1.- Allergens & Cross-Contamination: Education vs.

Ignorance
Approximately 15 million people live with food allergies, according to the
Food Allergy Research & Education (FARE) group. Restaurants today are filled
with guests who have become more educated but who are also sometimes
fueled by media-fueled misinformation. Employees are sometimes just as guilty
of being uneducated or misinformed. Both need to become more educated so
each is on the same page when necessary.
Food Allergies & Intolerances Explained
Lets clear up some differences between allergies, intolerances, sensitivities
and irritations as they relate to food. An allergy can be mild-to-severe, causing
symptoms ranging from mild hives to breathing issues, and may result in death
in severe cases. An intolerance orsensitivity can cause mild-to-severe
discomfort, and medical attention is sometimes needed. In the case of
anirritation, it is often an annoyance and may cause discomfort, but medical
attention is rarely needed.
What are these sinister food items causing all the trouble? The U.S. Centers for
Disease Control and Prevention (CDC) refer to the most common food allergens
as the Big 8milk, eggs, fish, crustacean shellfish, wheat, soy, peanuts and
tree nuts. Recently, corn and sesame have also been raising concerns.
In the case of an allergic reaction, physical symptoms are often apparent, and
employees must be aware of these indications. Warning signs every
foodservice employee should be aware of, and may need to call 911 about, are:
Hives
Itching
Swelling
Stomach pain

 Nausea or vomiting
Diarrhea
Sneezing
Coughing or wheezing
Shortness of breath
Difficulty breathing or swallowing
Swelling of airways
Restaurants always appreciate being provided with special dietary needs
information ahead of time. By giving staff time to prepare, the wait will be
lessened and the food will be handled properly. If a kitchen is limited on
equipment or space, items may not be efficiently cleaned. Restaurants may not
all carry products that meet a guests needs or exceptions. For severe allergies,
guests must understand that cross-contamination cannot be avoided.
What Needs to Be Done?
Training and education are key. All hospitality organizations must make it a
priority to train and educate their staff in sanitation and safety, including food
allergy education. The National Restaurant Association (NRA) leads in training
with the nationwide use of ServSafe, which certifies food service employees in
safety, handling and sanitation. Organizations may chooseor may be required
to use a Hazard Analysis and Critical Control Points plan, or they may create
an allergen assessment risk program. With either program, the risk must first
be assessed and all unintentional cross-contamination must be noted. Then
solutions for dealing with the risk must be decided. After setting management
guidelines for possible contamination, the solution must then be communicated
to employees, and a correction made. It is crucial that this be repeated and
reassessed throughout the flow of food handling.

Handling & Avoiding Cross-Contamination

Some food products can be contaminated before they are handled by
employees. This should be labeled by the manufacturer. Common examples are
products processed in a plant with other products containing wheat or nuts. It
is our obligation to notify our guests that such products are used. This can be
done with a menu note, tabletop advertisement, and/or relayed by the wait
staff.
Most allergen contaminations happen due to mishandling and mislabeling of
food products. As food handlers, there are important steps we can take. These
steps are recognized by CDC, the U.S. Food and Drug Administration (FDA) and
NRA as ways to avoid cross-contamination:
Use proper sanitary receiving guidelines (can be found at www.servsafe.com).
Implement a personal hygiene program. Cross-contamination is possible from
surfaces and people.
Use reputable suppliers, and check all permits and licenses.
Store all prepared food in areas separate from contaminants.
Properly handle, clean and store products in areas away from contaminants.
Wash and sanitize all equipment and small wares (use separate area or
equipment when possible).
Required training programs for front- and back-of-house employees.
Inform guests of secret ingredients.
Use visible disclaimer of possible allergens on menu.
Outcomes of Food Allergen Cross-Contamination
Food allergies are a major discomfort for those who have to deal with them.

The guest may have symptoms noted previously, and they also have a financial
commitment to doctor bills and medications, not to mention work missed. This
is all very unfortunate, but have you considered the loss for the establishment
that may have caused the cross-contamination that leads to the reaction? An
establishment may experience lawsuits, monetary loss, loss of customers and
reputation, negative media coverage, insurance liability, stakeholder liability
and possible business failureall because the night cook stored the rice near
the shrimp bisque.
By training employees, they have more accountability in keeping guests with
allergies safe, and they gain a level of confidence for having added knowledge
when a guest asks about specific menu items.
How Do We Begin?
Each person involved must have a responsibility to the establishment and to
the guest for food handling safety. With this knowledge, outbreaks can be
minimized and avoiding them can be a part of the daily sanitation protocol.
I cannot express how many times I have heard, What you teach your students
isnt the real world. My response: Well, yes, it is the real worldyou have to
make it that way. Set an example and follow through.
I dont have the time or the pockets to do extra training for my staff. They
should already know what to do. Me: There has to be time and money, just
figure out when and where, because the outcome of a real issue will be much
more expensive.
Finallybest things lastIt is common sense! Just clean as you go! Me:
Have you looked around lately? Common sense is not so common.
As industry leaders, we must keep a clean, safe environment for all guests,
regardless of their dining needs. It is crucial that we continue to educate both
our staff and our guests.

