FDA's food plant rules ask that everyone who makes, packs or holds food be qualified for the job: the education, training or experience, or a mix, to make clean and safe food at their station. That includes temporary and seasonal workers. Each one also needs training in food hygiene and food safety, including employee health and personal hygiene, fitted to the food, the plant and the job, and someone with the right background has to be responsible for seeing the rules are followed. The training has to be recorded, and records are kept at least two years. This applies to every plant under FDA's good manufacturing practices, qualified facilities included. The preventive controls qualified individual who writes a food safety plan is a separate, further requirement. In the example below, a Michigan preserves maker trains its cherry season crew.
The short version
- Every worker must be qualified for their duties, seasonal staff included.
- Train in food hygiene and food safety, including health and personal hygiene.
- Fit the training to the food, the plant and the job.
- Assign a qualified supervisor to make sure the rules are followed.
- Record the training; keep records at least two years.
- Qualified facilities aren't exempt from this.
- TaroStack keeps the batch records trained staff fill in. More below.
Who needs what
| Who | What the rule asks |
|---|---|
| Everyone who makes, packs or holds food | Qualified for their duties; food hygiene and food safety training, including health and personal hygiene; a training record |
| Temporary and seasonal workers | The same, before they start the job |
| Supervisors | The education, training or experience to supervise clean and safe food; responsibility clearly assigned |
| Whoever prepares a food safety plan | A preventive controls qualified individual, on top of the above |
| Qualified facilities | The same training and records; no food safety plan |
A ready-made log is in employee training log template, and what a preventive controls qualified individual does in pcqi requirements.
The rules
| Rule | Where |
|---|---|
| Everyone qualified | All who manufacture, process, pack or hold food, including temporary and seasonal personnel, have the education, training or experience for their duties (21 CFR 117.4(b)(1)) |
| The training | Food hygiene and food safety, including the importance of employee health and personal hygiene, as fits the food, the facility and the duties (117.4(b)(2)) |
| Supervisors | Responsibility for compliance assigned to supervisors with the education, training or experience to supervise clean and safe food (117.4(c)) |
| Records | Training records established and kept (117.4(d)); at least 2 years (117.315) |
| The plan's author | A preventive controls qualified individual prepares or oversees the food safety plan (117.180) |
This is general information, not legal advice.
An example: a cherry season crew
Old Mission Preserves, the made-up preserves maker in Traverse City, Michigan, I use in these examples, hires six seasonal workers each July for cherry season. It's a qualified facility, so it has no food safety plan, but the training rule applies all the same:
| Who | Training | When | Recorded |
|---|---|---|---|
| Six seasonal pitters and fillers | Handwashing, illness reporting, hair and jewelry, the allergen rule for the almond line, glass breakage | First morning, before the line starts | Name, date, topics, trainer |
| Returning seasonal worker | The same, plus what changed since last year | First morning | The same |
| The kettle operator | The process for each jam: times, temperatures, pH and fill | Before running a kettle alone | The same, with the process sheets |
| The production lead, the supervisor | Responsible for the rules on the floor | Assigned in writing each season | A signed assignment |
The kettle operator's training follows the processes in the jam plan, in jam haccp plan. The records for the season go in one folder and stay for at least two years, past the next attestation.
Get the checker
Download the training log. One sheet: each worker, their job, the date trained, the topics and the trainer; whether the record is complete and the date it can be discarded fill in. It's an ordinary Excel file with no macros, and it works in Google Sheets, LibreOffice and Numbers.
Where this stops working
The log shows who was trained. Which batches each crew made, and from which lots of cherries, is the other half of what an inspector asks to see.
How TaroStack does it
TaroStack keeps the batch and lot records that trained staff fill in, so each day's batches are on record.
Batches by lot and date. Each kettle run is a batch with its date, the cherry and sugar lots it used and how many jars it made.
Receiving by supplier and lot. Each delivery of cherries is received from its orchard with its lot.
Recalls. If a batch has to come back, one report shows every customer who got it.
| The job | Notebook | In TaroStack |
|---|---|---|
| Which batches the seasonal crew made | A notebook | Batches by date |
| Which orchard's cherries went into a batch | Not recorded | Batches by lot |
| Who got a batch | Invoices | One recall report |
Receiving, batches, lots and recalls are on every plan, from $49 a month. The first 30 days are free, with no credit card. If you'd like a hand setting up, ask, and we'll do it with you.