Produce Safety Alliance Annual Trainers & Lead Trainers Update - - PowerPoint PPT Presentation
Produce Safety Alliance Annual Trainers & Lead Trainers Update - - PowerPoint PPT Presentation
Produce Safety Alliance Annual Trainers & Lead Trainers Update October 31, 2018 Agenda Welcome & Introduction of the PSA PSA Milestones & Training Capacity Important FDA Guidance Documents & Announcements New and
Agenda
- Welcome & Introduction of the PSA
- PSA Milestones & Training Capacity
- Important FDA Guidance Documents &
Announcements
- New and Updated PSA Educational Materials
- Online Course Update, Social Media, &
Communications
- PSA Policies & Reminders
- 2019 Plans & Goals
Southwest: Donna Clements, M.S. Midwest: Don Stoeckel, Ph.D. Northeast: Betsy Bihn, Ph.D. Gretchen Wall, M.S. Laura Acuña-Maldonado, Ph.D. Michele Humiston Rob Way Southeast: Kristin Woods, Ph.D. Northwest: Connie Fisk, Ph.D.
Produce Safety Alliance Team
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2018 Milestones
- 3 National Soil Summits (2 in 2017, 1 in 2018)
- 1 National Water Summit (Feb. 2018)
- Advanced trainer course at UC Davis (May 2018)
- Release of PSA Version 1.1 Grower Training Manual
(Dec. 2017), Spanish (July 2018)
- New educational materials and factsheets
- Training reports
- International efforts
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PSA by the Numbers
- Reports conducted quarterly
- Next report available January 2019
- Full reports available on the website:
https://producesafetyalliance.cornell.edu/training/training-reports
- Most recent report captures data from September
2016 (launch of programs) until September 19, 2018
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PSA Training Milestones
Domestic
- 815 Grower Training Courses
- 18,893 Grower Participants
Domestic
- 58 Train-the-Trainer Courses
- 1,562 Trainers
- 209 Lead Trainers
International
- 12 Train-the-Trainer Courses
- 503 Trainers
- 32 Lead Trainers
International
- 335 Grower Training Courses
- 8,335 Grower Participants
Overall Stats
- Sept. 2016 – Sept. 2018
27,228 Grower Training Participants 2,207 Train-the-Trainer Participants
Train-the-Trainer Courses Grower Training Courses
WY: 1
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Regional Trainer Distribution
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PSA Courses by Region
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International Efforts
- Partnership with JIFSAN - Produce International Partnership
for Education & Outreach (PIP)
- Since 2017, 12 international TTT courses hosted, 8 through
the PIP
- Working with the PIP to address language and financial
barriers to international trainers becoming Lead Trainers
- New Trainers-of-Trainers (ToTs) approved with Spanish
proficiency for conducting international courses
- More info at:
https://international.jifsan.umd.edu/catalogue/course/pip
International Courses
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Note: 28 courses International GT courses and 1 TTT course currently do not have participant data, most of which were hosted between June - September 2018. Course data still yet to be returned by host or currently being entered into the AFDO database. Country Grower Courses GT Participants TTT Courses TTT Participants Argentina 11 200 Brazil 1 49 Canada 3 27 Chile 98 2676 Colombia 4 74 1 50 Costa Rica 21 401 1 Dominican Republic 5 27 1 34 Ecuador 28 551 1 29 Guatemala 9 333 1 33 Honduras 1 39 Jamaica 1 43 Mexico 130 3365 4 (2) 218 Morocco 1 6 Nicaragua 1 26 Peru 20 560 1 45 Spain 1 10 Uruguay 2 30 Totals 335 8335 12 491
International Trainers & Lead Trainers
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Country # of Trainers # of Lead Trainers Antigua and Barbuda 1 Argentina 1 1 Barbados 3 Canada 4 Chile 8 5 China 1 Colombia 48 Costa Rica 12 3 Dominica 1 Dominican Republic 34 Ecuador 23 3 El Salvador 1 Germany 1 Guatemala 26 Haiti 1 Honduras 35 1 Italy 2 2 Jamaica 26 Korea 1 Mexico 208 14 Netherlands 1 Panama 3 Peru 49
- St. Vincent & Grenadines
1 Saudi Arabia 1 Spain 1 Thailand 1 Trinidad & Tobago 9 United Kingdom 1 Uruguay 1 Vietnam 1 Total International 503 32
Top 3 Countries with Trainers:
- 1. Mexico (208)
- 2. Peru (49)
- 3. Colombia (48)
Top 3 Countries with Lead Trainers:
- 1. Mexico (14)
- 2. Chile (5)
- 3. Costa Rica/Ecuador (3)
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Building PSA Training Capacity
- Co-training and mentoring opportunities
- Expanded access to funding for LT development through CAP
funds
- Partnerships with State Departments of Agriculture & Health
- Connect states to existing resources/people and help identify
and address critical resources to address diversity of growers and farming practices in their region/state
- Produce International partnership (PIP) focusing on
international training needs, especially for countries which export large quantities of produce to the U.S.
