Lockers and Food Defense

Hi All,

Our last inspection resulted in a minor NC for an employee having a warehouse utility knife in their locker and the locker wasn't locked. The auditor cited both food defense and control of foreign matter contamination. The auditor stated that because the locker was unlocked, then any employee could open the locker and put the knife into a batch of product.

We have since closed our CAR for this by controlling the knife like we do with our production knives. However, we want to make sure that the locker issue does not come up again for anything else found in lockers.

What is allowed in employee lockers? Our GMPs state no food or drink, but what about OTC medications like acetaminophen or aspirin? What about lotions and foot powders? If we do not lock our employee lockers, wouldn't any of these items be subject to a "food defense" issue where an employee could grab them and put them into a batch? My point is where do we draw the line? Do we truly need to provide a lock for all employees or can we simply inspect our lockers and state that employees are not allowed to have food, drink, or production/warehouse knives in their lockers?

Thank you for all of your help with this!

All of our clients require drugs, OTC's and any others to be held by management and dispensed as needed.  This is built into their GMP's.

All do inspections on locked lockers - they are not the property of the employees, they are the property of the company.

You can control what is in their lockers and you can inspect lockers - issue locks, but have a master pass key.