I truly enjoy being an instructor of the Foreign Supplier Verification Programs rule course offered by the Food Safety Preventive Controls Alliance. I served on the task force that developed the course. Even if I didn’t, I’d be a strong supporter of the courses offered by the FSPCA because before serving on the task force, I sat in the FSPCA course for the human food rule that we offered – that course was the first one to be offered. There’s no doubt that no matter which FSMA regulation is concerned, the FSPCA course is the best way to learn how to comply.

For those who aren’t familiar with the FSPCA, it’s a public-private partnership funded by FDA with the mission of creating training courses to help industry comply with the Food Safety Modernization Act.

Initially, the FSVP courses were offered in-person. I was conducting them all around the country and the interaction and participation was great! When the pandemic hit, the FSPCA said the FSVP course could be offered virtually. Knowing that many in the industry needed help, we were happy to oblige.

For the most part, the people taking the courses online are as into it as those who were taking them in-person. Of course, a cat or a child occasionally joins us for a short time but those “distractions” are not much different than a little laughter outside the meeting room when in-person.

The first FSVP compliance date was May 30, 2017. Luckily for some, FDA has been using enforcement discretion and working with importers to bring them into compliance rather than taking action against them. (That approach is changing, so importers should beware.) So the companies taking the course now are behind the curve. They need to take this seriously and learn what they need to do to comply.

Which brings me to the purpose of this blog entry. On occasion, someone taking the online session thinks they can get away participating in spirit only. We make it quite clear that participants must have their cameras on the entire time and must be engaged in order to get their certificate. In my last session, I had someone join via phone, saying he was driving to his office. I figured he was close, so I decided it was okay for the introductory portion. When he finally arrived at his office, he said he was having trouble with his video, though he eventually got on. After the lunch break, he’s back in his car. I told him he had two minutes to get in front of a camera. He comes back on shortly thereafter on video – in his car!

He was the first person I’ve kicked out of a session. He not only disrupted things for the rest of the participants, his behavior clearly showed he’s not taking things seriously. Maybe he was thinking the instructor wouldn’t really care and would award him his certificate no matter what – he’d pull something over on the instructor. The real loser in this scenario was him and he would have been the loser even if he somehow received his certificate because in the event of an FDA inspection, it would have taken less than a minute for the FDA investigator to see this guy doesn’t understand FSVP and would have little or none of the required documentation.

To this guy and others who are just going through the motions, I say “be serious!”