Author’s note — Caution: soapbox rant ahead!
This will definitely come across as a soap-box-ish rant. As with any source of enlightenment and learning, the newly indoctrinated are historically known to be a bit overzealous and passionate about their newly gained knowledge, As someone recently certified with PCQI credentials, this author falls squarely into that category. Nevertheless, the import of the training and the understanding of how food safety is designed as a living “system” is so important, that it deserves a soapbox treatment. So with that context, read on!
The overarching goal of the Food Safety Modernization Act (FSMA) was to better protect public health by strengthening the food safety system. FSMA introduced several new concepts and regulations, among which, the requirements around Preventive Controls were specifically and significantly enhanced.
One such enforcement advancement is the requirement for Preventive Controls Qualified Individuals (PCQI’s). Every food manufacturing/processing facility must have a PCQI to oversee and be responsible for the preparation and implementation of a comprehensive Food Safety Plan. That plan must include an analysis of potential hazards in their processes and where/how to implement preventive controls, corrective actions, root cause analysis, verification and validation of food safety processes and scientific methods.
And while having a certified PCQI is required by law, here are two reasons why we encourage solution provider leaders and customer-facing professionals in the industry to pursue formal training.
Walking The Walk (…and Driving)
While simply designating and training a leader is a productive first step, truly being a PCQI is far more than a certification — It is being able to look at how a food safety operation runs, how it should run, and where preventive controls should be applied.
The same kind of holistic rhythm is required to drive a car safely — wielding your gas, breaks, signals, and gear shifts all in synchronization. A driver must also keep a clear view of what’s ahead — assessing speed, turns, pedestrians, other cars and potholes. Driving is less about the present, but truly preventing problems in the immediate future.
Food safety requires the same holistic approach — to be able to react while accounting for and managing many moving parts. We can take the metaphor further: Similar to how passing a driver’s exam demonstrates an understanding of how to safely operate a vehicle, unless everyone puts those concepts into action behind the wheel, the roads are no safer.
As the industry adopts information technology and moves toward digital automation solutions, it is critical that solution providers themselves adopt the food safety culture and knowledge that aligns with the FSMA compliance requirements of their customers. Organizations that adopt a leadership requirement for PCQI certification will be more capable of implementing the core food safety concepts into the day-to-day operations and use of their digital technology solutions and services. As a result, our industry as a whole will reap the benefits of what the FDA is now foreshadowing as the next FSMA advancement – a “new era of smarter food safety”.
Changing the Culture
The information imparted as part of the PCQI certification training creates a standard base level of understanding among food industry customers and the solution providers that support them. Therefore, the more solution provider team members that get involved, the better this common understanding pervades the culture of the organization, and its outward engagement with the industry.
‘Getting ahead of it’ is a concept that is often espoused within a food safety team. Visibility to all aspects of sanitation, process, and supplier controls leads to a common understanding of the interrelationships and possible root causes for food safety issues. This thinking and visibility of information should not only apply to food safety processes, but the food safety culture itself. When leaders become PCQI certified, the common understanding of preventive controls becomes part of the organization’s culture, and NOT just a shared knowledge base among the food safety team.
Changing the culture often involves the herculean task of re-setting food safety’s role and positioning in the minds of executives. Food safety preventive controls are at the heart of the matter. When done right, and when communicated effectively, the results will impact the business in a positive way.
For example, consistent preventive control management leads to lower risk of audit issues, inspection failures and ultimately production downtime. When leaders are indoctrinated in the connection between food safety practices and business outcomes, the overall food safety positioning changes — from one of being a cost center, to one of being an essential driver of risk management.
Like a rising tide that lifts all boats, the industry as a whole can see that “being preventative” is not only smart regulation, it is smart business. The start is the common baseline of understanding that is PCQI certification. Rather than seeing PCQI as a burden, let’s view it as an opportunity to move as a whole in the right direction.