23 replies to this topic

[AJL]

Hi, 

Customer says I need a Hep A policy. 

What is that even? Anyone here have one?

Apparently I am supposed to make sure everyone in my supply chain washes their hands. 

Thanks in advance. 

[Gelato Quality Lead]

We don't have a specific Hep A policy, but we do include this in our employee health management program, GMPs, and supply chain program.

 

For supply chain, we either request a third party audit (we know that this would be covered in that audit) or for smaller suppliers that have not gone through a third party audit, we ask to review their GMPs, supply a letter of continuing guarantee, etc.

 

Hope this helps at least a little

[AJL]

Thanks Gelato quality lead, yeah it's a new thing that got thrown on to a standard somewhere. .. that we need a stand alone policy
😏

[Scampi]

What you should have is a policy requiring employees to notify the company if they become ill or have a disease easily transmissible in food (like hep A) and that any employee who is carrying/suffering from said diseases shall be reassigned to other non food duties until the disease is no longer present

[kfromNE]

Hi, 

Customer says I need a Hep A policy. 

What is that even? Anyone here have one?

Apparently I am supposed to make sure everyone in my supply chain washes their hands. 

Thanks in advance. 

 

This is a specific requirement in the USA for restaurants where the risk is greater than in a food production facility. Like the posts above say - add it to your GMP/employee sick policy. 

[olenazh]

This is a specific requirement in the USA for restaurants where the risk is greater than in a food production facility. Like the posts above say - add it to your GMP/employee sick policy. 

Agree: I've never heard or read of such a requirement for food industry.

[Scampi]

Agree: I've never heard or read of such a requirement for food industry.

 

 

Olenzah, CFIA does not call out HEP A specifically, but there is a requirement for food borne illness

 

Communicable disease
(Maladie transmissible)

The term "communicable disease" is not specifically defined in the Safe Food for Canadians Act nor in the Safe Food for Canadians Regulations (SFCR). In general terms, "communicable disease" when used in Part 4 – Preventive Controls of the SFCR, refers to a disease that can be transmitted through direct contact with an individual or indirect contact through food. Examples of communicable diseases that can be transmitted through food include salmonellosis, campylobacteriosis, and hepatitis A.

[olenazh]

Olenzah, CFIA does not call out HEP A specifically, but there is a requirement for food borne illness

 

Communicable disease
(Maladie transmissible)

The term "communicable disease" is not specifically defined in the Safe Food for Canadians Act nor in the Safe Food for Canadians Regulations (SFCR). In general terms, "communicable disease" when used in Part 4 – Preventive Controls of the SFCR, refers to a disease that can be transmitted through direct contact with an individual or indirect contact through food. Examples of communicable diseases that can be transmitted through food include salmonellosis, campylobacteriosis, and hepatitis A.

There are controversial theories about survival of viruses on food as they need live cells to thrive on. However, you're right in terms of having strong GMP/hygiene practices because the viruses could be transmitted through direct human-human contact.

[Scampi]

There are controversial theories about survival of viruses on food as they need live cells to thrive on. However, you're right in terms of having strong GMP/hygiene practices because the viruses could be transmitted through direct human-human contact.

 

There have been many many recalls on food that are traced directly back to an ill employee-specifically Hep A and RTE products---this is NOT a theory, but genome facts hence the requirement  

 

This isn't a discussion about food carrying viruses, this is specifically for diseases carried by employees, transferred to foods where in turn the consumer gets sick

[AJL]

Hep À can survive on frozen foods and cause outbreaks.
So it is relevant. But a stand alone procedure?

[G M]

Hep À can survive on frozen foods and cause outbreaks.
So it is relevant. But a stand alone procedure?

 

Presumably you already have a policy telling people not to come to work if they're sick, just add a line or subsection to notify HR or the appropriate manager of  infection with disease communicable through food "such as" Hep A

 

I would expect that to satisfy what the customer is probably looking for.

[ShaunD]

Sainsbury's mention this in their new Food Safety manual:

 

See attachement (I cant seem to add screen capture).

Attached Files

•  Capture.JPG   82.24KB   0 downloads

Edited by ShaunD, 01 November 2023 - 08:45 AM.

