Association of Food and Drug Officials
November 30, 2009
Director, Div. of Human Resource Development
11919 Rockville Pike
Rockville, MD 20852
Thanks so much for the opportunity to comment on FDA’s vision for a national food safety training system. Members of the Association of Food & Drug Officials (AFDO) Steering Committee who are working directly on the development of the International Food Protection Training Institute (IFPTI) have reviewed the draft “Visionary Plan for Food Safety Training and Certification for Federal/State/Local/Territorial/Tribal Regulators” and the schematic “Integrated Food Safety Training and Certification Systems” and have the following comments and questions:
FDA should evaluate the training language in the House and Senate Bills (especially once the final Bill is passed) to be sure that FDA’s training vision is aligned with the legislation).
- The draft documents reinforce the idea that building a fully-integrated food safety system will require an integrated food safety training system. We fully concur with this concept.
- We also concur with the document’s call for a clear set of knowledge and skills (i.e. competencies) and the need to provide training at all levels of government to attain critical competencies. Standard 2 from both the Retail and Manufactured Foods Regulatory Program Standards should be utilized when setting these competencies. In addition, training should not be limited to inspection and investigation, but include other specific areas such as recalls, environmental sampling, dealing with imported foods, and audit checks.
- The vision should be expanded to the producer level. We note that the FDA Council is asked to focus on manufactured foods, feed, cooperative programs, and retail but not at the producer level.
- At least two areas are conspicuous by their absence and, we believe, should be included in the training and certification vision for the future: Animal health, or more specifically, the health of food-producing animals.
- Producer-level systems as they evolve (or exist) to prevent, mitigate, and regulate food protection issues.
- The general role of a training institute is recognized in the draft vision plan, and we believe its envisioned role is generally on target. Our development to date supports the view that a training institute can manage training delivery functions at some level as well as perform administrative functions associated with training. The vision’s inclusion of this dual role is very encouraging to us. One specific note (see top page 5 – “ADMINISTRATION” paragraph), we suggest strengthening the concept that institutes developing and delivering training are not necessarily secondary roles to administering students and maintaining records.
Thank you for considering our comments as you proceed in designing this integrated training system. We know you understand that AFDO will be very supportive where we can and are most interested in assisting you in this very critical task.
- Instructor development needs to be added to administrative duties. This is an area where the IFPTI can also play a major role.
- We agree that training and certification should be linked at the job profile level (skills and knowledge), but separate in governance and operation. The document should mention that a cost model and budget needs to be developed for the entire training and certification system. (Ideally, this cost model and budget should be articulated within the larger context of the overarching cost model and budget for integration of the food protection system.)
- We would anticipate that CDC will provide necessary awareness and performance training about food protection-related public health issues and systems. However, FDA will need to decide which courses in the CDC curriculum apply to regulatory food protection professionals.
- Though it is not clear what the state/local role would be in either the training or certification councils, we believe that state/local representatives should be actively involved in the problem-solving/decision-making process.
- The term “centers of excellence” needs to be clarified. Are these centers a few designated universities, all universities, or any set of entities that the FDA identifies as worthy of the designation based on their expertise and selection in a competitive contracting process? Could the IFPTI be a Center of Excellence in addition to an administrative body? How will the Centers be funded? We suggest the inclusion of more explicit expectations of what an “institute”/”center of excellence” should be able to deliver (i.e. raise the bar up front). This is another potential area to align with final legislation language.
- Who (what entity) will manage the training curriculum once it is developed? Perhaps this question is answered in a roundabout way by acknowledging that an institute will provide administrative services, which includes the distribution of travel funding to participate in training. However, we believe this curriculum management role needs to be clarified.
- AFDO believes that the FDA needs to exercise its stated option (Audit section, page 5) to contract for the audit of training providers. The FDA needs to qualify auditors to audit against delivery performance standards established by the FDA, in consultation with representatives of state and local food protection programs, key professional associations in the food protection community, and the IFPTI. Though under this option the FDA (or FDA-contracted training institute) would contract with qualified organizations to perform and report audit results and recommendations, FDA would perform final review of contractor-provided data and recommendations, and implement follow-up actions the agency determines to be warranted and appropriate.
- AFDO is concerned about each of the three (3) federal agencies having separate advisory councils and acting totally independently. We believe that actions needed to create and sustain training and certification programs for food protection professionals will need to be cooperative, or at the very least coordinated, in areas where agencies have dual jurisdiction, overlapping activities, or complementary roles and responsibilities (e.g. laboratories, USDA/FSIS training for retail inspections, import activities, USDA/AMS involvement at the producer level with shell eggs, fresh fruits and vegetables).
- It occurs to us that the vision includes another set of councils, advisory groups, and auditors. Perhaps we should all think about integrating these.
- Finally, we believe the FDA should be prepared to advance this vision even if other federal agencies do not support it
Ronald S. Klein
cc: Steve Solomon