I am looking for clarification of what SQF deems as an "infectious disease". What diseases are considered "infectious." ? Is there a list? With HIPPA laws and the SQF code being vague, how can a company know they are in compliance? The issue was brought up with our HR department when an temporary employee acknowledged they had Hepatitis C. We need to clarify our company policy. The FDA recommends that employees not be excluded from employment.
Does this mean we should not include that particular disease?
Thanks in advance for your comments.
Hepatitis C and Employment Should a person infected with the Hepatitis C virus be restricted from working in certain jobs or settings?
CDC’s recommendations(https://www.cdc.gov/mmwr/preview/mmwrhtml/00055154.htm) for prevention and control of the Hepatitis C virus infection state that people should not be excluded from work, school, play, child care, or other settings because they have Hepatitis C. There is no evidence that people can get Hepatitis C from food handlers, teachers, or other service providers without blood-to-blood contact.
The code says, “13.3.1.1 Personnel suffering from infectious diseases or are carriers of, any infectious disease shall not engage in the manufacture of food contact packaging, or storage areas where food contact packaging is exposed”.
Guidance document states,
“Personnel Hygiene and Welfare
13.3.1 Personnel
13.3.1.1 Personnel suffering from infectious diseases or are carriers of, any infectious disease shall not engage
in the manufacture of food contact packaging, or storage areas where food contact packaging is exposed.
13.3.1.2 Personnel with exposed cuts, sores or lesions shall not be engaged in handling packaging materials.
Minor cuts or abrasions on exposed parts of the body shall be covered with colored bandage containing a metal
strip or an alternative suitable waterproof and colored dressing.
13.3.1.3 Smoking, chewing, eating, drinking or spitting is not permitted in areas where product is produced,
stored or otherwise exposed.
13.3.1 Implementation Guidance
What does it mean?
In many jurisdictions, personnel requirements in food manufacturing plants are covered by food safety
legislation. Where this applies, the legislative requirements must underpin the requirements of 13.3.1.
This element covers the basic personal hygiene requirement for working in food contact packaging
facility.
What do I have to do?
Staff identified as carriers of infectious diseases are not to be permitted to handle raw materials, work in
progress, or finished product.
Employees must be aware of risks to the products from the potential transmission of pathogens from ill
employees. An example of a control program could be the removal of an employee from direct contact with
product to non-product contact activities when the employee reports potential illness. Ideally, an employee
will not be penalized for reporting illness to the facility. This will be supported by introductory training with all
employees on reporting illnesses and a questionnaire on illnesses for visitors.
Staff in food contact manufacturing facilities with exposed cuts is not permitted to handle products unless
suitable protective coverings are applied. These coverings must be monitored regularly by responsible
personnel to ensure they remain effective. Bandages are to be brightly colored and protected to ensure they
can be easily seen and include a metal strip for ease of detection if the facility uses metal detection.
Dressings on hands and fingers are required to be covered with a suitable glove or finger cot or stall which is
disposable, colored and waterproof.
Smoking, eating, chewing and drinking are not permitted in areas where product is produced, stored or
otherwise exposed. A risk analysis for drinking water must be conducted and controls must be developed by
the facility to minimize the risk to the safety and quality of the product if it is provided in a production area
where product is exposed. If water is consumed in the processing area, it is recommended that employees
wash hands before returning to their station, or hand sanitizer needs to be applied prior to returning to their
work station.
13.3.1 Auditing Guidance
Medical screening and personal hygiene policies and procedures shall be reviewed at the initial desk
audit, and the effective implementation checked at each facility audit though observation, review of
records and interviews with staff. SQF auditors will question employees on hygiene practices to ensure
they are understood and applied. Evidence may include:
· Medical screening and personal hygiene policies and procedures are in place and effectively
implemented;
· Employees notify the business of illness;
· Personnel engaged in raw materials and packaging manufacturing do not exhibit any signs of
illness or open cuts or sores;
· Personnel who are known to have been ill with an infectious illness are not involved in
packaging manufacturing or handling stored product;
· Personnel sores or cuts on hands are redeployed to low risk areas or have cuts suitably
