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New SQF Code Amendment - 13.3.1.1 Edition 9 - Manufacture of Food Packaging

manufacture of food packaging edition 9 code amendment medical screening procedure

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karlieh

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Posted 10 January 2022 - 02:57 PM

The new amendment in section 13.3.1.1 states that "a medical screening procedure shall be in place for all employees, visitors and contractors who handle exposed product or food contact surfaces".

 

From a Canadian perspective, how do I go about writing a medical screening procedure, when we are not legally allowed to ask anyone if they have any infectious diseases that present a health risk to others? Is there is certain or specific way to word the procedure?

 

We received a non-conformance on this during our audit, and management doesn't know how to go about writing a medical procedure about this.

 

Would a risk assessment be sufficient enough to replace the procedure, since our facility is very low risk?



Scampi

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Posted 10 January 2022 - 03:55 PM

you could try, but a R/A is probably not sufficient

 

you don't need to write a medical screening procedure, just add it to your employee training

 

You can have passive screening  e.g. train your employers that they must report food borne illness to the company(HR), and that alternative work will be found for them, and then log any that do occur (which should be incredibly rare)

 

That should keep you covered


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olenazh

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Posted 10 January 2022 - 04:07 PM

Why aren't you legally allowed to ask questions RE: your employees' health condition potentially dangerous to food? Never heard of that here, in Canada. Can you please refer to the regulatory document stating that?



Scampi

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Posted 10 January 2022 - 07:30 PM

Olenzah, in Ontario, it is very delicate

 

https://www.ohrc.on....ive-information


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olenazh

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Posted 10 January 2022 - 07:37 PM

Olenzah, in Ontario, it is very delicate

 

https://www.ohrc.on....ive-information

Hey, Scampi: I don't see any mention of health info related to food in "information about health or age necessary for pension, disability, superannuation, life insurance and benefit plans [may reveal disability, age, sex (pregnancy) or gender identity]" Though, thanks a lot for this reference, I wasn't aware of that.



MDaleDDF

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Posted 10 January 2022 - 07:37 PM

Olenzah, in Ontario, it is very delicate

 

https://www.ohrc.on....ive-information

All the worries in this link seem pre-employment, no?  "Due to the sensitive nature of this information, only request it after making an offer (preferably in writing) of employment"  We're not talking about asking during the hiring process...



Scampi

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Posted 10 January 2022 - 08:04 PM

That's exactly the point, IF a company wants to ask (in Ontario)-legally they cannot ask once you've been hired

 

 

And since the SQF element in question is using the wording screening, incorrectly  what they mean can be passive  e.g. a policy that says employees must report if they test positive

 

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