It was weird, and a newly hired FDA inspector was attending the training as well to learn how to enforce it. So it was good to know that the training I received matched what they're auditing against.
I still find it frustrating that they (FDA) kept maintaining it wasn't HACCP, but then make anyone under seafood HACCP, juice HACCP, and LACF regulations exempt. That tells me that they were unsatisfied with the HACCP plans they saw, but considered the ones prescribed by the government to be acceptable.
During the training we spent about half the time discussing about how we could use our existing HACCP plans (those of us under 3rd party schemes etc. who had them already) just by changing the terminology. You just need to identify preventative controls that fall under the PC umbrella (supplier approval, allergen labeling, and sanitation), were not a "process control" (which you can still call a CCP), and not one of FDA's identified pre-requisite programs (cGMP's like pest control).
Basically, if something on the risk matrix for your hazard analysis fell below the CCP-line, but above the "it's never happened" line, and it happened to be controlled by sanitation, allergens labeling, or suppliers, you created preventative controls. If it was controlled by a practice identified in the cGMP's, then it's still considered controlled by pre-requisite programs like maintenance and pest control.
It's a maze but I think I finally get it. The frustrating part is that I feel like I'm writing a program to satisfy an auditor rather than doing an honest hazard analysis and treating my programs as pre-requisites to producing food.