11.7.5.7 - Knives/Scissors & OTC Drugs (not together)

11.7.5.7 Knives and cutting instruments used in processing and packaging operations shall be controlled, and

kept clean and well maintained.

Currently we use knives/Scissors to open product packaging, does this mean they need to be controlled by delegating knives to certain people/rooms?

Where in the code would I find that OTC drugs cannot be provided in First Aid kits?

Hi Lacey -

Regarding 11.7.5.7, you need to account for your knives and scissors so that you know if one goes missing and where to start looking for it (hopefully, not in your product). Assigning the tools to specific individuals or rooms is a great way to handle this - this is how we do it in our facility depending on the type of tool, and our auditor was satisfied.

For your second questions, there is nothing in the code that specifically prohibits OTC drugs in first aid kits. However, you may want to review your HR policies and OSHA standards on this issue. Our facility does not allow OTC drugs first aid kits for those reasons, not because of SQF.

11.3.11.1 First aid facilities shall be provided to treat minor injuries and suitable arrangements shall be provided in circumstances when a patient requires more specialized care.

Hi Lacey -

Regarding 11.7.5.7, you need to account for your knives and scissors so that you know if one goes missing and where to start looking for it (hopefully, not in your product). Assigning the tools to specific individuals or rooms is a great way to handle this - this is how we do it in our facility depending on the type of tool, and our auditor was satisfied.

 

For your second questions, there is nothing in the code that specifically prohibits OTC drugs in first aid kits. However, you may want to review your HR policies and OSHA standards on this issue. Our facility does not allow OTC drugs first aid kits for those reasons, not because of SQF.

 

11.3.11.1 First aid facilities shall be provided to treat minor injuries and suitable arrangements shall be provided in circumstances when a patient requires more specialized care.

I was told by our consultant that we couldn't have them for SQF... Now I'm starting to question everything else we discussed...

Hi Lacey,

As Jennifer B pointed out, you may have specific HR policies limiting the use of OTC medications, or there may be OSHA standards which come in to play which you have to consider for reasons other than "because SQF said so". Given the litigious society that we have become, as an employer you really need to consider whether the benefits of providing OTC medications outweigh the risk of a lawsuit should someone suffer unexpected side effects, or be allergic to the medication that was dispensed to them at work. From a food safety standpoint, you might also consider what the FDA says regarding the subject in GMP's (21CFR110 http://www.accessdat...h.cfm?fr=110.10).

A lot of times, it is less of a headache to just come out with a policy which states that x, y, and z are prohibited and that the use (or possession) of them has to be approved so it can be documented and controlled. (Please note the last part of 11.3.11.1: suitable arrangements shall be provided in circumstances when a patient requires more specialized care).  Consider what the medication is, what is used for, how is it used, is this to control a contagious illness, will this medicine make the individual drowsy (and could a workplace accident occur), etc. etc. etc. etc.. If you allow the medication to be kept on the person, typically documenting this on a register/record in the office will suffice as the employer's knowledge that the medication is now present. It is up to the employee then to maintain control of it. If control is not maintained, the employee would need to be held accountable and responsible.

I've seen "Personal Use Medication" registers used and audited against successfully. I've also witnessed a company get a non-conformance on their audit because the auditor found a bottle of Tylenol left out on the desk in the production office. There was no control over the medicine and hence the nonconformance!

Ultimately, you have to ask the question: is there a risk if this were to become foreign material in the food? If so, how could it become foreign material? How can I control it so it doesn't become foreign material? How can I prove to the auditor that I have controlled it?

(FYI - if you come out with a policy stating that you control the medicine through prohibition, and the auditor winds up finding uncontrolled medication - you guessed it, nonconformance.)

This can be an area that might trip you up, so I hope you have found the contributions helpful.

Thanks,

Chris

Weird to pull back a topic from 2013, but I was reading through, and had a question.

Do I have to add scissors kept in desks to the knife and scissor register? 

For instance, our Office Manager keeps a pair of scissors in her drawer at all times, and these are not available to members of the warehouse. Do they have to be documented as well?

Hi Wayne, scissors are not easy to break and a warehouse is low risk...the hazard analysis to me comes out at very, very low risk of product contamination.  BUT, why not add them anyhow; it is very easy to do I'm sure and doing so will ensure that it will not be a talking point with any auditor and may even get you a very tiny gold star. :smile:

Regards,

Simon