SQF Health Questionnaire
Thanks,
Phil
Thank you for your timing!
Setanta
Because I am not recognizing this and I am preparing for an Audit, what is this under?
Thank you for your timing!
Setanta
11.3.1.1 Personnel suffering from infectious diseases or are carriers of any infectious disease shall not engage in product handling or processing operation
Edit: Or Personnel Hygiene and Welfare under whatever module is applicable for you
1. Did you go on a cruise?
2. Did you drink the tap water in Cancun?
3. How are your poops?
... and so on
Per SQF, we are having employees complete a Health Survey for pre-employment and upon returning from vacation or sick days. I really don't want to keep a file with this kind of information due to HIPPA laws. I'm thinking we will just document that the employee completed the survey and shred the survey. Any suggestions?
Thanks,
Phil
Hi Imadoughguy,
You have cited the chief reason why the GFSI "Medical Screening" requirements have been an issue for not only you, but a lot of other (US) industry professionals. I'd point you back to this conversation (although it was BRC-related, it applies all the same): http://www.ifsqn.com...h__1#entry56623
As an employer, do you want to take on the liability of infringing on privacy rights, or would you find it more advantageous to put the onus on the employee to report all illnesses to their supervisor? This is a slippery slope, and I'm afraid that a lot of US companies have put themselves at risk of litigation in attempt to simply pull the trigger on compliance to this requirement. I have been through GFSI certification a few times with different companies. At no time did I enforce "employee questionnaires", and at no time did I require pre-employment screening. These activities open you up to a lawsuit you can't win in court, and I've not seen a non-conformance result from stating that the internal policy requires the employee(s) to inform supervision of illness so they can be kept from direct food contact. You'll note that in the conversation I attached, 21CFR110 provides the federal directive regarding disease control:
"(a)Disease control. Any person who, by medical examination or supervisory observation, is shown to have, or appears to have, an illness, open lesion, including boils, sores, or infected wounds, or any other abnormal source of microbial contamination by which there is a reasonable possibility of food, food-contact surfaces, or food-packaging materials becoming contaminated, shall be excluded from any operations which may be expected to result in such contamination until the condition is corrected. Personnel shall be instructed to report such health conditions to their supervisors."
I hope this helps.
Chris
Hi Imadoughguy,
You have cited the chief reason why the GFSI "Medical Screening" requirements have been an issue for not only you, but a lot of other (US) industry professionals. I'd point you back to this conversation (although it was BRC-related, it applies all the same): http://www.ifsqn.com...h__1#entry56623
As an employer, do you want to take on the liability of infringing on privacy rights, or would you find it more advantageous to put the onus on the employee to report all illnesses to their supervisor? This is a slippery slope, and I'm afraid that a lot of US companies have put themselves at risk of litigation in attempt to simply pull the trigger on compliance to this requirement. I have been through GFSI certification a few times with different companies. At no time did I enforce "employee questionnaires", and at no time did I require pre-employment screening. These activities open you up to a lawsuit you can't win in court, and I've not seen a non-conformance result from stating that the internal policy requires the employee(s) to inform supervision of illness so they can be kept from direct food contact. You'll note that in the conversation I attached, 21CFR110 provides the federal directive regarding disease control:
"(a)Disease control. Any person who, by medical examination or supervisory observation, is shown to have, or appears to have, an illness, open lesion, including boils, sores, or infected wounds, or any other abnormal source of microbial contamination by which there is a reasonable possibility of food, food-contact surfaces, or food-packaging materials becoming contaminated, shall be excluded from any operations which may be expected to result in such contamination until the condition is corrected. Personnel shall be instructed to report such health conditions to their supervisors."
I hope this helps.
Chris
Your comments and directive are very helpful.
FYI... we ran our survey by our legal counsel and they okayed it.
I didn't ask them what to do with the completed survey... I'll let you know what they say about that.
Phil
-Chris
Per SQF, we are having employees complete a Health Survey for pre-employment and upon returning from vacation or sick days. I really don't want to keep a file with this kind of information due to HIPPA laws. I'm thinking we will just document that the employee completed the survey and shred the survey. Any suggestions?
Thanks,
Phil
There is no requirement under SQF for a "health survey".
Glenn Oster
http://www.getgoc.com
I know what you mean, I was thinking about it last night and I wouldn't feel comfortable filling out a health survey either.
Kinda sounds like we need to know but can't ask. :-)
We have to tell people what we want them to report, so I guess we could just give them a copy of the policy as a reminder when they return to work and at hire go over it as part of GMP training.
Phil
I should have said "as a means to meet SQF Code 11.3.1 we are thinking about a health survey" etc...
Nice to hear from you.
Thanks again.
Phil
I know SQF is not intended to be prescriptive, but how is a manager expected to know if an employee has a non-obvious infectious disease (ex.diarrhea) without the employee telling their supervisor or other management personnel? Most production employees have a limited number of sick days, and when they run out of days they're out money, so there is an incentive for them to work while ill. I have to believe that this is a regular occurance at most, if not all food manufacturers.
Tricky issue to be sure.
Thank you.