General Health & Safety Training NOT Required?

I was discussing our training program with our Ops Mgr today and he told me that he doesn't think that either HACCP or SQF (we're working toward Level 2 certification) actually requires Health & Safety training.

But... I don't see how we can accomplish all of our food safety goals w/o a General Health & Safety program and training. I did a search through the SQF standard for anything specifying Health & Safety training but didn't see anything. 

Can anyone weigh in on this? Especially in terms of any actual legal requirements (by FDA, OSHA, etc.) or SQF standards on the chance I missed something?

Many thanks in advance,

~Emily~ 

Good 1 page read that i believe addresses this.

 

http://www.sqfi.com/...comes-document/

Many thanks to you, Brian. I believe the paragraph below will help me with this issue. 

Expected Outcomes for Accredited Certification to SQFI ES Code

For the defined certification scope, an organization certified to the SQFI ES Code is committed to responsible practices related to trading activities, human resource activities, social management programs, and programs for managing environmental impacts and occupational health & safety risks.

Again, thank you, thank you, thank you!

~Emily~

Hi Emily,

I am confused. 

Perhaps it relates to the US interpretation of "Health" ?

AFAIK, the SQF Code is a Standard to ensure Food Safety.

Nonetheless, certain aspects of a foodhandler's health may interact with Product Safety, eg transmission of disease.

Such hazards and their control  are included within Prerequisite programs, eg Personal Hygiene.

The implementation of Prerequisite programs as related to FS Standards usually demands Training.

I am amazed.

Is it really true that in the USA, a Company has no legal responsibility to protect the H&S of its employees while working.

Hi Emily,

 

I am confused. 

 

Perhaps it relates to the US interpretation of "Health" ?

 

AFAIK, the SQF Code is a Standard to ensure Food Safety.

 

Nonetheless, certain aspects of a foodhandler's health may interact with Product Safety, eg transmission of disease.

 

Such hazards and their control  are included within Prerequisite programs, eg Personal Hygiene.

 

The implementation of Prerequisite programs as related to FS Standards usually demands Training.

 

I am amazed.

 

Is it really true that in the USA, a Company has no legal responsibility to protect the H&S of its employees while working.

Hi Charles,

I think I did not use the appropriate terminology that I intended/was actually speaking about. I should have said Occupational Health and Safety. We do have laws protecting our health and safety (derived from the Government agency, OSHA); when I mentioned legal requirements, I was curious because I did a search on OSHA's website and saw that there are requirements to protect us but couldn't find requirements for any specific training since we don't have a forklift/baler/heavy machinery. 

My question is whether standard Occupational Health and Safety training are required parts of HACCP and/or SQF. My ops manager says no but I feel they are intrinsically linked. If you're being unsafe in your health (coming to work sick) or safety (sticking your hand in a mixing bowl to scrape the sides while it's running), you're automatically putting the safety and quality of the food you're producing in jeopardy.

Hopefully I've worded this better for everyone's understanding. Sometimes it makes sense in my head but not on the screen once others read it --- sorry!

Thank you!

~Emily~

Hi Emily,

Here is perhaps (?) the  UK equivalent to OSHA  -

http://www.hse.gov.u...afety/write.htm

Here is a UK generic example of Employer's responsibility for an Alarm Installation Company from above site -

 health-and-safety-policy-example.doc   216.5KB   109 downloads

I suggest that for a Food Processor there will be overlap to the type of issues found in Prerequisite Functions for a FS system. Including Training..

Also note the parallel thread running to this one -

http://www.ifsqn.com...ety/#entry41693

Hi Emily,

 

Here is perhaps (?) the  UK equivalent to OSHA  -

 

http://www.hse.gov.u...afety/write.htm

 

Here is a UK generic example of Employer's responsibility for an Alarm Installation Company from above site -

 

health-and-safety-policy-example.doc

 

I suggest that for a Food Processor there will be overlap to the type of issues found in Prerequisite Functions for a FS system. Including Training..

 

Also note the parallel thread running to this one -

 

http://www.ifsqn.com...ety/#entry41693

Thank you, Charles.

I try to search through topics to be sure I don't duplicate but it looks like I missed this one. I will peruse it once I'm out of my meeting. I think that I'm just going to try to sneak the training in together and see how it works. ;-) Worst-case scenario, it'll be the first battle I pick since I feel strongly that all employees should have formal occupational health and safety training, including the company's policy on how to handle emergency situations, where the first aid kit(s) is/are, etc. Even if they're part of new employee orientation, I still think they should just be included in annual training as a CYA to protect the company. 

