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Employee medical fitness- recurring positive results

medicals FSSC22000 staphylococcus aureus

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lydiashoniwa

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Posted 06 March 2019 - 08:03 AM

Hi everyone 

 

I hope you are all well. 

 

We are a sauce, condiments and spice (powder blends) manufacturer certified under FSSC22000, and we have a bit of an issue when it comes to staff medicals- one of our staff members- a food handler in the dry blending plant- has tested positive for a Staph aureus  nasal swab every time for the past 4 medical exams. On all occasions when the result returns positive, we provide counselling that explains what staph is, where it comes from and the effects it has on food safety etc, then we issue them with an antibacterial ointment to treat the  "ïnfection", now this normally does the trick and after a week of treatment the staff member gets retested usually yielding a negative result- but this particular staff member tests positive over and over again. We are at our wits end and are now considering terminating her contract as we are a very small company (less than 50 employees), there is not any other department/area we can move her to really plus there is also the risk of her contaminating product and well as infecting other staff- any advice on how we can go about solving this riddle?



Charles.C

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Posted 06 March 2019 - 12:47 PM

Hi Lydia,

 

I assume these products can be RTE.

 

So what is the legal situation in S.Africa ?

 

I think in the UK, for example, exclusion or "transfer" would probably be a legal requirement.


Kind Regards,

 

Charles.C


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Posted 06 March 2019 - 02:29 PM

Lydia,

 

As mentioned in the above post, you have to sort out the legal requirements at your place.

This person (though might only be a carrier of Staph) can be a source of product and process contamination and can jeopardize your product, which in most cases is post treated and RTE.



Scampi

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Posted 06 March 2019 - 03:30 PM

does said employee follow all your GMP's?  Staph is found on most people in one area another...…

 

A nasal swab seems a bit much to me, unless of course your facility isn't following proper procedures, and why did you chose a nasal swab instead of skin on hands?

 

The bacterium Staphylococcus aureus is often found on the skin and in the noses of healthy people, and may or may not cause problems. It has been estimated that at any given time 25 to 30 percent of the population has staph bacteria in the nose, but only some of those infected have symptoms

 

About 25% of people and animals have Staph on their skin and in their nose. It usually does not cause illness in healthy people, but Staph has the ability to make toxins that can cause food poisoning.

 

Are you prepared to lose 25% of your workforce?


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FSQA

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Posted 06 March 2019 - 03:48 PM

does said employee follow all your GMP's?  Staph is found on most people in one area another...…

Scampi,

 

I agree , and as some stats show Staph can be a natural habitat on skin, nose and other body parts in 33% healthy population in the US ( i can only speak of USA), however, IMO she is not the only one who was targeted and tested for the nasal swab testing. Other employees would have been tested too. She is being getting positive results on repetitive testings.

 

She might be an healthy individual but she might be a carrier, and since this several tests are conducted/documented already, how can one justify of keeping her on handling the RTE product and ascertain that GMPs are followed without continuous supervision and monitoring (just my opinion).



Scampi

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Posted 06 March 2019 - 04:00 PM

I worry about the human rights piece on this...….(at least in  Canada) an employee who was terminated because "maybe" the could make people sick could sue for wrongful termination and/or having their human rights violated. There are lots of folks working in a lot of varying fields where they could pass on an illness without knowing, are we going to start checking for TB as well (people can carry and never get sick with this one too)

 

I would consult a lawyer before deciding anything permanent and put employee in another area pending determination

 

 

Just wondering where to draw the line...…………...


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Charles.C

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Posted 06 March 2019 - 09:10 PM

I worry about the human rights piece on this...….(at least in  Canada) an employee who was terminated because "maybe" the could make people sick could sue for wrongful termination and/or having their human rights violated. There are lots of folks working in a lot of varying fields where they could pass on an illness without knowing, are we going to start checking for TB as well (people can carry and never get sick with this one too)

 

I would consult a lawyer before deciding anything permanent and put employee in another area pending determination

 

 

Just wondering where to draw the line...…………...

 

Hi Scampi,

 

Remember typhoid Mary ?

 

I had a look at this before I posted -

 

Attached File  UK, fitness to work.pdf   196.4KB   21 downloads

 

 

PS - Yes, I also wondered about "Lines", eg -

 

Attached File  S.aureus in Flight-Catering,2000.pdf   175.02KB   19 downloads


Edited by Charles.C, 06 March 2019 - 10:58 PM.
expanded

Kind Regards,

 

Charles.C


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lydiashoniwa

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Posted 07 March 2019 - 07:04 AM

Hi everyone 

 

to answer some of your questions, we recently had a listeria outbreak in South Africa that affected over 1000 people and killed almost 300- so our regulations were amended to be more stringent on manufacturers such as ourselves, however,  these regulations, in general, do not indicate tests required or limits when it comes to medical fitness (there is no guidance really it just states that food handlers must be medically fit  ), so a lot of food manufacturers in SA are left to their own interpretation of what food handler medicals must comprise of, in all the years I've worked as a food safety professional every company I worked for had different tests done when it came to staff medicals, some were very simple (just basic blood pressure, vision, hearing & weight) whilst others took half a day just to complete (nasal swabs, stool samples etc) and I am yet to meet an auditor who was not satisfied with the tests done or could tell me exactly what medically fit means for a food handler- so when it comes to legal standing there isn't much support really cause all we get is food handlers shall be medically fit to handle food". 

