Food Safety Awareness Training
Updated September 20, 2017
FDA now offers free online training for carrier personnel
On September 20, 2017, the U.S. Food and Drug Administration announced availability of a free one-hour training module to help carriers meet the training requirements of the sanitary transportation rule. The training module can be launched online or downloaded at https://www.fda.gov/Food/GuidanceRegulation/FSMA/ucm576097.htm.
The awareness training requirement outlined in Section 1.910 of the rule applies when the carrier and shipper have agreed in a written contract that the carrier is responsible, in whole or in part, for the sanitary conditions during transportation. Note also that under the rule, a freight broker is considered a shipper, so the requirement applies in written contracts between carriers and brokers as well.
While carriers are required to provide training to personnel in those circumstances, they do not have to use the free FDA module. FDA says that carriers may:
Offer this module to their operations personnel as a means of satisfying the minimum requirements;
Use this module to complement or enhance training they currently offer;
Train their personnel using their own training programs; or
Provide training obtained from a third-party vendor or other provider
The FDA course is designed to provide basic food safety training to transportation operations personnel, but it does not describe specific operating procedures and practices. The goal is to complement industry best practices. The FDA training module will help personnel:
Recognize their responsibilities under the rule;
Identify potential food safety problems that may occur during food transportation; and
Describe common ways to prevent food safety problems
Depending on your capabilities and preferences, there are two ways your personnel can complete FDA's Sanitary Transportation Rule training module:
Carrier personnel can take the course online from the FDA website. At the conclusion of the online module, they can print a certificate of completion. To ensure that the certificate prints properly participants should enter their names as they want them to appear in the designated areas of the training. They can follow the instructions at the end of the training to print their certificate.
Companies that maintain their own SCORM-compliant Learning Management System (LMS) can download the course files and import them into the LMS. One advantage of this method is that the LMS automatically tracks completion data to satisfy the documentation requirements of Under Section 1.912(c).
System requirements for viewing the online module on computers and mobile devices and instructions for LMS administrators are available on the FDA website.
Alternatives to FDA module
Most carriers will find it both easy and obviously cost-effective to use either the online or downloaded FDA module. However, a carrier can develop and/or deliver its own training program if it has a reason to do so. In the final rule, FDA explicitly said an in-house program is acceptable as long as it meets the content requirements of 1.910(a) and the documentation requirements of 1.910(b). To comply with the rule and UFSTP, an awareness training program for personnel engaged in transportation operations at a minimum must cover:
Potential food safety problems that may occur;
Basic sanitary practices; and
Carrier responsibility under the rule
Clearly, your best guide to what content is acceptable is that included in the FDA module.
Regardless of whether a carrier uses the free FDA module, conducts its own training or uses a third-party provider, it must maintain a record of the date the training occurred, the type of training and the name of the person trained. Under Section 1.912(c), these records must be maintained on each individual until at least 12 months after the individual stops performing the duties for which the training is provided.
Third-party training providers remain an option. UFSTP is monitoring third-party providers and will share those providers and any discounts for UFSTP applicants to carriers once they apply and pay the annual fee.