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Addresses definitions for foodborne disease outbreak exemptions, critiques setting a fixed 70% passing score, and recommends recognition of exams validated under established testing standards. Raises concerns about approval scope across multiple food establishment categories, confidentiality of application materials and exam content, and the future flexibility of certification exam formats amid technological change.",{"@graph":14,"@context":73},[15,34,56],{"@type":16,"itemListElement":17},"BreadcrumbList",[18,23,27,31],{"item":19,"name":20,"@type":21,"position":22},"https://docshare.wps.com","Home","ListItem",1,{"item":24,"name":25,"@type":21,"position":26},"https://docshare.wps.com/document/","Document",2,{"item":28,"name":29,"@type":21,"position":30},"https://docshare.wps.com/document/exam/","Exam",3,{"item":32,"name":10,"@type":21,"position":33},"https://docshare.wps.com/document/food-employee-certification-act-department-of-agriculture-comments-on-proposed-regulations/495815/",4,{"url":32,"name":10,"@type":35,"image":36,"author":41,"headline":10,"publisher":44,"fileFormat":47,"inLanguage":8,"description":12,"dateModified":48,"datePublished":49,"encodingFormat":47,"isAccessibleForFree":50,"interactionStatistic":51},"DigitalDocument",{"url":37,"@type":38,"width":39,"height":40},"https://docshare.wps.com/thumbnails/food-employee-certification-act-department-of-agriculture-comments-on-proposed-regulations/495815.png","ImageObject",300,407,{"name":42,"@type":43},"Ophelia","Person",{"url":19,"name":45,"@type":46},"DocShare","Organization","application/pdf","2026-11-04","2026-10-02",true,{"@type":52,"interactionType":53,"userInteractionCount":55},"InteractionCounter",{"@type":54},"ViewAction",12,{"@type":57,"mainEntity":58},"FAQPage",[59,65,69],{"name":60,"@type":61,"acceptedAnswer":62},"Why does the submission argue against deleting the exemption language in the definition of foodborne disease outbreak?","Question",{"text":63,"@type":64},"The comments state that the 1997 FDA Food Code and updated Centers for Disease Control definitions no longer allow this exemption, so the referenced language should be removed.","Answer",{"name":66,"@type":61,"acceptedAnswer":67},"What is the position on setting a fixed 70% passing score?",{"text":68,"@type":64},"A fixed score is viewed as invalidating exams built on nationally recognized standards, because passing scores should be determined by exam developers based on expert recommendations comparing difficulty with minimum job knowledge requirements.",{"name":70,"@type":61,"acceptedAnswer":71},"How should confidentiality and exam integrity be protected for certification program approvals?",{"text":72,"@type":64},"The comments recommend precautions to prevent public disclosure of materials provided under the approval process, proposing a framework that treats the certification examination and its contents as highly confidential and proprietary to preserve usability and purpose.","https://schema.org",{"og:url":32,"og:type":75,"og:title":10,"og:site_name":45,"og:description":12},"article",{"robots":77,"canonical":32},"index,follow",{"doc_id":79,"site_id":7},495815,1790928972,{"code":4,"msg":82,"data":83},"success",[84,88,92,95,100,105,110,115,120,123,127],{"id":22,"doc_module":4,"doc_module_name":25,"category_name":85,"show_sort_weight":86,"slug":87},"Story & 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\nBureau of Food Safety and Laboratory Services2301 North Cameron StreetHarrisburg,PA 17110-9408  \nAttention:Martha M.Melton  \nDear Ms.Melton:  \nThe Bureau of Food Safety and Laboratory Services is to be commended for thedevelopment of proposed regulations that very closely approximates what the participatingindustries had intended when it proposed the Food Employee Certification Act,3 Pa.C.S.86503(d)and 6505.  \nIt is very important to realize however,that at the very core of industry's participation inthis process was an understanding and agreement to utilize existing nationally recognized testingprocedures for sanitation training as models wherever possible.In the restaurant industry'sparticular situation our SERVSAFE®courses are recognized as a model for training and fortesting throughout the United States.We have several recommendations in areas where we thinkthe Department could be more responsive to the existing industry standards.  \nWe respectfully submit the following comments to improve the proposed regulations forthe Food Employee Certification:  \n1.§76.2～Definitions.  \nUnder the definition of Foodborne disease outbreak -part (ii)states in significant part“The term includes a single case of illness such as one person ill from botulism orchemical poisoning.”  \nIt is our belief that this should be deleted as the new Centers For Disease Control,definition reflected in the 1997 FDA Food Code,no longer allows for this exemption.  \n# 2.§76.4 and 76.10-Eligibility to apply for certification and Applying for certification.\n\nThe proposed regulations establish a passing score for the certification exam at 70%or higher on an approved certification examination.We believe that if the proposedregulations specify a specific passing score,it will invalidate all of the examinationsthat were developed based on nationally recognized standards for test development.  \nThere are scientifically-based standards for determining the passing score for examsthat all examinations must follow to be valid and reliable.The passing score for anexam is determined by the exam developer based on the recommendation of expertswho compare the examination difficulty with the minimum knowledge required tofunction in the job being tested for.These scores are established after the test hasbeen developed.Therefore,every approved exam may legitimately have a passingscore.For instance,harder tests will likely have a lower passing score and easiertests will likely have a higher passing score.  \nORIGINAL:\\#1858COPIES:   HARBISONSMITHSANDUSKYWYATTEBERESCHAK  \nTherefore,it is inappropriate to establish a specific passing score for alreadyestablished certification examinations.The proposed regulations would be betterserved by stating that the Department will recognize examinations that are developedto national standards(i.e.,Standards for Educational and Psychological Testingdeveloped jointly by the American Psychological Association,American EducationalResearch Association and National Council For Measurement in Education).Ourcertification programs by the Educational Foundation of the National RestaurantAssociation comply with these national standards.  \nOnce again,a passing grade determination should be established based on theexisting standards that are nationally recognized and that the Department shouldretain the flexibility to establish passing scores based on the certification programproposals submitted to the Department which would subscribe to these nationalstandards.It does not make sense to arbitrarily establish a passing score of 70%asthe all encompassing standard.  \n3.§76.5-Certification programs:obtaining the Department's approval.  \n(b)General requirements for approval -Can a certification program be approved if itaddresses more than one industry-specific category of food establishmentdescribed in876.3(a)?For instance,our SERVSAFE⑧Certification Program hasbeen approved for restaurants,congregate feeding sites,co","cbCaidgT8FvMqTq8","https://ap.wps.com/l/cbCaidgT8FvMqTq8","pdf",2212541,45,"English","# §76.2 - Definitions\n## Foodborne disease outbreak exemption\n# §76.4 and §76.10 - Eligibility to apply and applying for certification\n## Passing score rationale and national testing standards\n# §76.5 - Certification programs and approval\n## Program scope across industry categories\n## Confidentiality of approval documentation\n# §76.8 - Format of a certification examination\n## Multiple-choice and future technology considerations","[{\"question\":\"Why does the submission argue against deleting the exemption language in the definition of foodborne disease outbreak?\",\"answer\":\"The comments state that the 1997 FDA Food Code and updated Centers for Disease Control definitions no longer allow this exemption, so the referenced language should be removed.\"},{\"question\":\"What is the position on setting a fixed 70% passing score?\",\"answer\":\"A fixed score is viewed as invalidating exams built on nationally recognized standards, because passing scores should be determined by exam developers based on expert recommendations comparing difficulty with minimum job knowledge requirements.\"},{\"question\":\"How should confidentiality and exam integrity be protected for certification program approvals?\",\"answer\":\"The comments recommend precautions to prevent public disclosure of materials provided under the approval process, proposing a framework that treats the certification examination and its contents as highly confidential and proprietary to preserve usability and purpose.\"}]","Food Employee Certification Act - Department of Agriculture Comments on Proposed Regulations | PDF",1790922365,113]