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BRCGS - Control of personal medicine

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Best Answer , 14 December 2023 - 12:03 PM

I would like to thank you all for your thoughts and ideas, experience. I think we found best solution in this case, now it is just to see how it will work in practise. 


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INL

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Posted 09 November 2023 - 01:08 PM

Good day,

 

How do you manage and oversee the usage and storage of personal medications within your facilities? Specifically, could you clarify what types of medications are typically documented in a logbook? Moreover, who holds the responsibility for maintaining this record? Additionally, I'd like to understand if the requirement to log personal medicines applies to all individuals working within the facility, or is it limited to those involved in the production process?

 



MDaleDDF

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Posted 09 November 2023 - 01:10 PM

Never heard of this, but if my boss asked for a list of my personal medications, I'd tell him to sod off.   It's nobody's business.  We have other safeguards in place to stop any medications in the building from entering product.

But I would not ask my employees for a list of their personal medications.  To me this is stepping way outside your lane.  I'd question the legalities of it quite honestly.



INL

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Posted 09 November 2023 - 01:17 PM

Never heard of this, but if my boss asked for a list of my personal medications, I'd tell him to sod off.   It's nobody's business.  We have other safeguards in place to stop any medications in the building from entering product.

But I would not ask my employees for a list of their personal medications.  To me this is stepping way outside your lane.  I'd question the legalities of it quite honestly.

I understand and agree with your point. In situations where a production line worker requires essential medication beyond pain relief, there should be a system to reduce the risk of product contamination. I'd like to know how facilities ensure control in these circumstances. 
 



kfromNE

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Posted 09 November 2023 - 01:30 PM

I understand and agree with your point. In situations where a production line worker requires essential medication beyond pain relief, there should be a system to reduce the risk of product contamination. I'd like to know how facilities ensure control in these circumstances. 
 

 

Are you referring to pain patches? 



INL

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Posted 09 November 2023 - 01:45 PM

Are you referring to pain patches? 

No, I mean medications in the form of pills or creams (for example, antibiotics). Pain patches should be metal detectable and documented in a logbook.



MDaleDDF

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Posted 09 November 2023 - 03:10 PM

Pain patches are not metal detectable.   If I'm on antibiotics, it's nobody's business.

Control it with GMPs, nothing allowed in pockets in production, etc.

 

I'm not sure how it works in Norway, but here I would never ask someone what medications they're on, I don't think it's legal as an employer to demand to know, and I have a pretty good idea what response I'd get if I asked my guys and gals to let me know when they were on medications.

 

Sorry, I disagree with your entire premise.   There's plenty of ways to control this without delving into your employees' personal medical information.


Edited by MDaleDDF, 09 November 2023 - 03:12 PM.


Scampi

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Posted 09 November 2023 - 03:21 PM

This is simple

 

Usage refers to not having medications of any kind on the production floor----------that goes into your GMP training and procedure

 

Storage-again, nothing on the floor in pockets-----GMPs

 

Done-------do not over complicate this


Please stop referring to me as Sir/sirs


SQFconsultant

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Posted 09 November 2023 - 03:43 PM

Our facility is a drug (includes prescriptions and any otc) free facility. If an employee needs to take certain items during working hours the items are held in a locked cabinet and dispensed per room by our on site medical personnel that have first reviewed the item or items for acceptable use while working.  Marco drugs are only allowed by prescription and for office type workers, in other words they are kept away from operating equipment, etc. We do allow cbd and nice patches along with a selection of supplements such as nattokinase to help people reverse the effects of the covin bio weapon shots and also provide these folks with free EES sessions to help in repair their DNA. 


All the Best,

 

All Rights Reserved,

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Glenn Oster.

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SQFconsultant

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Posted 09 November 2023 - 03:45 PM

Sorry for the malfunctioning spellchecker


All the Best,

 

All Rights Reserved,

Without Prejudice,

Glenn Oster.

Glenn Oster Consulting, LLC -

SQF System Development | Internal Auditor Training | eConsultant

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http://www.GCEMVI.XYZ

http://www.GlennOster.com

 


Setanta

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Posted 09 November 2023 - 03:56 PM

Our employees should not have anything for personal use out on the production floor. If they have a need of an OTC medication, they have to go to their locker to take it. We don't have monitor for individual drug usage.
We use behavioral observations if there may be an issue. If they tell us they have a prescription that they should not be operating machinery while on this prescription, we get the doctor to determine whether or not they can be at work. This is in the US and anything more would be a HUGE overreach of privacy regulations.