 

We do consider our product as RTE, and our limit for staph on the final product that it should not be detected, we swab hands monthly and test for e.coli and staph aureus, GMP procedures are in place and are verified by the supervisors and QA team daily and I have to agree that yes, though staph is naturally found in humans, we have tested our entire staff complement and she was 1 of 4 who were positive for staph aureus, we counselled and issued the antibacterial ointment and everyone else came back negative on the retest except her (on all retests). The concern for human rights and employment fairness is a valid one and I completely agree that it seems very unfair to fire someone over something they really have no control over, but does the utilitarian theory not take precedence in this case- the greatest good for the greatest number of people- in other words should we risk the potential contamination of a ready to eat product that is consumed by a very large part of the population including the very young, the very old and the immunocompromised for one employee with a persistent and constant threat to not only our food safety management system but other employees as well? 



lydiashoniwa

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Posted 07 March 2019 - 07:14 AM

Scampi,

 

I agree , and as some stats show Staph can be a natural habitat on skin, nose and other body parts in 33% healthy population in the US ( i can only speak of USA), however, IMO she is not the only one who was targeted and tested for the nasal swab testing. Other employees would have been tested too. She is being getting positive results on repetitive testings.

 

She might be an healthy individual but she might be a carrier, and since this several tests are conducted/documented already, how can one justify of keeping her on handling the RTE product and ascertain that GMPs are followed without continuous supervision and monitoring (just my opinion).

 This is my thinking exactly- the risk is too high and the concentrated effort that would be required to try and keep it under control is too much i.e. stringent supervision, more frequent testing, more PPC etc. 



Charles.C

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Posted 07 March 2019 - 07:53 AM

Hi Lydia,

 

Thks for yr response.

 

IMEX, Management in such situations will often attempt to find alternative, appropriate, work locations. But admittedly such is often not so easy.

 

I wouldn't know if relevant but I did notice this quote -

 

According  to  Government  Regulation  962  of  2012,
promulgated  under  the  Foodstuffs,  Cosmetics  and
Disinfectants  Act,  No.  54  of  1972  of  Republic  of  South
Africa Sub regulation 11(ii) it stipulates that food or facility
shall  not  be  handled  by  any  ill  person  people  known,  or
suspected, to be suffering from, or to be a carrier of a disease
or illness likely to be transmitted through food, should not be
allowed  to  enter  any  food  handling  area  if  there  is  a
likelihood  of  their  contaminating  food.  Any  person  so
affected should immediately report illness or symptoms of
illness to the management.

 

 

Attached File  food handlers, 2017.pdf   337.92KB   16 downloads

 

It is a topic on which, internationally, opinions vary but may I ask whether yr food handlers routinely  wear hand coverings, eg gloves ?.


Kind Regards,

 

Charles.C


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lydiashoniwa

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Posted 07 March 2019 - 08:28 AM

Hi Lydia,

 

Thks for yr response.

 

IMEX, Management in such situations will often attempt to find alternative, appropriate, work locations. But admittedly such is often not so easy.

 

I wouldn't know if relevant but I did notice this quote -

 

 

attachicon.gif food handlers, 2017.pdf

 

It is a topic on which, internationally, opinions vary but may I ask whether yr food handlers routinely  wear hand coverings, eg gloves ?.

Hi Charles 

 

This regulation has since been repealed and replaced with Regulation 638 of 2018 and as such that subclause has been replaced with the following one: 

 
 
Food. a facility or a container may not be handled by a person -
(a) who has on his or her body a suppurating abscess or a sore, a cut or an
abrasion, including other infected skin lesions, unless covered with a
moisture proof dressing which is firmly secured to prevent contamination of
the food:
(b) (i) who has reported or who is suspected of suffering from or being a carrier
of a disease or condition in its contagious stage likely to be transmitted
through food. which includes jaundice, diarrhoea. vomiting, fever, sore throat
with fever and discharges from the ear, eye or nose:
(ii) a person referred to in subparagraph (i) may only resume handling food,
a facility or a container if the person submits a certificate by a medical
practitioner stating that the person is fit to handle food
 
Its a bit of a catch 22 because others on our team seem to think that this limits us to only symptomatic illness- so where a carrier does not show symptoms of illness including any of those listed in (b)(i) we would not know 
 
the second point may be worth digging deeper into- thank you. 


Scampi

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Posted 07 March 2019 - 01:59 PM

Item B may be there to protect workers from unlawful termination

 

I suggest again you contact a lawyer before considering termination

 

And it's a real shame about the listeria outbreak SA endured..............


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Charles.C

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Posted 07 March 2019 - 11:20 PM

Hi Lydia,

 

As per previous Post, any Legal requirements will usually take first priority.

 

In respect to risk assessment, medical microbiology not my expertise but I can supply a little more background from a cursory look on IT.

 

afai can deduce from yr information,  yr specific case is likely categorised as a persistent, asymptomatic, nasal carrier of S.aureus (presumably coagulase positive).

 

I assume hand swabs were negative for S.aureus ? If so, there does appear to be some literature  support for non-exclusion, eg -

 

Attached File  san1,Preventing Foodborne Disease A Focus on the Infected Food Handler, NDSC,Ireland,2004.PNG   25.57KB   0 downloads

Attached File  san2,Food Handler Exclusion Guidelines,Queensland,2017.PNG   10.77KB   0 downloads

Attached File  san3,WHO,Foodborne disease outbreaks Guidelines for investigation and control,2008.PNG   25.54KB   0 downloads

Attached File  san5 - UK,Food Handlers Fitness to Work,Regulatory Guidance and Best Practice Advice For FBOs,2009.PNG   39.57KB   0 downloads

 

Caveat 1 -  Only one ref.is recent.

Caveat 2 - Above opinions were typically mentioned as risk based  however evidential details not given (from a quick look).

Caveat 3 - Attached File  san4 - Infected food handlers Occupational aspects of Management,NHS,2008.PNG   9.42KB   0 downloads


Kind Regards,

 

Charles.C






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