Beacon AI is a drafting assistant. It is not regulatory advice. It is not a substitute for HACCP plan validation, CCP determination, hazard analysis, or any other regulatory decision that requires a credentialed individual. Every output requires review and signature by a Preventive Controls Qualified Individual (PCQI), SQF Practitioner, or equivalent credentialed reviewer before regulatory use. Citations refer to public regulations as of the date displayed; consult original sources before relying on them. Use of Beacon AI does not transfer liability for the underlying regulatory decision to SystemPath, Anthropic, OpenAI, or Google.
Do I need a PCQI on staff, or can I contract one?
You do not have to employ a Preventive Controls Qualified Individual full time, but someone who meets the PCQI definition has to prepare and oversee your food safety plan. A contracted PCQI is allowed under 21 CFR 117 as long as that person does the required work - writing the plan, validating preventive controls, and reviewing records. For a five-person plant, a contractor is often the practical route.
What the rule actually requires
21 CFR 117 does not say a Preventive Controls Qualified Individual has to be your employee. It says certain tasks must be done by a PCQI: preparing the food safety plan, validating the preventive controls, reviewing records, and reanalyzing the plan when something changes. The title can sit with a contractor, a corporate resource, or a trained staff member - the work is what matters.
Staff or contract for a small plant
A five-person plant rarely needs a full-time PCQI. A contracted PCQI who knows your process can write and sign the plan and check in on the schedule the rule sets. Keep their training certificate and the signed plan on file so the role is clear. The trade-off is response time: an on-staff PCQI handles a deviation the same shift, while a contractor may be a phone call away. Match the choice to how often your process actually changes.
Frequently Asked Questions
Sources & Citations
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Beacon AI is a drafting assistant. It is not regulatory advice. It is not a substitute for HACCP plan validation, CCP determination, hazard analysis, or any other regulatory decision that requires a credentialed individual. Every output requires review and signature by a Preventive Controls Qualified Individual (PCQI), SQF Practitioner, or equivalent credentialed reviewer before regulatory use. Citations refer to public regulations as of the date displayed; consult original sources before relying on them. Use of Beacon AI does not transfer liability for the underlying regulatory decision to SystemPath, Anthropic, OpenAI, or Google.
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