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Food Safety Training Q&A
- Is HACCP (Hazard Analysis and Critical Control Points) training required for all employees involved in food manufacturing?
- Yes. It is essential that all employees involved (either directly or indirectly) in food manufacturing are adequately trained. These employees may include food production personnel, maintenance personnel, and sanitation personnel, as well as the food production supervisors and managers. Food manufacturers should implement a written training program to ensure that all of the staff members are aware of their responsibilities in upholding food safety. In addition to the initial food safety training, it is highly recommended that employers conduct or ensure supervision and instruction as the employees work. The periodic evaluation of employee competency is also strongly encouraged. In the case of insufficient performance, re-training should be undertaken as needed.
- Is GMP (Good Manufacturing Practices) training required for all employees involved in food manufacturing?
- No. Currently, GMP training is highly recommended for food handlers and supervisors, and this is a recommendation which also applies for every employee who comes in direct or indirect contact with food manufacturing. GMP training typically addresses the issues of record keeping, sanitation, staff qualifications, equipment verification, cleanliness, process validation, and complaint handling. Ideally, all employees should be trained. It is good to remember that food manufacturers are subject to arbitrary inspections; a food manufacturing site that does not comply with the GMP standards can be punished with recall, fines, seizures, or jail time.
- Do we need to reveal the contents of our secret recipes in order to implement HACCP training?
- No. It is enough to evaluate the preparation process of the food products (i.e. monitoring cooking, hot and cold holding, cooling, reheating, receiving, etc.); this in itself is considered a thorough implementation of HACCP training.
- Does FSMA (Food Safety Modernization Act) require employees to receive food safety training?
- No, not specifically. However, FSMA does require employers to create a written preventive controls plan, which typically includes the element of food safety training. Specifically, the plan involves: (1) evaluating potential hazards to food safety; (2) identifying preventive controls to reduce/avert the hazards; (3) specifying how the controls will be monitored and retaining records; and (4) identifying corrective actions should problems arise.
- How often does the FDA inspect food manufacturing facilities?
- According to FSMA, high-risk domestic food processing facilities must be inspected by the FDA once in the next five years (at minimum), and then once every three years. Low-risk domestic food processing facilities must be inspected by the FDA once every seven years, at minimum. The FDA is also required to evaluate relevant health data every two years (so as to determine any dangerous food-borne contaminants). While there is no comprehensive list available as per what facilities are determined high- or low-risk by the FDA, high-risks foods are typically deemed those which have a higher potential to cause harm after consumption (i.e. ripened cheese, unpasteurized juice, prepared salads, infant formula, etc.).
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