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FDA Updates/Announcements
- Draft PSR Guidance (NEW! 10/19/18)
- Small entities compliance guide
- Enforcement discretion/farm inspections
- Updates to facilities registration guidance
- Inflation adjusted cut-offs
- Status of agricultural water and compliance date extension
- Equivalent methods for water testing
- Other specific FDA fact sheets
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Draft Guidance Published
- Draft Guidance for Industry: Standards for the Growing,
Harvesting, Packing, and Holding of Produce for Human Consumption
- Guide To Minimize Food Safety Hazards of Fresh-Cut Produce:
Draft Guidance for Industry
– Published in Federal Register on October 22, 2018 – Comments can be submitted until Apr. 22, 2019 – PSA planning to host Educator’s call in early December 2018 to discuss the draft guidance
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Small Entities Compliance Guide
Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption: What You Need To Know About the Food and Drug Administration Regulation; Small Entity Compliance Guide; Availability
- Released September 2017
- Restates much of Rule in a format that may be easier
to understand
- Included in 1.1 versions of the PSA Manual
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Enforcement Discretion
Trainers should be aware of enforcement discretion:
- Farm and facility definitions. When facilities conduct farm
activities, that otherwise would not be subject to CGMPs, enforcement discretion for PC-HF Rule requirements
- Written assurances related to kill steps
- Other important announcements:
– No routine inspections until Spring 2019 – No enforcement of Subpart E (water) while rulemaking for extension to compliance date is underway
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Farm Inspections Tour
- FDA release June 2018
– Virtual produce tour video
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Status as a Qualified Facility
- Farm mixed-type facilities may be covered by both the Produce
Safety Rule and a Preventive Controls Rule
- Important guidance for facilities that fall under the definition of a
Qualified Facility
– A very small business based on 3-year average sales of {human or animal} food plus the market value of {human animal} food manufactured, processed, packed, or held without sale (e.g., held for a fee) OR – Majority of sales are to qualified end users, and the average value of all food sold <$500,000 (3-year average, inflation adjusted)
- $1,000,000 for human food, part 117
- $2,500,000 for animal food, part 507
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FSMA Inflation Adjusted Cut Offs
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Water Compliance Date Extension
- Proposed Rule by FDA, called:
Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption; Extension of Compliance Dates for Subpart E.
- Applies to all provisions of Subpart E other than sprouts
– Safe and sanitary agricultural water quality – Annual inspection of the agricultural water system – Numeric criteria for agricultural water used during production and postharvest – Monitoring requirements for agricultural water used during postharvest
- Until the Proposed Rule is accepted and more is known, the
water requirements in Module 5: Agricultural Water remain
– Enforcement discretion applies in the meantime
Version 9-2017
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Business Size Compliance Dates For Most Produce Proposed Water Related Compliance Dates All other businesses (>$500K) 1/26/18 1/26/22 Small businesses (>$250K-500K) 1/28/19 1/26/23 Very small businesses (>$25K-250K) 1/27/20 1/26/24
FDA Proposed Rule: Water Compliance Dates
- According to the Proposed Rule issued Sept. 2017, compliance dates
for all agricultural water requirements allow for an additional 4 years.
