When drafting regulations, it is very important that you do so in a manner that is consistent with requirements set forth by the new SQF/BRC... standards, so there is no conflict in our procedures.
We, (GIS) are a very small (less than 10 employees) food manufacturer and work very hard to keep up with demands. The courses we are required to take to get us to the level we need to be are available only thru private bodies (NSF...) and are very costly, $1000 per course, as well as the audits. WE spend $3-5,000 a year to stay educated.
More government sponsored educational materials (way beyond "wash your hands" would go a long way to avoid any fines. Only large corporations with good budgets can afford the training to operate a safe food environment.
JoAnne Theodore - Comment
This is comment on Notice
Burden of Food and Drug Administration Food Safety Modernization Act Fee Amounts on Small Business
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