This isn’t exactly new as they are previously highlighted in SQF edition 7.2 and SQF edition 8.0. Let’s revisit how can you achieve compliance for this specific addendum.
When I first read about the medical screening of employees, I think about questionnaires, medical tests and privacy laws and regulations. Yes, we are dealing with all of these and you might want to involve your Health and Safety Officer and HR Manager. SQF does not prescribe the exact process for medical screen employees in the SQF Edition 9 requirements. We are writing quick guidance on what to consider for your medical screening procedures.
What are we concerned about?
The communicable disease may be transmittable through food as a vehicle. Example of communicable disease:
You are probably used to temperature checks before accessing a facility, by now. It is important to note that there is no evidence of coronaviruses are transmissible through food products. However, temperature checks can certainly count as one of the measures for screening employees that might be sick.
Hiring screening and Returning back to work
As part of hiring screening, you may screen employees for communicable diseases. See below for privacy and anti-discriminatory regulations. If it is possible for your local regulatory, this would help you screen away high-risk employees (employees suffering from long-term communicable disease), from working directly with opened food products.
An employee suffering from communicable disease must be required to present a doctor’s clearance notes, to prove that they are no longer present risks to open food products.
Health Screening and Reporting
Supervisors and Managers must be properly trained to identify common symptoms of communicable diseases. Staff must be properly trained to report symptoms of communicable diseases.
As an employee, we are probably considering not reporting sickness due to fear of missing work and wages.
To encourage reporting communicable disease, the site should consider “sick day policy” and alternatives tasks for sick employees and penalties for not reporting communicable disease. Further, a penalties policy for misusing “sick days” can help to motivate employees to use their sick days when they need them the most.
A comprehensive policy can be developed together by the Health and Safety Officer, HR Manager and QA Manager, to ensure that the appropriate legislation and company’s priorities are being captured.
Addressing Local Law and Regulatory requirements for Employee’s Privacy
There are privacy and anti-discriminatory laws and regulations that limit what can be and what cannot be asked and shared regarding an employee’s health status. You must be aware of the local regulatory requirements -when in doubt, consult your HR Manager or HR consultants. They will be able to advise what works best for you, in your case.
The most effective screening methods:
Are all screening methods foolproof? The above-listed screening procedures are not foolproof. They are examples of preventative measures to protect the food products and employees and your plant, to continue to operate without transferring biological hazards risk to the consumers. No screening method is more superior compared to another method.
There are many ways that you can use for medical screening of employees. Remember SQF code is very versatile and it is up to you, to prove that the system or process that you use is effective. Always meet the local compliance for employee privacy -what you can and cannot do.
Need a template?
If you are seeking for SQF Module 12.3 Personnel Hygiene procedures and forms template, you can purchase them here. The new requirements have been added and included in the template bundles.
In addition, if you are our full template bundles customer, these added policies will be automatically sent to you, as part of your package.
Not ready yet, check out a sample of our SQF Management Commitment template here.
Personal Hygiene: A Basic Pre-requisite Program for Ensuring Food Safety. Retrieved from https://www.food-safety.com/articles/3724-sanitation-personal-hygiene-a-basic-prerequisite-program-for-ensuring-food-safety.
Food Safety -Facts Sheet. World Health Organization. Retrieved from https://www.who.int/news-room/fact-sheets/detail/food-safety