Chef Danielle M. Gleason C.H.E., C.S.C. has been an instructor at Sullivan

Universitys National Center for Hospitality Studies in Louisville, Ky. for 13
years. She is a ServSafe-certified instructor/proctor and also teaches online
sanitation courses. She sits on the board for the Salvation Army in Louisville
and is a member of Les Dames dEscoffier International.
2.Guidance to FSMA Compliance
By Kathy Hardee, Esq.
On August 24, 2016, the U.S. Food and Drug Administration (FDA) issued
portions of its guidance for complying with the Food Safety Modernization Act
(FSMA) Preventive Controls rule for human food, entitled Hazard Analysis and
Risk-Based Preventive Controls for Human Food: Draft Guidance for Industry. As
is customary, a guidance is not legally binding but provides FDAs current
thoughts on how to comply FSMAs preventive controls for human food. This
guidance is a draft and may be changed following public comment. That being
said, this is the first practical advice from FDA on creating a food safety plan
under FSMA.
When final, the guidance will include 14 chapters. Initially, the introduction,
chapters 1 through 5, and appendices 1 through 3 have been released, with
additional chapters and appendices to follow once prepared.
The purpose of the guidance as described by FDA is to assist facilities in:
Understanding the biological, chemical (including radiological) and physical
hazards that are commonly of concern in manufacturing, processing, packing
and holding of FDA-regulated food products
Understanding the components of a food safety plan and the importance of
each component
Understanding how to conduct a Hazard Analysis and develop a food safety
plan for the products that a facility processes

 Understanding how to identify control measures for common biological

(specifically bacterial pathogens), chemical and physical hazards associated
with many processed foods so those controls can be applied to the hazards
identified in a Hazard Analysis
Understanding how to identify and apply the preventive control management
components (i.e., monitoring, corrective actions and corrections and
verification)
Understanding the recordkeeping requirements associated with the food
safety plan and implementation of the food safety plan
Highlights of the first five chapters include the following:
Chapter 1: The Food Safety Plan
The food safety plan is the documentation of the processes which are required
to be taken when complying with the Preventive Controls rule. Chapter one sets
forth how a food safety plan and a Hazard Analysis and Critical Control Points
(HAACP) plan vary from one another. There is no standardized format for the
food safety plan, so long as it documents all of the required steps. Examples of
forms to be included in a food safety plan are included in Appendix 2.
Chapter 2: Conducting a Hazard Analysis
A Hazard Analysis is defined as the process of collecting and evaluating
information on hazards and the conditions leading to their presence to
determine which hazards are significant for food safety and therefore should be
addressed in a HAACP plan or food safety plan. A Hazard Analysis includes two
steps: (1) a hazard identification and (2) a hazard evaluation. A sample hazard
analysis worksheet is included in Chapter 2 and in Appendix 2.
Chapter 3: Potential Hazards with the Manufacturing, Processing, Packing and
Holding of Human Food
This chapter of the guidance suggests that hazards could include ingredient-

related hazards, process-related hazards and hazards that may be introduced

from the food production environment. Numerous examples of each type
hazard is provided for consideration. Food products may become contaminated
with biological, chemical (including radiological) or physical hazards.
Chapter 4: Preventive Controls
A facility only needs to apply preventive controls if, after conducting a Hazard
Analysis of the products and processes conducted at its facilities, a known or
reasonably foreseeable biological, chemical or physical hazards that requires a
preventive control is identified. A facility must implement preventive controls
so that any hazards requiring a preventive control will be significantly
minimized or prevented and the food manufactured, processed, packed or held
by the facility will not be adulterated. Chapter 4 provides examples of
preventive controls that might be used to address potential hazards. The
guidance in this chapter also is intended to provide recommendations on
monitoring the preventive controls.
Chapter 5: Application of Preventive Controls and Preventive Controls
Management Components
This chapter focuses on applying the preventive controls and instituting the
appropriate management components [i.e., monitoring, corrective actions and
corrections, and verification activities (and their associated records)].
One issue that has been of concern since the preventive controls were first
released is that of who is qualified to create the food safety plan. A preventive
controls-qualified individual (PCQI) must develop or oversee the development
of the plan. Qualification may be based upon training through job experience or
by completing training equivalent to the standardized training curriculum
recognized as adequate by FDA. Thus, a HAACP consultant or someone trained
in HAACP is not a PCQI without the additional training to understand the
requirements of a food safety plan under FSMA. The PCQI need not be an
employee of the facility.
The Food Safety Preventive Controls Alliance has been working to create an

FDA-approved curriculum since before the preventive controls were finalized.

Now completed, training is being provided across the country.[1] Completion of
this course will certify the participant as a PCQI qualified to create a food safety
plan for your facility. Review of the contents of the course will determine
whether someone is otherwise qualified based upon job experience. Sending a
facility representative to a training course to make sure they understand the
nuances between a HAACP plan and a food safety plan is recommended by this
author.
With final preventive controls in place, FDA has now provided guidance and has
endorsed training regarding compliance. The ball is now in the court of food
facilities to comply with FSMA.

