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SQF Facility Audit, Challenge bodily fluids containment kit

SQF Challenge Bodily fluids Facility audit

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#1 CSL QC/QA

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Posted 18 June 2018 - 02:36 PM

Hello food safety world.

 

We just completed our SQF facility audit for Mod 2 and 11. We received a minor for not having a human body fluids containment kit on hand. This was not mentioned during the desk audit, as we presented the areas that we have first aid kits, the auditor seemed please with the kits and the locations, nor have I ever heard of a requirement for this. During the facility audit he asked to see the body fluid kits, Which of course we did not have. 

I did not agree and he asked if i wanted to challenge. Which i said , Yes. My question to the community is? 

 

What can i expect from SQF? 



#2 MsMars

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Posted 18 June 2018 - 02:40 PM

 

11.3.1.2 The site shall have measures in place to prevent contact of materials, ingredients, food packaging, food, or food contact surfaces from any bodily fluids from open wounds, coughing, sneezing, spitting, or any other means. In the event of an injury which causes spillage of bodily fluid, properly trained employee shall ensure that all affected areas including handling and processing areas have been adequately cleaned and that all materials and products have been quarantined and disposed of.

 

We caught this during a gap audit - we did not have a procedure in place specifically for the cleanup of bodily fluids.  I don't see a requirement in the code specifically for a bodily fluid cleanup kit, but they are handy to have and help cement your procedure for cleanup since they contain all the necessary supplies for it. They're not very expensive, either. 

 

Do you address bodily fluid cleanup in any of your SOPs?


Edited by MsMars, 18 June 2018 - 02:43 PM.


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#3 Scampi

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Posted 18 June 2018 - 02:48 PM

11.3.1.2 The site shall have measures in place to prevent contact of materials, ingredients, food packaging, food,
or food contact surfaces from any bodily fluids from open wounds, coughing, sneezing, spitting, or any other
means.
 
Agree with Mrs. Mars----you need only a procedure and some plan to deal with this should it happen 
 
Absorbant pads/kitty litter/ paper towels
Biohazard bags for disposal
Gloves for clean up
Sanitizer that will kill blood borne pathogens
 
Steps to follow
attend to employee (first aid, hospital what have you)
cordon off area (pylons and bright yellow "danger" tape or something like it
Prevent spread of fluids (absorbent pad,kitty litter, inflatable dams)
Clean up fluids (dedicated employee and SOP)
Double bag and remove to exterior garbage (including gloves and any other PPE used in clean up)
Sanitize area (or clean and sanitize depending on severity)
 
Be sure to include a reference that product MAY be put on hold if there is any chance it was contaminated pending lab analysis---or just condemn it, better safe than sorry)
 
But NO you do not need to purchase a special kit and the above steps may be over kill depending on your process/lay out etc

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#4 Scampi

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Posted 18 June 2018 - 02:49 PM

Oh, and on your daily GMP /operational record, you should be monitoring for

 

Open wounds

Coughing/spitting etc


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#5 CSL QC/QA

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Posted 18 June 2018 - 02:58 PM

Thank you for the quick response. 

 

In our First aid policy we have written that all blood or body fluids will be cleaned up using a spray bottle of diluted bleach, wiped down and paper towels will be disposed of immediately in a separate bag. We had told the auditor this and showed him the SOP. But he then asked specifically do we have a kit.

 

Dennis 



#6 CSL QC/QA

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Posted 18 June 2018 - 03:03 PM

Thank you MsMars and Scampi. It is starting to make more sense. 

 

We still scored a 94. So I'm not sore about it, but I do want my facility to have appropriate procedures in place. This will be a good exercise for our continuous improvement log to turn in to senior management. Thanks again.

 

Dennis



#7 Scampi

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Posted 18 June 2018 - 03:06 PM

on the subject of your auditor, those are the sorts of things we all need to push back on. They cannot dock points for something that is not mentioned in the code.

 

You will see that auditors 'demanding" ridiculous things is something we've all come across.

 

Glad to help!!!


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#8 MsMars

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Posted 18 June 2018 - 03:38 PM

Dennis - if it's addressed in your first aid policy and you have a procedure for it, then I would think you have grounds to challenge since the code does not specify that you need a kit.  But I suppose if you scored a 94, it would depend on how much trouble you are willing to go through for 1 point.  If you have other challenges to make that could potentially bring you up to a 96 or higher, then it would be worth trouble to add this one since you'd have the potential to be bumped up to "Excellent".  But sadly, IMHO and contrary to what Scampi said, I don't know that I would go through that process for one point.  Just my thoughts.



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#9 Scampi

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Posted 18 June 2018 - 03:46 PM

I agree Mrs. Mars, I would have argued during the audit........but I've been doing this for a very long time and got my start in poultry where you have a vet on a power trip looking over your shoulder constantly threatening to stop production because he/she saw one fly in a 15000 sq foot facility in July

 

I probably wouldn't file an appeal after the fact on one point

 

I would, however, inform my CB of the comment so they can ensure the auditors are equally following the code.


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#10 MIguel A. Rodriguez

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Posted 18 June 2018 - 04:06 PM

Very interesting. Thank you all for the comments. This little tiny things are the reasons of lot of headache during audits.


Edited by MIguel A. Rodriguez, 18 June 2018 - 04:06 PM.


#11 SQFconsultant

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Posted 18 June 2018 - 06:14 PM

So, you had an SOP for this and you showed the documentation to the Auditor.

 

But, the auditor wanted an actual body fluid kit.

 

And you got hit with a minor for it.

 

There is no requirement for a body fluid kit.

 

This happened at one of our client locations.

 

They challenged it to the CB with copy to SQFI.

 

They won.


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#12 kfromNE

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Posted 21 June 2018 - 06:52 PM

I see you're from the US. I know this won't help but I suspect your auditor required the kit because it is required for many food establishments controlled under state regulations because it is part of many state food code laws. Having taught ServSafe for many years, I know it is mentioned in the manual. Your auditor was mostly likely confusing state vs federal.



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#13 Hoosiersmoker

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Posted 21 June 2018 - 08:19 PM

I agree with not bothering for one point but it is our responsibility to keep an auditor - that we hire incidentally - in check when it comes to coloring outside the lines. If it's done in a manner that doesn't alienate the auditor, who might be back next year, it's definitely worth the effort. Just my .02







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