Thanks again!

~Emily~

Hi Emily,

You're obviously skilled at multitasking.

Should add that I'm in no way decrying Brianweber's proposal, Ethical issues are rightfully of concern and I assume SQF have a Business Model also.

Thank you, Charles.

 

I try to search through topics to be sure I don't duplicate but it looks like I missed this one. I will peruse it once I'm out of my meeting. I think that I'm just going to try to sneak the training in together and see how it works. ;-) Worst-case scenario, it'll be the first battle I pick since I feel strongly that all employees should have formal occupational health and safety training, including the company's policy on how to handle emergency situations, where the first aid kit(s) is/are, etc. Even if they're part of new employee orientation, I still think they should just be included in annual training as a CYA to protect the company. 

 

Thanks again!

 

~Emily~

Emily, I assure you, OSHA requires that any employer with more than 10 employees has to properly train them in Occupational Health & Safety.  What is trained will depend on your site.  At the minimum, there are requirements for emergency preparedness, hazard communication and use of PPE.  But as far as OSHA is concerned, any risk that is at your site requires that you train your workers how to work safely around it.

Even where there are no specific standards for training, there's always the General Duty Clause, which requires employees to have a safe and healthful workplace.

The reason why it's not put into the food safety standards is because it's covered under government regulations.  For the US, the OSHA standards are to be found at 29 CFR 1910.  The OSHA web site is awesome.

The rule of thumb is that if you have a safety plan for something, you need to train workers.  And the prudent course of action is to have refresher training every year.

A list of what you should be looking to consider in any workplace:

1. Fall protection (if anyone goes over 4 feet from the ground where there are no railings)

2. Lockout/Tagout

3. Hearing Conservation ( if you have noise over 85 decibels)

4. Hazard Communication (for chemical hazards, and most sanitizing chemicals would be considered hazardous chemicals)

5. Emergency Action (required from all employers)

6. Fire Prevention

7. Confined Space (if you have confined spaces that workers need to enter)

8. Bloodborne Pathogen (if you have a first aid crew, which is required if you are more than 4 minutes from an ER and there is the potential for injury on the job)

If you are in a state with a state plan, they may have imposed more strict regulations than OSHA has (it's allowed, so you better check out your state), which means that just looking at the OSHA site is not enough.

If you want more help, feel free to contact me, I've been handling occupational health & safety for many years. 

Martha

Emily, I assure you, OSHA requires that any employer with more than 10 employees has to properly train them in Occupational Health & Safety.  What is trained will depend on your site.  At the minimum, there are requirements for emergency preparedness, hazard communication and use of PPE.  But as far as OSHA is concerned, any risk that is at your site requires that you train your workers how to work safely around it.

 

Even where there are no specific standards for training, there's always the General Duty Clause, which requires employees to have a safe and healthful workplace.

 

The reason why it's not put into the food safety standards is because it's covered under government regulations.  For the US, the OSHA standards are to be found at 29 CFR 1910.  The OSHA web site is awesome.

 

The rule of thumb is that if you have a safety plan for something, you need to train workers.  And the prudent course of action is to have refresher training every year.

 

A list of what you should be looking to consider in any workplace:

 

1. Fall protection (if anyone goes over 4 feet from the ground where there are no railings)

2. Lockout/Tagout

3. Hearing Conservation ( if you have noise over 85 decibels)

4. Hazard Communication (for chemical hazards, and most sanitizing chemicals would be considered hazardous chemicals)

5. Emergency Action (required from all employers)

6. Fire Prevention

7. Confined Space (if you have confined spaces that workers need to enter)

8. Bloodborne Pathogen (if you have a first aid crew, which is required if you are more than 4 minutes from an ER and there is the potential for injury on the job)

 

If you are in a state with a state plan, they may have imposed more strict regulations than OSHA has (it's allowed, so you better check out your state), which means that just looking at the OSHA site is not enough.

 

If you want more help, feel free to contact me, I've been handling occupational health & safety for many years. 

 

Martha

Martha,

Thank you very much!

 

Martha,

 

Thank you very much!

 

My 2 jobs since I've come to Michigan have been for small employers; while I was involved with quality (among other things) in my last position, I wasn't involved in OSH so am not as "up" on legal requirements as I would like. 

