SQF Medical Screening Requirement – How to Implement Practically
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:
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.
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
Here's the SQF guidance on this topic:
Historically I've always included it in our new hire info sent to temp agencies, our GMP program and visitors/contractor's policy. I name out the big ones from FDA Food Code (Norovirus, Salmonella Typhi [typhoid], Shigella spp, Hep A, Nontyphoidal Salmonella) and train employees they are required to self-report if they have or acquire any of them. They don't have to reveal confidential medical info to us, but it is a public issue that they have to report if they're affected by something on the lists.
I've had go arounds whether bloodborne illnesses need to be included, general science stating it required blood-to-blood contact so not a food safety concern. It's brought up in the refresher trainings for GMP at least annually where I work, couple notices sometimes get posted to bulletin boards, but we've never actively screened for them in any of my sites.
We also require employee to report if they become ill (diarrhea, fever, vomiting, etc.), which all in concert together seem to satisfy auditors we are working to prevent illnesses as much as HIPPA permits.