Hi Lacey,
As Jennifer B pointed out, you may have specific HR policies limiting the use of OTC medications, or there may be OSHA standards which come in to play which you have to consider for reasons other than "because SQF said so". Given the litigious society that we have become, as an employer you really need to consider whether the benefits of providing OTC medications outweigh the risk of a lawsuit should someone suffer unexpected side effects, or be allergic to the medication that was dispensed to them at work. From a food safety standpoint, you might also consider what the FDA says regarding the subject in GMP's (21CFR110 http://www.accessdat...h.cfm?fr=110.10).
A lot of times, it is less of a headache to just come out with a policy which states that x, y, and z are prohibited and that the use (or possession) of them has to be approved so it can be documented and controlled. (Please note the last part of 11.3.11.1: suitable arrangements shall be provided in circumstances when a patient requires more specialized care). Consider what the medication is, what is used for, how is it used, is this to control a contagious illness, will this medicine make the individual drowsy (and could a workplace accident occur), etc. etc. etc. etc.. If you allow the medication to be kept on the person, typically documenting this on a register/record in the office will suffice as the employer's knowledge that the medication is now present. It is up to the employee then to maintain control of it. If control is not maintained, the employee would need to be held accountable and responsible.
I've seen "Personal Use Medication" registers used and audited against successfully. I've also witnessed a company get a non-conformance on their audit because the auditor found a bottle of Tylenol left out on the desk in the production office. There was no control over the medicine and hence the nonconformance!
Ultimately, you have to ask the question: is there a risk if this were to become foreign material in the food? If so, how could it become foreign material? How can I control it so it doesn't become foreign material? How can I prove to the auditor that I have controlled it?
(FYI - if you come out with a policy stating that you control the medicine through prohibition, and the auditor winds up finding uncontrolled medication - you guessed it, nonconformance.)
This can be an area that might trip you up, so I hope you have found the contributions helpful.
Thanks,
Chris