- For example, ‘all other businesses’ would have until 2022 to begin
taking their water samples.
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- Continue water testing
– To better understand water quality – To meet buyer and audit requirements
- Develop water management strategies
– To identify and reduce risks – Example: Surveys of water sources
- Understand quality by testing … especially if
they have never tested they should test – For generic E. coli – Before using agricultural water – During frequent use periods
Water Compliance Date Extension: Suggestions for Growers Now
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Equivalent Water Testing Methodologies
- This FDA fact sheet was updated in 2018 to include
presence/absence methods
- Old version, with only quantitative methods, included in the
1.1 version of the PSA Manual
– Trainers should explain and remove the old version from the manual
- Different methods apply to water used different ways
– Production water criteria; must use quantitative methods – Postharvest water criteria; may use either quantitative or presence/absence methods
The proposed compliance dates for water rules (Subpart E except for sprouts) in the PSR are 2022 or later. Requirements may change.
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FDA Fact Sheet: Equivalent Water
Testing Methodologies (Quantitative)
Cited method in FDA Fact Sheet Shorthand method name EPA Method 1603 Modified mTEC agar EPA Method 1103.1, Standard Methods 9213 D, ASTM method D5392-93 mTEC agar EPA Method 1604 MI agar Standard Methods 9222 B followed by 9222 G m-Endo followed by NA-MUG agar Hach method 10029 m-ColiBlue 24 ampules Product/medium named in FDA Fact Sheet Method notes IDEXX Colilert test kit, only if using Quanti-Tray/2000 IDEXX Colilert-18 test kit,
- nly if using Quanti-
Tray/2000 Most probable number methods (quantitative) Production or Postharvest Water Membrane filtration methods (quantitative) There are several formats for Colilert, be sure the lab uses the FDA-named quantitative
- format. One reference
protocol for this product is Standard Methods 9223B.
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FDA Fact Sheet: Equivalent Water
Testing Methodologies (Presence/Absence)
Product/medium named in FDA Fact Sheet Manufacturer/source TECTATM EC/TC medium and instrument Veolia Water Technologies Modified Colitag, ATP D05- 0035 CPI International IDEXX Colilert test kit IDEXX Laboratories, Inc. IDEXX Colilert-18 test kit IDEXX Laboratories, Inc. IDEXX Colisure test kit IDEXX Laboratories, Inc. E*Colite Bag or Vial test Charm Sciences Readycult Coliforms 100 EMD Millipore, catalog 101298 Postharvest Water Only Presence/absence methods (in 100 mL)
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Rarely Consumed Raw
- Included in the 1.1 version of the PSA Manual
- Saves trainers from explaining the FDA’s process
– For example, sweet potato is rarely consumed raw but yams are not because not enough people reported eating yams raw – Another example, taro is toxic if eaten raw but it is not on the list for the same reason
- Process for addressing these issues used by Hawaii Dept. Agriculture
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Biological Soil Amendments
- Fact Sheet released by FDA in 2018
– This document explains the main issues both in the language of the Rule and in plain English – The fact sheet can save a lot of time explaining the definitions and time-to-harvest requirements
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New PSA Resources & Materials
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New PSA Resources & Materials
- Supplemental fact sheets and teaching add-ons
– UPDATED Post-harvest Sanitizer Tool (Excel), plus NEW factsheet – Coliform activity NEW – Cleaning & Sanitation Activity (Photos) – Required PSR records (Word template) – Exemptions & Exclusions (PPT) – New videos…and more to come! – Addition of Spanish language documents
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- Water continues to be a big issue resulting
in many questions from stakeholders, so PSA team has focused attention here
- PSA materials to address consistency and accuracy in training
- Supplemental Slides: Updates on Agricultural Water
- Supplemental Activity: Is This Agricultural Water?