4.FSPCA Preventive Controls for Human Food

Training
FSPCA PREVENTIVE CONTROLS FOR HUMAN FOOD
COURSE DESCRIPTION
The Current Good Manufacturing Practice, Hazard Analysis, and Risk-based
Preventive Controls for Human Foodregulation (referred to as the Preventive
Controls for Human Food regulation) is intended to ensure safe
manufacturing/processing, packing and holding of food products for human
consumption in the United States. The regulation requires that certain activities
must be completed by a preventive controls qualified individual who has
successfully completed training in the development and application of riskbased preventive controls. This course developed by the FSPCA is the
standardized curriculum recognized by FDA; successfully completing this
course is one way to meet the requirements for a preventive controls qualified
individual.
These courses are taught by Lead Instructors trained by the FSPCA, who have
been instructed in how to teach the FDA-recognized standardized curriculum.

This course is a prerequisite to the FSPCA PREVENTIVE CONTROLS FOR HUMAN

FOOD LEAD INSTRUCTOR TRAINING course.
RESOURCES

FSPCA Preventive Controls for Human Food Participant Manual (English)

FSPCA Preventive Controls for Human Food Courses

FSPCA Human Food Bookstore

FSPCA PREVENTIVE CONTROLS FOR HUMAN FOOD LEAD
INSTRUCTOR TRAINING
COURSE DESCRIPTION
This course provides the participant the knowledge and tools needed to
perform the duties of a Lead Instructor for the standardized training curriculum
that FDA considers adequate in meeting the requirements for training of a
preventive controls qualified individual under the Hazard Analysis and Riskbased Preventive Controls for Human Food rule.
The course content is focused on strategies to aid in the effective instruction of
the food safety activities and documentation that support the creation and
implementation of a preventive controls Food Safety Plan. Administrative tasks
for issuing Food Safety Preventive Controls Alliance certificates is also covered
as well as a refresher on effective presentation for the adult learner.
Upon successful completion of the full, 2-day FSPCA Lead Instructor Course for
Human Food, you will be qualified to be a Lead Instructor by the FSPCA.
Completing this training allows you to deliver the FSPCA Preventive Controls for
Human Food course as a Lead Instructor. You will receive email notification
upon completion of the course with instructions on how to download the Lead
Instructor for Human Food FSPCA certificate of completion.
PREREQUISITES

1.

Successful completion of the FSPCA Preventive Controls for Human Food

Course

2.

Must be an approved FSPCA Lead Instructor candidate to register

Information on how to apply to become a Lead Instructor can be found here.
Lead Instructor criteria shown below.
SELECTION CRITERIA FOR LEAD INSTRUCTOR
Applicants must meet the following criteria to be selected as a Lead Instructor
Candidate.
EDUCATION
Applicants must have at least 30 semester hours in one or a combination of the
following sciences:

biological sciences

food science /technology

chemistry

microbiology

veterinary science

animal science

public health

environmental health

or related scientific fields that provided knowledge directly related to the

human or animal food industry
WORK EXPERIENCE
Applicants must have at least five years of food safety work experience in or
with the human or animal food industry, e.g.,

food processing

packaging

handling facilities

corporate food safety function

food safety consulting or laboratory

food testing

food safety auditing

food safety training and education

food safety regulatory work (inspections, policy development,

compliance work)

or other related experience

FOOD SAFETY TRAINING EXPERIENCE
Applicants must identify specific courses / programs in which they have
participated in an instructor capacity. The committee will determine relevance
of the experience and may consider:

HACCP instruction experience

Combinations of different food/ food safety courses (including feed)

Academic teaching experience

FSPCA PREVENTIVE CONTROLS FOR HUMAN FOOD + FSPCA
PREVENTIVE CONTROLS FOR HUMAN FOOD LEAD INSTRUCTOR
TRAINING (INTERNATIONAL ONLY)
COURSE DESCRIPTION
This 4-day course combines the FSPCA Preventive Controls for Human Food
Course with the FSPCA Preventive Controls for Human Food Lead Instructor
Training. (See course descriptions above).

Upon successful completion of the course, you will be qualified to be a Lead

Instructor by the FSPCA. Completing this training allows you to deliver the
FSPCA Preventive Controls for Human Food course as a Lead Instructor. You will
receive email notification upon completion of the course with instructions on
how to download the Lead Instructor for Human Food FSPCA certificate of
completion.
PREREQUISITES
1.

Participants must be an approved Human Food Lead Instructor candidate

2.

You must be present for the entire course, please plan travel accordingly
LEAD INSTRUCTOR COURSE SCHEDULE
Below is a list of upcoming FSPCA Preventive Controls for Human Food Lead
Instructor Courses (approved, proposed or in the planning stages refer to the
color key).
Please Note!

1.

You cannot register for Lead Instructor courses from this website

2.

Only approved Lead Instructors for Human Food Candidates are sent
Lead Instructor course registration information via email when course
registrations opens

3.

No other information is available until registration opens