Employee medical fitness- recurring positive results
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?
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.
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.
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?
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).
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...…………...
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 -
UK, fitness to work.pdf 196.4KB 24 downloads
PS - Yes, I also wondered about "Lines", eg -
S.aureus in Flight-Catering,2000.pdf 175.02KB 21 downloads
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?
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.
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.
food handlers, 2017.pdf 337.92KB 22 downloads
It is a topic on which, internationally, opinions vary but may I ask whether yr food handlers routinely wear hand coverings, eg gloves ?.
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 -
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:
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..............
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 -
san1,Preventing Foodborne Disease A Focus on the Infected Food Handler, NDSC,Ireland,2004.PNG 25.57KB 0 downloads
san2,Food Handler Exclusion Guidelines,Queensland,2017.PNG 10.77KB 0 downloads
san3,WHO,Foodborne disease outbreaks Guidelines for investigation and control,2008.PNG 25.54KB 0 downloads
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 - san4 - Infected food handlers Occupational aspects of Management,NHS,2008.PNG 9.42KB 0 downloads