 

I am going to take your list and information as back up to talk our ops manager into this training. It may also be that his hesitancy is not to conduct the training itself but to conduct it at the same time as our FSMS training. That is a whole different "battle" -- and an easier one at that!

 

Thank you, again,

 

~Emily~

 

It's my pleasure, Emily.

Just like you did for your HACCP Plan, you can do a walk around, look at your worksite, watch your people do their jobs, and find where the risks are.  Safety people are KNOWN for doing JHAs (Job Hazard Assessments) continually.  As you walk through your facility, it becomes part of your way of looking at things.  You're asking, "Where are the risks here?  For food and for people?  How can they be countered?"

After you see what is there to harm your people, you go to the OSHA web site and type in your topic.  They have tons of information, from quick cards to information sheets to links to the regulations.  They actually want to help you keep your employees healthy and safe.  They would rather that they never have to issue a citation, but that no worker is ever harmed by his job.  You can write up your programs as very simple and easy to read documents, It does not need to be written in "legalese."  Just say what you are going to do.

As you can tell, keeping people safe on the job is a passion of mine.  I've seen some bad accidents, and I don't want to wish that on anyone.

I like the saying that OSHA put on a poster in 2011.  The statistics are for the US, and they have not changed since then.

Martha

        12                                                      + 3.3                             = 2 many

workers die on the job every day                  million workers seriously injured on the job each year

And, Michigan has their own state plan, and it looks like there are many resources on their site to help you set up your programs and training.

http://www.michigan....1407---,00.html

Martha

Hi Emily

The topic you are requesting is under the FDA Good Manufacturing Practices, I attached the link below. Go to the training section.

Here is a cut from it.

Training programs should be periodically reviewed and updated where necessary. Systems should be in place to ensure that food handlers remain aware of all procedures necessary to maintain the safety and prevent adulteration of food.

(d) Supervision. Responsibility for assuring compliance by all personnel with all requirements of this part shall be clearly assigned to appropriately trained supervisory personnel.

Periodic assessments of the effectiveness of training and instruction programs shall be made, as well as routine supervision and checks to ensure that procedures are being carried out effectively.

http://www.fda.gov/F...P/ucm207458.htm

 

Training programs should be periodically reviewed and updated where necessary. Systems should be in place to ensure that food handlers remain aware of all procedures necessary to maintain the safety, and prevent adulteration of, food.

 

(Italics and punctuation added to make the regulation more clear.)

nd01ken, this refers to the safety of the food, not the safety of the workers.  The FDA has no power to regulate on the occupational safety training of workers.

The jurisdiction of the different agencies is pretty specific, but they tend to use the same words to mean different things.  I think it's on purpose to confuse people, lol.

I was hired by someone who thought that EHS is usually used the same as Food Safety.  If you are in the occupational safety field, it is not the same.  It's a by-product of our legal system and the English language.

BTW, I noticed that you are from the city of my birth, that I am so proud to be from.  Baltimore is a great city, and I visit The Fort every few years.  I moved to the Eastern Shore, Kent County, for this job, and I love it here, but a part of me still feels at home in Charm City.

And I love my Balamer accent.

Martha

nd01ken & Martha: thanks to you both. Between you two and Brian Weber's original reply, I have a wealth of information on both the food safety and occupational safety side of things.

Everyone here is great!! 

Hi Emily,

It sounds like you're on a good track. We use the same "Workplace Inspection checklist" to monitor premises, employee hygiene, and occupational health and safety standards (e.g. fire extinguishers checked monthly, emergency exits are clear and unobstructed, etc.). It is handy to have one inspection instead of two different ones. And you get the added benefit of reviewing one set of deviations. In my opinion, it brings more clarity to the operation.

Cheers.

Also the SQF code does make reference to "regulatory requirements", which you could interpret as occupational health and safety if you want to bring the point home with your boss.

2.1.1:

ii. Methods used to comply with its customer and regulatory requirements and continually improve its food safety management system; and

We use the same "Workplace Inspection checklist" to monitor premises, employee hygiene, and occupational health and safety standards (e.g. fire extinguishers checked monthly, emergency exits are clear and unobstructed, etc.). It is handy to have one inspection instead of two different ones. And you get the added benefit of reviewing one set of deviations. In my opinion, it brings more clarity to the operation.

Great idea, amppyr - thank you! We are realizing we need to produce way more documents that we had previously thought so I welcome any opportunity to include multiple documents into one. 

Thanks a bunch!