3 replies to this topic

[matthewcc]

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

 

[SQFconsultant]

Effective date 10-4-2021

 

https://www.sqfi.com...rsn=bf687914_11

[GMO]

I assume you would need a questionnaire and exclude staff who are or are likely to be carrying pathogens currently which could be communicable.

 

I think it's not on the FSA website anymore (which is a shame as it was a good document) but I've found a copy on a local authority website of the FSA (UK) Fitness to Work procedure.

 

Food Handlers: Fitness to Work

 

What is great about it is that it gives you an example (p18) but also some potential pathogens and what you should do if someone has a positive test for a wide range of examples via a clinician.  

 

The sites you visit in the UK will normally have an adaptation of this (retailers have their own requirements but you see something pretty similar wherever you go.)

 

I'd imagine something like that might satisfy the clause?  You'd need to make sure that it was used (or something similar) at pre employment, first day, return from illness (and ideally holiday), visitors and contractors would also need it.  We also put in a (likely to be abused but ticked the box) reminder by our clock in machines in most places I've worked to say something like "by clocking in, I confirm I am free from the following symptoms... and not a carrier of..." etc and prompting the employee to talk to their supervisor before starting work if that's not the case.  That then "ticked the box" in auditors' eyes for any illness which occurred since the last worked shift and possibly gets you away from overtly checking after holiday if liked.  We did it though because a lot of the countries our staff travelled to were higher risk for food poisoning so we wanted to be certain and actually ask someone "ok, did you have that typical kind of upset stomach you sometimes get when you travel?"  As people don't always put two and two together and realise that was food poisoning.

[matthewcc]

Thanks, I wouldn't even know how to find that document on the SQFI website. Maybe it's buried somewhere? These are from today, available from sqfi.com with two clicks, and don't have the amendment:

 

https://www.sqfi.com...vrsn=7f70c75a_8

https://www.sqfi.com...vrsn=9a64dbea_5

 

 

 

Effective date 10-4-2021

 

https://www.sqfi.com...rsn=bf687914_11