[AJL]

Hi Shaun, I tried to PM bit it didn't work 🙈
Yes it is for said customer. But don't really know what ro expect, hoping some one could share theirs so I can see if the one I wrote was up to par

[AJL]

Hi Shaun, I tried to PM bit it didn't work 🙈
Yes it is for said customer. But don't really know what ro expect, hoping some one could share theirs so I can see if the one I wrote was up to par

[jfrey123]

Our GMP policy lists a handful of communicable diseases we require employees to inform us if they have or contract.  Hep A is one of them.  This satisfies SQF and our customer audits.

[AJL]

Yes but see what Shaun D has shared, they are asking for a stand alone policy

[Gelato Quality Lead]

Hi AJL,

 

It seems like this customer requirement is not very common (the standalone policy for Hep A). If you have any of the other policies/programs that we have mentioned in previous comments, I'm sure you can pull out what is relevant to Hep A and model your Hep A policy around what your other health/GMP policy includes. Most likely there will be a lot of crossover (hand washing, hand washing signs, employee health management training). For supply chain, you could probably just specify in your supplier approval program to ask for what their policies are for Hep A. 

 

The requirements that ShaunD posted are pretty specific in what they are asking for, so you can just add those to the Hep A policy framework. Not sure if this answers your question but this is how I would go about satisfying this requirement as you are likely already mitigating other communicable diseases.

Edited by Gelato Quality Lead, 01 November 2023 - 06:13 PM.

[Abby7]

Hello:

 

Firstly, I will start by stating what a customer of ours requires, is likely outside the privacy laws in most jurisdictions. 

But we were requested to ask our employees - handling frozen fruit - (so, high risk) if they are vaccinated or ever been ill with Hep A. 

I included this in our "Communicable Disease" Policy and annual training module and added a 'don't know" option to both questions to give our employees an option if they don't want to answer.

 

Just a thought that perhaps this may need to be included in a 'stand alone' policy.

 

Again, I have been grateful, that to date, no employee has pushed back on this invasion of their privacy.

 

Abby 7

[ShaunD]

Hi AJL,

 

Unfortunately, as we don't handle or use fresh or frozen produce, there is no requirement for us to have a Hep A policy so was able to ingore this clause.

I do have Hep A listed in our Pathogenic Microrganisms Profile, within our HACCP, but as it is not generally associated with our products, no controls are required.

 

Sorry I can't be of more help.

[jfrey123]

Hello:

 

Again, I have been grateful, that to date, no employee has pushed back on this invasion of their privacy.

 

Abby 7

 

I used to be very concerned about this when I started in food over a decade ago.  I can't speak for Canada, but the US has granted themselves authority in this issue for the communicable diseases that can affect food safety, which is why our GMP programs at various companies I've worked for require employees to notify us of the very specific communicable diseases that can transfer to food.  Hep A is one of them.  US FDA tied a single strain of Hep A to a single farm in Baja Mexico in both 2022 and 2023.  We are required by law (and in my case SQF code) to keep employees with a communicable disease away from food, food-contact surfaces and food packaging.

[Scampi]

Hello:

 

Firstly, I will start by stating what a customer of ours requires, is likely outside the privacy laws in most jurisdictions. 

But we were requested to ask our employees - handling frozen fruit - (so, high risk) if they are vaccinated or ever been ill with Hep A. 

I included this in our "Communicable Disease" Policy and annual training module and added a 'don't know" option to both questions to give our employees an option if they don't want to answer.

 

Just a thought that perhaps this may need to be included in a 'stand alone' policy.

 

Again, I have been grateful, that to date, no employee has pushed back on this invasion of their privacy.

 

Abby 7

Abby---not an invasion on privacy ---it's terms of employment

 

They do not have to disclose to you OR the supervisor---they may go to HR directly

[Abby7]

Hello:

 

Thanks Scampi and Jfrey 23 for your responses.

For many years the obligation to report communicable disease related symptoms has been part of Communicable Disease Policy & training modules I have presented. It is the vaccination requirement that I believed falls outside of Canadian regulatory limits.  Thanks for clarifying.

[AJL]

Thanks everyone. Interesting topic and I appreciate the input & discussion

[AJL]

Sainsbury's mention this in their new Food Safety manual:

See attachement (I cant seem to add screen capture).

Hi, I tried to send you a message but I couldn't get it to work 🙄
Any idea why?

Edited by AJL, 04 November 2023 - 03:50 PM.