7 replies to this topic

[RAM86]

We have an employee in our production area that has a disability that requires him to inject insulin and keep ready small snacks to regulate his insulin levels. 

 

Are there any stipulations that BRC standards may be bent in regards to accommodating someone with a disability and allow them to keep their cooler with insulin and snacks nearby the work area?

[Setanta]

Is the breakroom too far away for his needs? I would really caution about bending any BRC rules.

[RAM86]

Is the breakroom too far away for his needs? I would really caution about bending any BRC rules.

 

 

Not really, but I was asked if there were any accommodations we can make. This was a new one to me that I've never experienced. Wasn't sure if there was some type of allowance for medical needs.

[Scampi]

If the employee is having that much trouble regulating insulin levels, perhaps they should be transferred to a position that allows more freedom for access to the breakroom as required

 

 

You do have to make concessions for medical issues, but not at the sake of your food safety

[jfrey123]

Reasonable accommodations for disability and medical issues are required by US law.  GFSI schemes won't care if they see a hazard to food safety.  In your shoes, I would have to suggest the employee shouldn't work in processing areas with open/exposed product as cross contamination with their snacks or insulin injection syringes (if they're injecting manually vs an automatic pump).  I would place them in a storage or shipping/receiving type role, write an exemption permitting them to keep snacks in a designated area signed by the employee or QA, with some language addressing whether you'd permit the snacks to contain allergens or not.  Make it clear they need to remove themselves from the shipping/storage area when they need to take a snack or inject, if medically safe to do so, but also specify that trash found on the floor or food found in undesignated areas is still a violation of your GMP.  It wouldn't be reasonable to me to let them pocket snacks and just eat them whenever they're pulling orders or cruising around on their forklift, etc.

[SQFconsultant]

The person should go back to their medical provider and inquire if they are eligible to wear an automatic patch - it regulates the amount of insulin needed and delivers same thru the skin under the patch.

 

I know of several people that work in food companies that have these - it eliminates the need for "snacks."

 

Best thing is the Keto diet - elimination of sugar - I have seen many people that were diabetic become non-diabetic by simply changing their diet.

 

Of course the medical industry doesn't like hearing about that. No money in that.

[MDaleDDF]

I agree a pump patch is the way to go.   My mother was actually a diabetic educator at UofM, and helped develop the first pumps, kinda cool.

If they can't wear a patch, tell them they can step out quickly to scarf down an orange or whatever, insulin as needed.  

Diabetes indeed sux.....

[ChristinaK]

Unfortunately, insulin injections are often cheaper than the pump. If this person doesn't have decent medical insurance, the injections are likely the most affordable for him. Downside is that there is a steep learning curve for figuring out how to time your injections so you don't crash and need the "snack" (probably a glucose tab).

 

Keep in mind you may also have to adjust your sharps/foreign material program to accommodate this. If he's allowed in any production areas from receiving raw materials to shipping finished goods, you need to ensure that there is 0 chance of those used injections being present in your product. That means having a specific sharps disposal device he needs to use, with firm disciplinary action if he disposes of them in the regular trash. 

 

Do you have water stations set up near production areas? Ex: a water cooler with disposable cups. That may be a solution for where he can store his cooler. Or perhaps if you have a first aid kit located nearby the production area it could be kept near there? Or maybe on a production supervisor or manager's desk? Also, depending on how hot your facility gets, a cooler might not keep the insulin cold enough during a shift.

 

You'll want to work with HR and/or legal on this as well to ensure your solutions don't cross any legal (HIPPA) lines and that you've tried to offer reasonable accommodation under ADA law. Depending on the nature of your operation, reasonable accommodation for this person may not be possible, and that's where you want HR and legal to be on the same page with you.