- Fact sheet: The Water Analysis Method requirements in the PSR
- Webinar: How to Create a Water Lab Map for Farms in Your Area
PSA collaboration with Michigan State, June 22, 2018
- SOP to map of water analysis labs
- Educational slides to communicate farm needs with labs
Agricultural Water Resources
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PSA Online Grower Training Course
- Developing remaining PSA Modules and building content
within eCornell platform
- Working towards goal of early 2019 pilot
- Course will meet requirements of 112.22(c) and result in AFDO
certificate
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PSA Communications
- General Listserv – 4,296 members
– Sign up on PSA website
- Educator’s Listserv – 372 members
– 8 Zoom meetings hosted in 2018 with ~500 educators in attendance – Contact mmc15@cornell.edu to sign up or visit: https://producesafetyalliance.cornell.edu/resources/educators-group/
- PSA Trainers & Lead Trainers Listserv – 2,364 members
– Automatically enrolled after attending a PSA TTT – Update contact info on Trainer Directory: https://producesafetyalliance.cornell.edu/training/directory/
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Social Media
https://www.facebook.com/ ProduceSafetyAlliance https://twitter.com/ Produce_Safety
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PSA Policy Reminders
- PSA Course Protocols – PSA reserves the right to conduct
course audits, revoke course registrations, or suspend trainer status if training course protocols are not met.
– Training protocols are outlined in the PSA Train-the-Trainer Manual under the Course Info and Trainer Info tabs.
- PSA Grower Training Course Evaluations must be printed,
distributed to all participants, collected, and mailed directly to AFDO.
– We have begun auditing the receipt of evaluations and have implemented a tracking system. Warnings will be sent to Lead Trainers if three or more course evaluations are missing for more than 90 days. If evaluations continue to not be returned for future courses, Lead Trainer status will be suspended.
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Evaluations
- Do not edit the information in the
upper right hand box of the course evaluations or reuse other course evaluations.
- Follow the evaluation printing
instructions included in AFDO’s course approval e-mail. Poorly/incorrectly printed copies of evaluations cannot be processed with PSA’s evaluation scanning software.
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Printing Evaluations
- Only white paper, 28 lb. thickness
- 2-sided duplex printing recommended
- Do not use photocopied versions
- Print evals at 100% size (do not select
“fit” or “scale to fit page”
- Use blue or black pen and instruct
participants to stay inside boxes
3 different printing scales 2 different paper sizes YUCK, just yuck…
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PSA Policy Reminders
- Please make sure to register courses at least 2 weeks in advance!
This provides AFDO the necessary time to generate the registration paperwork and set up the course within the database.
– Retroactive registration not accepted unless all paperwork can be presented including PSA evaluations, course documentation, and proof of PSA lead Trainer/Trainer attendance, and subject to $250 administrative fee.
- Keep AFDO up-to-date if any changes are made after the initial
course registration is made (location, date, trainers, etc.).
– This impacts training certificates and eligibility for ToT status.
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Updated USB Content & Trainer Directory
USB content updated on August 1, 2018
- Download at:
https://producesafetyalliance.cornell.edu/training/grower-training- powerpoint-modules/ Keep your contact info up-to-date with AFDO and the PSA
- https://producesafetyalliance.cornell.edu/
training/directory/
- Use the ‘Update my Entry’ section
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2019 Goals
- Continue to support PSA Trainers, Lead Trainers, and those
interested in becoming PSA Trainers/Lead Trainers
- Continue to support growers in both understanding PSR
requirements and how to implement practices to reduce risks
- Complete and launch PSA Online Course (English and Spanish)
- Develop a Spanish PSA web interface
- Complete peer-reviewed publications to ensure we are
sharing data that has been generated
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Funding Updates
- PSA has received some additional funding to support
us through 2020
- Funding is still a concern as needs will extend far
beyond current funding
- PSA provides unique outreach and assistance that is
important to growers, trainers, and the produce industry
- Sustainable PSA funding is a challenge
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Importance of the PSA
- Collaboration
- Facilitating dialog and discussion
- Up-to-date resources and educational
materials
- Developing PSA Trainers and Lead Trainers
- Updating PSA Curriculum
- Providing Development Opportunities
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The PSA Website
http://producesafetyalliance.cornell.edu/
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