Hello, I'm a bit late to this topic because we didn't see it in the SQF Code previously, and in fact "medical screening" does not appear in the SQF Code on sqfi.com even to this day; all of this is to explain why we are getting started late.
Anyway, our SQF auditor brought up that there is now a medical screening requirement in SQF Code 11.3.1.1 (which, presumably, would be in 17.3.1.1, but I can't verify on the sqfi.website), which I have quoted below, with changes including "Medical Amendment" and text that follows:
11.3.1.1
Personnel who are known to be carriers of infectious diseases that present a health risk to others through the packing or storage processes shall not engage in the processing or packing of food or enter storage areas where food is exposed.
Medical Amendment added: Code Amendment #1A medical screening procedure shall be in place for all employees, visitors and contractors who handle exposed product or food contact surfaces.
We already have procedural requirements and refresher trainings that instruct workers that they must report any condition that could be a microbial risk to product, product-contact surfaces, or packaging materials, and that the area supervisors must exclude from operations any person, including a visitor, who has such a condition. The auditor saw all that (we spent maybe almost half an hour on this) and appeared ready to give us a nonconformance anyway. I sense the auditor was reluctant to give an NC because the requirement came in late and it doesn't appear in the code; however, that is only my opinion.
My question is, given the auditor saw what we already have and wasn't quite satisfied, what should we in fact do for a screening? We've considered a question that could go to employees asking if they have such a condition, such as in their app that they use for clocking in and out for work shifts. Is this too much, and if not, how often should they answer this question?
We are regulated in the United States under 21 CFR Part 111 and 117 and we have SQF and NSF GMP certifications for manufacturing dietary supplements.
Thank you,
Matthew