Edited by Setanta, 09 November 2023 - 03:57 PM.

-Setanta         

 

 

 


jfrey123

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Posted 09 November 2023 - 09:43 PM

I'm with everyone else on not permitting any personal medications on the floor.  Just like any other personal effect, it should be prohibited to address all food safety concerns.

 

I wouldn't dream of logging medications anywhere due to medical privacy concerns.  You can inform employees they're prohibited from operating equipment if they're on some type of narcotic rx medication, but I don't see how you can require them to tell you they're taking it outside of a failed drug test where they reveal the rx from a doctor to justify the use.



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Posted 10 November 2023 - 05:36 AM

Good day,

 

How do you manage and oversee the usage and storage of personal medications within your facilities? Specifically, could you clarify what types of medications are typically documented in a logbook? Moreover, who holds the responsibility for maintaining this record? Additionally, I'd like to understand if the requirement to log personal medicines applies to all individuals working within the facility, or is it limited to those involved in the production process?

 

 

Hi INL,

 

:welcome:

 

Welcome to the IFSQN forums

 

I think Scampi has hit the nail on the head with this one, your procedures need to ensure that personal medicines are not taken into product areas unless absolutely necessary. This is normally achieved by requiring personal medicines to be secured in personal lockers.

 

Any exceptions should be on an individual basis, BRCGS Guidance does mention asthma and diabetes where an employee may need to keep medicine close at hand. We used to manage that by not allowing medicines in product areas but allowing medical alert bracelets* and ensuring that supervisory staff were aware of such medical conditions to ensure they were prepared in an emergency situation.

 

BRCGS Global Standard Food Safety Issue 9 Guidance for the control of Personal medicines:

Wherever possible, medicines should not be taken into production areas (e.g. they could be stored in lockers along with other personal items). However, where staff have a medical need to keep personal medicines with them (e.g. they have asthma or diabetes), procedures must be in place to control these medicines (such as a requirement to notify the company of the defined medical need). Consideration should be given to the format and packaging of the medicines (e.g. glass bottles) to minimise the potential risk of product contamination.

 

* Section 7.2 Personal hygiene, clause 7.2.1 does in fact mention medical alert jewellery:

The requirements for personal hygiene shall be documented and communicated to all personnel. These shall include, at a minimum, the following:

• watches and similar wearable devices shall not be worn

• jewellery shall not be worn, with the exception of a single, plain wedding ring, wedding

wristband or medical alert jewellery

…etc.

 

Kind regards,

 

Tony



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INL

INL

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Posted 10 November 2023 - 07:34 AM

Hi INL,

 

:welcome:

 

Welcome to the IFSQN forums

 

I think Scampi has hit the nail on the head with this one, your procedures need to ensure that personal medicines are not taken into product areas unless absolutely necessary. This is normally achieved by requiring personal medicines to be secured in personal lockers.

 

Any exceptions should be on an individual basis, BRCGS Guidance does mention asthma and diabetes where an employee may need to keep medicine close at hand. We used to manage that by not allowing medicines in product areas but allowing medical alert bracelets* and ensuring that supervisory staff were aware of such medical conditions to ensure they were prepared in an emergency situation.

 

BRCGS Global Standard Food Safety Issue 9 Guidance for the control of Personal medicines:

Wherever possible, medicines should not be taken into production areas (e.g. they could be stored in lockers along with other personal items). However, where staff have a medical need to keep personal medicines with them (e.g. they have asthma or diabetes), procedures must be in place to control these medicines (such as a requirement to notify the company of the defined medical need). Consideration should be given to the format and packaging of the medicines (e.g. glass bottles) to minimise the potential risk of product contamination.

 

* Section 7.2 Personal hygiene, clause 7.2.1 does in fact mention medical alert jewellery:

The requirements for personal hygiene shall be documented and communicated to all personnel. These shall include, at a minimum, the following:

• watches and similar wearable devices shall not be worn

• jewellery shall not be worn, with the exception of a single, plain wedding ring, wedding

wristband or medical alert jewellery

…etc.

 

Kind regards,

 

Tony

 

Yes, I agree with the points raised by everyone. Our established procedure has always been clear that employees are not allowed to bring medicine into the production area. Importantly, we've never required employees to disclose their medication use, considering it as private information that deserves respect.
 
