What is PCQI Certification? Who needs PCQI Certification?
The FSMA Preventive Controls rule for Human Food and the Preventive Controls Rule for Animal Food both require that a facility has a “Preventive Controls Qualified Individual”, or PCQI. If you read this carefully you see it says “Qualified Individual”, not “Certified Individual”. There is no certification for the PCQI but there are certain qualifications an individual must have to be a PCQI. The answers to the questions “What is PCQI Certification?” and “Who needs PCQI Certification?” and “How do I get PCQI Certified?” are that there is no PCQI certification, no one is PCQI Certified and instead you will need to be able to show that you have the training and qualifications to be a PCQI.
Here, you can see the definition of a Preventive Controls Qualified Individual. This is a:
Qualified individual who has successfully completed training in the development and application of risk-based preventive controls, at least equivalent to that received under a standardized curriculum recognized as adequate by the FDA or is otherwise qualified through job experience to develop and apply food safety system.
The best way to meet these requirements is to take an FSPCA-approved course that uses the standard curriculum developed by FSPCA. Our online PCQI course meets these requirements.
This course is very interactive. You will watch videos to learn the information, take notes in your manual, listen to the examples and questions by our student group, and complete exercises in the exercise module. Your success is based on the completion of all of the content and successfully completing each exercise section. There is no final test.
What will I learn in this course?
Let’s take a look at how the preventive controls rule helps you build a preventive food safety system. The system builds on foundational systems that you have in place in your facility. Most facilities already have GMPs and other prerequisite programs. These are programs that keep your facility clean and sanitary and capable of making safe food.
These programs provide a foundation for your food safety plan. The food safety plan and these foundational programs work together to make up your food safety system. The food safety plan is your plan for controlling known or reasonably foreseeable hazards that are associated with your food products through the use of preventive controls.
This course will teach you how to write a FSMA-compliant Food Safety Plan and provide you with the qualifications to become a Preventive Controls Qualified Individual (PCQI). And now you are able to explain why you are Qualified to be a PCQI and are not a Certified PCQI.
Is the food safety plan different than HACCP? I had HACCP training, is that good enough?
Your facilities may already have a HACCP plan in place. Typically, HACCP plans focus on process controls. The food safety plan goes one step further and includes the other preventive controls I mentioned.
Supply chain, allergen and sanitation activities have typically been included in the GMPs or prerequisite programs. In the preventive controls regulation these may sometimes be elevated into the food safety plan as preventive controls. You will be learning about this throughout the course.
But what you see here is that sometimes when a hazard analysis identifies a specific hazard. For example, recontamination of product after a kill step. Then these activities become more important. In that example, a sanitation control is needed to control the hazard of recontamination. Sanitation is being used to control a hazard identified during the hazard analysis. We need to elevate that to a preventive control.
You can see that the sanitation circle overlaps in both GMPs and the food safety plan showing that sometimes sanitation activities are GMPs, but some specific sanitation activities may be elevated into the food safety plan. They may become preventive controls. In our example, sanitation to prevent the recontamination of product will become a preventive control, but general sanitation will remain a GMP
The same thing can happen with allergen controls or supply chain controls. When you see a specific hazard during hazard analysis, we will need to address those with the preventive control. So those activities now become part of the food safety plan. The requirement for becoming qualified to be the PCQI is that you have “successfully completed training in the development and application of risk based preventive controls, at least equivalent to that received under a standardized curriculum recognized as adequate by the FDA”. HACCP courses do not meet this definition.