33 replies to this topic

[GMO]

I have a feeling it's somewhat a cultural thing, GMO. Here stateside, the sentiment is 'your (as the GFSI scheme auditor) job is to keep me on track to make safe food that enters commerce. I feel the auditor/scheme has no place trying to control anything other than that. The fridge in my break room has no impact on me producing safe food. If it breaks down, we replace it. We aren't allocating resources to monitor it.

 

This might be why you hardly ever see BRC GFSI schemes here stateside; 'rules' like that just wouldn't be a good fit culturally. 

 

Wow, that's so odd.  I'm not advocating for it though as a "here's a rule, follow it" perspective, more that "here's the potential to cause consumer harm, albeit indirectly".  There are lots of times I've been anecdotally told that infected food handlers continuing to work in the US is a significant problem.  So perhaps it is worth considering?

 

Anyway, you raise an interesting point.  I was recently in a site which had ditched BRCGS.  Nothing to do with being US, it's British but the reasoning for ditching it was "it's too prescriptive."  To be honest, being in sites where there is an immature food safety culture, I find a prescriptive standard pretty helpful.  It did nothing for the sites food safety and quality standards I can tell you.

 

But in any case, BRCGS does give you freedom to comply or to sensibly risk assess why compliance isn't required.  

 

Wow though.  Just wow.  Really?  Is there the same attitude to health and safety laws?  A "you can't tell me" kind of approach?

[chrisrushworth]

Wow, that's so odd.  I'm not advocating for it though as a "here's a rule, follow it" perspective, more that "here's the potential to cause consumer harm, albeit indirectly".  There are lots of times I've been anecdotally told that infected food handlers continuing to work in the US is a significant problem.  So perhaps it is worth considering?

 

Anyway, you raise an interesting point.  I was recently in a site which had ditched BRCGS.  Nothing to do with being US, it's British but the reasoning for ditching it was "it's too prescriptive."  To be honest, being in sites where there is an immature food safety culture, I find a prescriptive standard pretty helpful.  It did nothing for the sites food safety and quality standards I can tell you.

 

But in any case, BRCGS does give you freedom to comply or to sensibly risk assess why compliance isn't required.  

 

Wow though.  Just wow.  Really?  Is there the same attitude to health and safety laws?  A "you can't tell me" kind of approach?

 

 

Its shocking reading back some people responses... & how they feel....

 

BRCGS is striving for us to make the best safest food possible, its hard enough getting MD's and Senior managers on the same technical page...

 

Shocking that so many "technical managers" think its a waste of time...

 

Glad i live in the UK!

[GMO]

Ok, I'm going to keep going on this as I'm baffled that people are pushing back against it, much as Chris is.

 

Yes, you have no control over where and how the food staff bring to site was prepared.  However, you did presumably buy the fridge they are using.

 

We know that as the temperature of that fridge goes up, the risk of bacterial growth increases.

 

No food is sterile so pathogenic bacteria may be present in your staff's food even if it was prepared well.

 

If your staff become infected due to eating food with elevated counts of pathogens, what is your sickness policy?  Do you pay if someone is absent?  Is there a risk someone could work if infected or be asymptomatic?  Is it ethical that the person was made ill due to your lack of maintenance and monitoring of your site fridge?  Is that any less of an ethical concern than making a consumer ill due to poor temperature monitoring of your despatch area?

 

As a food handling site, I'm sure you'd expect toilets to be cleaned and well maintained.  But by the same argument being put forward here, is that not out of scope?  After all your food handlers change and wash hands before handling food so what's the problem!

 

Ok, last point.  What is this telling your staff about your management culture if their fridge doesn't matter?  Why would the fridges in the plant matter to them if their fridge doesn't matter to you?  If their health doesn't matter to you?  What will that do to your food safety culture?  

[AltonBrownFanClub]

I love a community discussion with different opinions.

I'll admit I was skeptical about the impact of break room fridge monitoring, but I've come around.

 

The point GMO made about toilet facilities got me.

Businesses should ensure facilities are in good repair- not just food manufacturing areas.

Of course employee health is vital and should be promoted.

 

BRC- "Do you provide safe food storage for employees?"

Us- "Yes"

BRC- "Ok, prove it"

 

I'll add a wifi datalogger to our refrigerators and monitor daily.

It's the least we can do when we ask so much of employees already.

(No nail polish, no jewelry, clean uniform, shoe covers, hairnets, etc...)

Why wouldn't we want their food to be as safe as possible too?

 

[AltonBrownFanClub]

My computer lagged. Sorry for the double post. 

Edited by AltonBrownFanClub, 29 January 2025 - 05:21 PM.

[jfrey123]

If your staff become infected due to eating food with elevated counts of pathogens, what is your sickness policy?  Do you pay if someone is absent?  Is there a risk someone could work if infected or be asymptomatic?  Is it ethical that the person was made ill due to your lack of maintenance and monitoring of your site fridge?  Is that any less of an ethical concern than making a consumer ill due to poor temperature monitoring of your despatch area?

 

As a food handling site, I'm sure you'd expect toilets to be cleaned and well maintained.  But by the same argument being put forward here, is that not out of scope?  After all your food handlers change and wash hands before handling food so what's the problem!

 

Ok, last point.  What is this telling your staff about your management culture if their fridge doesn't matter?  Why would the fridges in the plant matter to them if their fridge doesn't matter to you?  If their health doesn't matter to you?  What will that do to your food safety culture?  