From the insights shared by everyone and considering our current practices at the facility, it seems we are aligned with the right approach. So I want to ask how to interpret this. How do you control the use and storage?  

In Norway, there is a law stating that it may be necessary for an employee to inform the employer if they are using medications that could affect their ability to perform specific job tasks, such as operating a truck, forklift trucks . This is particularly crucial if the medications have side effects that could impact reaction time, concentration, or coordination, posing a risk to workplace safety. However, in such cases, the privacy of the employee must also be respected, and the information is handled confidentially. 
 
I appreciate the engagement in this discussion. It's crucial for us to ensure there's no risk of contamination due to medication use, while also being mindful of respecting the personal information of our employees. Thank you for your contributions.

Standard says:
7.2.5. Processes and written instructions for staff shall be in place to control the use and storage of personal medicines, so as to minimise the risk of product contamination.
Personal medicines
Personal medicines need to be controlled to ensure they do not constitute a risk to product.
The site must have a documented procedure on the control and storage of medicines.
Wherever possible, medicines should not be taken into production areas (e.g. they could be
stored in lockers along with other personal items). However, where staff have a medical need
to keep personal medicines with them (e.g. they have asthma or diabetes), procedures must
be in place to control these medicines (such as a requirement to notify the company of the
defined medical need). Consideration should be given to the format and packaging of the
medicines (e.g. glass bottles) to minimise the potential risk of product contamination.

Edited by INL, 10 November 2023 - 07:35 AM.


Swiftee

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Posted 13 November 2023 - 02:21 PM

At my packhouse we have a locked draw marked personal medicines in the production office, people who have diabetes/epipens or some medicine they need immediately are kept here. Things like paracetamol or not a medical emergency are kept in their personal lockers away from production. Any visitors entering site who have to have medication on them is declared on site entry and if required it is completed on our handback forms for engineers etc.

 

Taken from our procedure:

 

Due to the possibility of product being contaminated by harmful substances, personal Medicines are not allowed in the field whilst picking or in the production area (unless there is an important medical reason why this should be allowed. In this case the medication will be strictly controlled as detailed below)

 

Non-urgent medication must be left in lockers provided or in the office refrigerator if this is necessary.

 

Personal Medication that may be deemed to be needed more urgently may be left with the field supervisor or with a supervisor in the production office.

 

There should be a dedicated place for the storage of such medicines so that in an emergency the medicine location is clear.

 

If it is essential for medical reasons that medication must remain with the person, this must be agreed with a senior manager beforehand.

 

Any person entering the production or picking area with medication of any kind must declare this on their arrival. The fact that they have medication with them must be noted on the hand back form. All medication must be accounted for at the end of the day and signed out.



G M

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Posted 13 November 2023 - 08:44 PM

This is simple

 

Usage refers to not having medications of any kind on the production floor----------that goes into your GMP training and procedure

 

Storage-again, nothing on the floor in pockets-----GMPs

 

Done-------do not over complicate this

 

+1

 

Consumables are to be kept in the break room.  I don't care if its a peanut butter sandwich, antibiotics, chewing tobacco etc.  Keep it in the break room.  That's on the list of GMPs every one reviews every year.



SHQuality

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Posted 17 November 2023 - 08:34 AM

I understand and agree with your point. In situations where a production line worker requires essential medication beyond pain relief, there should be a system to reduce the risk of product contamination. I'd like to know how facilities ensure control in these circumstances. 
 

Simple. You cannot consume food or medication on the factory floor. You don't need a list of employee medications, you need a procedure that keeps that medication stored in the employee's personal locker. It would be a privacy violation to request personal medical information anyway.


Edited by SHQuality, 17 November 2023 - 08:34 AM.


Hoosiersmoker

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Posted 01 December 2023 - 07:14 PM

Don't forget to include those that have to have a medication on their person at all times. Our system allows for a sealed container to keep only the amount necessary to be in their pocket. This is allowed with a doctor's note submitted to HR. Otherwise no medications of any kind are allowed in production areas. Trained on day one and reviewed annually.



INL

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Posted 14 December 2023 - 12:03 PM   Best Answer

I would like to thank you all for your thoughts and ideas, experience. I think we found best solution in this case, now it is just to see how it will work in practise. 





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