SQF 11.3.1.1 Infectious Diseases and Medical Screening Amendment

Hello,

We recently had an Internal Audit and it was pointed out that we do not cover infectious diseases and medical screening (SQF amendment 10-2021) in our Personnel Hygiene and Welfare Policy- element 11.3.1.1.  Does anyone have an example of how they wrote this into their policy that meets the SQF requirements?  Any information that is shared would be greatly appreciated.  Thank you all very much!

Brenda

Following, thank you!

Add it to your initial and annual GMP training for employees and visitor GMP training.  Make sure it's written into your GMP training documents and reference those documents in your Personnel Hygiene and Welfare Policy.  Below is an excerpt from my GMP document:

 

Employee Health:

• Employees with boils, open sores and infected wounds or any other sources of bacterial contamination shall be prohibited from working in any production area without prior management approval.  If approval is received, appropriate wound coverings (gloves, Band-Aids, etc.) must be worn.
• In the instance that Band-Aids need to be worn, production employees must wear Curad Woven Blue Detectable Bandages and put gloves on over bandages on their hands.
• All employees need to be in good health when working in the production, storage, and lab areas; they are required to notify management of any illnesses (diarrhea, fever, vomiting, etc.).
• Any individual who is infected with a communicable disease, who has been exposed to a communicable disease, or who is a carrier of a communicable disease shall be prohibited from working and entering the facility.  In such situations, management shall be notified and a sick day granted.

Spidey - For the communicable disease, I'm reading it as specifically food borne illness, are you? Although of course you can reference any contagious disease you plan on enforcing beyond that.  This seems like the way most plants I've been in already interpret this part of the code, what do you see as actually new? 

Also, in teh case of foodborne illness, is SQF looking for a clearance to come back to work, i.e. doctor's note? I can think of an example where I had a lab employee out for a month because she had E coli, and could not return until she tested negative. Thanks!

We pretty much do the same as Spidey suggested.  Also, SQFi recorded a webinar on the Edition 9 Amendments they added this year.  You might check it out as one of the break out sessions specifically covered this amendment.  You should be able to copy and past this into your web search to view the recording. 

Spidey - For the communicable disease, I'm reading it as specifically food borne illness, are you? Although of course you can reference any contagious disease you plan on enforcing beyond that.  This seems like the way most plants I've been in already interpret this part of the code, what do you see as actually new? 

 

Also, in the case of foodborne illness, is SQF looking for a clearance to come back to work, i.e. doctor's note? I can think of an example where I had a lab employee out for a month because she had E coli, and could not return until she tested negative. Thanks!

Foodborne illness is specifically what SQF meant in their new amendment, but they mentioned the sites can include other types of illness as well.  This is the procedure my company had in place prior to that amendment addition and we prefer the larger umbrella of communicable diseases that includes foodborne illness and others.  The SQF guidance document mentions that this was always implied, but never specifically written down.  I think the biggest change for sites is that SQF will now be looking for written documentation of this and quizzing employees over this.

As far as returning to work, the SQF guidance document did not provide any guidance.  I think that's something your site will have to determine.  Though it's always important to remember, if you didn't document it, it didn't happen.

Our company is currently doing temperature checks at the door and requiring employees and visitors to fill out symptom questionnaires. I would very much like to get away from this but have been confused about this amendment. Mainly the term "screening" which seems to be throwing everyone off.  

I currently have in our GMPs something similar to what Spidey has volunteered. That it is the employees responsibility to notify management if they knowingly are infected with any foodborne illness or are experiencing symptoms. How to manage open sores, and exposed cuts, etc.  I also have written a procedure incase symptoms begin occurring on the production floor during a shift and not just before an employee comes into work. To accompany this, I have added an illness report which will document the procedures taken incase this occurs. Training will take place yearly and refresher training as needed with accompanying documents. 

GMP Visitor agreement includes the above information and I am thinking about adding a statement on the daily visitor log in for visitors to confirm that they are presently not known carriers of any foodborne illness and are not experiencing symptoms.

Do you think this is acceptable and enough to do away with the pesky temperature checks because they are annoying everyone. Thank you :)

For those who operate in the United States:  In addition to what has already been said above, Annex 7 of the US Food Code: 2017 has three model forms that address this issue, that the SQF Edition 9 guidance documents reference, and that could certainly be tailored to individual facility needs.

The guidance document also states, "The requirement is specific to pathogens transmitted by food."

Of course, we all know that guidance documents aren't official, you're only supposed to be held to the actual wording of the code, but still... it is something at least.
 

Add it to your initial and annual GMP training for employees and visitor GMP training.  Make sure it's written into your GMP training documents and reference those documents in your Personnel Hygiene and Welfare Policy.  Below is an excerpt from my GMP document:

 Hi Spidey, so shoud this code designed to the policy or SOP? 

 Hi Spidey, so shoud this code designed to the policy or SOP? 

Hi Eric,

It's a 1-year old Post. There may be a delay.