 

I'm going to lean into the 'Dumb American' stereotype for replying to this (all in the spirit of friendly online debate).  I'm with TimG, it feels to me a cultural thing for Americans vs the UK, especially with the tone of your questions above.  But let me add a couple of friendly counterpoints:

 

On sickness policy, why shouldn't every business that offers a refrigerator be required to monitor it to this level?  Why just us in the food industry?  The same hazard you list for employee illness exists in office buildings as much as it exists in a food manufacturing plant.  And what about the outdoor construction workers who manage to keep lunch safe working in the summer heat?  If they can bring lunch in a chilled lunchbox, then my employees can too.  GFSI requiring us to have a refrigerator is, IMO, to eliminate the odds that employees decide to use the company's cold storage to keep their lunch, nothing more.

 

For toilets, yes they should be clean.  But what level of monitoring would you say is sufficient?  Should I ATP my toilet seats?  I think you'd agree that's preposterous, but GFSI requirements call for clean restroom facilities and allow us to list them on a master sanitation schedule with visual inspections to comply.  In comparison to refrigeration monitoring, I'd equate it to sticking my hand in there once a week and seeing if it's cold.  

 

From a culture standpoint, it can go both ways:  we implement a monitoring program, and now it's a fresh requirement for them to uphold.  They screw up and forget to monitor the refrigerator in the breakroom, and now I have to issue disciplinary writeups.  The poor QA tech who is already dealing with issues on the floor has yet another checklist to run, and of course that has to be reviewed and signed off by someone else.  

 

I'll close with a time a customer auditor argued with me that we should be monitoring the actual temp of the refrigerator per SQF.  He couldn't find anything wrong with our site in general and decided to harp on this for half an hour, "I just can't believe you're not, SQF says you must!"  So I dove into the code and guidance I could find, and it is not expressly stated or even implied in SQF.  When he wouldn't let it drop, even wrote it into his report demanding a CAPA, we replied that we disagreed, that 3 SQF auditors found no fault in that clause, and would consider their note for future improvements.

[GMO]

On sickness policy, why shouldn't every business that offers a refrigerator be required to monitor it to this level?  Why just us in the food industry?  The same hazard you list for employee illness exists in office buildings as much as it exists in a food manufacturing plant.  And what about the outdoor construction workers who manage to keep lunch safe working in the summer heat?  If they can bring lunch in a chilled lunchbox, then my employees can too.  GFSI requiring us to have a refrigerator is, IMO, to eliminate the odds that employees decide to use the company's cold storage to keep their lunch, nothing more.

 

For toilets, yes they should be clean.  But what level of monitoring would you say is sufficient?  Should I ATP my toilet seats?  

 

I suppose from a construction site point of view, I'd argue that's good practice but if you think about risk, it's not going to make the building unsafe if you make the builder ill.  It could make the food product unsafe if you make your food handler ill.  That's why I think it's different.  Do you not see that point?

 

No I don't agree with ATP swabs in any case.  Most of the time they're a waste of money.  But what I do have is records of cleaning and inspection of my toilets daily.  So I do have the equivalent for the toilets if you think about it? 

(I've posted on other threads about how much visual inspection is unappreciated for even plant cleaning so I definitely have that view in toilets.  People are OBSESSED with needing a tool to tell them something is clean when to be honest, most of it is common sense.)

[jfrey123]

I suppose from a construction site point of view, I'd argue that's good practice but if you think about risk, it's not going to make the building unsafe if you make the builder ill.  It could make the food product unsafe if you make your food handler ill.  That's why I think it's different.  Do you not see that point?

 

No I don't agree with ATP swabs in any case.  Most of the time they're a waste of money.  But what I do have is records of cleaning and inspection of my toilets daily.  So I do have the equivalent for the toilets if you think about it? 

(I've posted on other threads about how much visual inspection is unappreciated for even plant cleaning so I definitely have that view in toilets.  People are OBSESSED with needing a tool to tell them something is clean when to be honest, most of it is common sense.)

 

I'm going to keep the banter going, please read it in a friendly tone as we continue to debate (more of a devil's advocate for fun at this point):

 

Touche on the food handler being ill leading to others being ill.  But I still compare it to any other job where a refrigerator is not available to employees, and without widespread reports of those employees becoming ill I would deem the risk to be low.  Why couldn't a food service employee bring a small padded cooler if they need to keep something told for 4 hours until lunch, like every outdoor employee in the world?  Or the millions of school children who manage to bring a lunch from home and not get sick when they consume it at lunch time?  I maintain the purpose of the standard here is to avoid employees using production storage areas to keep a lunch cold, that GFSI is requiring us to provide a more attractive alternative in a suitable spot.  

 

On toilets, we both agree that ATP monitoring of a toilet would be absurd, and that visual inspection is sufficient.  I would point to that and then say requiring a data logger of a breakroom refrigerator is also absurd, and if anything, a check that it is functioning should be sufficient.  Again, I'm biased in my SQF background and acknowledge the other GFSI schemes go to the level of requiring detailed monitoring.  I just think it's asinine.  When we add controls to a system, we have to plan contingencies and deviation protocols to the SOP.  If I approach my boss and say I've included the breakroom refrigerator in our crisis management program, I'm going to get laughed out of the room.  But if you're required to monitor the temp specifically, logic would say you should have a full deviation plan for it along with CAPA investigations as to what led to the deviation.  What length of time above 4C is considered a deviation and what is your corrective action?  Do you discard all your employees' meals once that time occurs?

[GMO]

Then plan like any other deviation. Have an alert set point and an action set point.

The only decent sites I've worked in have had multiple fridges so if one exceeds a tolerance set point, the staff lunches can be moved.

Much as you would with a production fridge in fact. It's not difficult.

There are always ways to try and be obtuse. Even with the pretense of banter. If you disagree with it, don't comply. It's ultimately up tk you. I'm just advising that brings food safety, audit and culture risk but it's still your choice.

Edited by GMO, 30 January 2025 - 04:28 AM.