9 replies to this topic

[mm.stf]

Hi guys,

 

I'd like to bring this one for discussion.

 

One of our staff members (a supervisor, by the way) started wearing pimple patches on his face. 

The discussion started inside the quality team of whether we should allow it or not inside the production room.

 

Obviously there is a high risk of the patches falling off the skin (I've worn them myself - out of work - and had it happening to me); so I'm on the side of not allowing it. On the other hand, someone brought up the fact of the pimple being an opened wound that would pose microbiological risk to the product.

 

The staff member in question said he wears super strong patches that won't come off for 3 days; but my concern lays on allowing it and other members starting to wear patches not as strong/good quality.

 

Has anyone else gone through a situation like this? What would you do?

 

We don't have any policy that specifically mentions pimples or pimple patches; our GMP policy vaguely says "wounds must be covered with appropriate dressings".

 

Thank you!

[SQFconsultant]

Not allowed here and if the person has an open wound they are not working in production until healed.

[Tony-C]

Hi mm.stf,

 

This is a fair question as many standards refer to covering cuts/sores/grazes and then for gloves to be worn if appropriate as I guess that in most cases apply to hands and most other areas will be covered by protective clothing.

 

 Glove Covering Head.png   867.65KB   0 downloads

 

As Glenn has indicated any dressing which could fall off and contaminate the product should not be permitted and people with open wounds should be excluded from production areas. 

 

One possible solution would be wearing a face mask but this is only effective if the patch is within the mask coverage.

 

A policy of exclusion and working in an area where there is no risk of product contamination is the belt and braces solution.

 

Kind regards,

 

Tony

[GMO]

Agree with the above from a food safety risk.  If you'd permit a cut on the face to be covered by a detectable plaster (if it wasn't a pimple) then that is an option.  I do not know of a standard that asks for additional face coverings in this situation although I agree the risk is almost as high as hands which are normally required to be covered with gloves.

 

I would agree on a purely food safety standpoint that non open product areas only AND the dressing is substituted for a detectable dressing (which they may not want to do if their normal patch has some specific anti break out properties). However, I'm also a manager with a lot of experience and I realise this is going to be a can of bloody worms.

 

I'd get HR involved early doors and get them onboard before you do anything. Food safety should and does trump other concerns, however, no sense walking into a minefield without at least body armour on. There is a chance the person being asked to move will take extreme offence to it and their managers won't want it to happen.  So you need some allies before you pull out the pin in the grenade and chuck it over the wall.  And that might be food safety considerations and beyond.  For example, if the person has big problems with their skin they may have issues with staph. but also they may be able to be helped by referral to a dermatologist which the company might facilitate if it gets them back to their normal role quicker. But while this is a pain for you, it's likely the person will be super sensitive about it so a combination of preventing a food safety issue but also protecting the person and the business will be needed.

Edited by GMO, Today, 11:04 AM.

[Setanta]

I would say no, usually because IMX people usually try to hide the patch with extra make-up, adding another hazard. A MD bandage would only briing even more attention. 

 

That sucks for your employee! 

[MDaleDDF]

Our policy is wounds must be cleaned properly and totally covered with a metal detectable band aid.   I'm normally a stickler, but I'd say if it's covered with a metal detectable band aid, I'd be alright with it.   Our band aids do NOT fall off, so as long as they care for it like they would another wound, whateva...  a covered wound is a covered wound.

I apologize in advance for being nice on this one, lol.
 

[Scampi]

It's a simple no for me

[kconf]

I would allow it if it can be covered by a MD bandage on top. Polypropylene  particles from hairnets and beard nets have higher chances of falling into production than a "guaranteed to be waterproof and stays on" patch. 

[jfrey123]

An unpopped pimple isn't an open wound, but a popped one is.  Referring to FDA GMP's for the US market:

 

(a) Disease control.  Any person who, by medical examination or supervisory observation, is shown to have, or appears to have, an illness, open lesion, including boils, sores, or infected wounds, or any other abnormal source of microbial contamination by which there is a reasonable possibility of food, food-contact surfaces, or food-packaging materials becoming contaminated, must be excluded from any operations which may be expected to result in such contamination until the condition is corrected, unless conditions such as open lesions, boils, and infected wounds are adequately covered (e.g., by an impermeable cover). Personnel must be instructed to report such health conditions to their supervisors.

 

These are always open to interpretation, but by my read comparing the bold to the underlined exemptions above, you could permit the employee to wear a pimple patch and I would add it must be covered by a detectable bandage.  Removing the employee to a storage only or other non-food handling role would be equally acceptable. 

 

Also adding in that you might also need to consider whether the patches are recommended by their doctor, because if your attitude is "send them home until the 'wound' fully heals," you risk running afoul of the Reasonable Accommodations required for medical issues.

[MDaleDDF]

Also adding in that you might also need to consider whether the patches are recommended by their doctor, because if your attitude is "send them home until the 'wound' fully heals," you risk running afoul of the Reasonable Accommodations required for medical issues.

Ahhhh yes, good point.....