10 replies to this topic

[TimG]

So, I've been away from the food safety side of things for 2+ years and maybe I need to realign my thinking again. I am going through this facility's previous year SQF audit to make sure we are still following agreed upon corrections and came across one I am having trouble reconciling with logic.

Facility lunchroom, with a clearly marked 'ok to walk to with food' (non-GMP) path. It has lockable lockers for our employees to store their personal effects, and LUNCH. The auditor said it was against code to store lunch in lockers in the lunchroom. The section of code they cited:

 

11.3.5.2 Change rooms shall be provided to enable staff and visitors to change into and out of protective clothing as required. Change rooms shall be kept clean.

 

The NC was appealed all the way up through the chain, with a final ruling of denied because "the facility did not provide evidence of a procedure or stated checks they conduct to reduce risk." However, I noticed our pest control procedure was listed as evidence we are minimizing risk and monitoring (also internal GMP audits).

 

To comply to their final ruling, we put up a 'no food in lockers' sign.

 

Here's the crux of this long post: I think this is a completely BS take on the code, and I feel enforcing misguided rulings like this does more food safety harm than good, but I'm at a loss as to what more I can do. I got into compliance because I hated stupid rules, and this really seems like I am not enforcing a stupid rule with not allowing food in lunchroom lockers.

I don't really expect a direct route forward from anyone, but maybe some outside the box ideas from you guys can help me wrap my head around this one.

[SQFconsultant]

So, if I work at your company can I put my peanut butter and jelly sandwich in my locker with my bottle of beer?

[Scotty_SQF]

We have our lockers in the lunch room as well and haven't had any issues with this.  In my career only ever had one auditor go through lockers.  

[Setanta]

We do not restrict the food people can bring to work. We haven't had an issue with this in audits.

 

Alcohol is prohibited and would be confiscated, and the responsible person requested to remove it for a 1st offense. 

 

The break room is separated from the production room, and there is no food or drink allowed in the production room. We have bottled water and people must drink it in a specific area and leave their cups behind. 

 

Again, SQF auditors have not had an issue with this. (so far...) 

[Brothbro]

Is your locker/breakroom layout implying that staff have to walk into the lunch room to take off their PPE? Sounds to me like you don't consider the locker area a "change room", instead it's just an area for people to drop off their personal belongings. Your "change room" is likely somewhere else where the smocks are stored, on the way to the production floor. Does that sound accurate? I've worked in SQF facilities that were structured like that before and they never had an issue with it. It could be that the auditor misinterpreted the flow of how staff get ready for their work day.

[jfrey123]

Can they walk this non-GMP path in their smocks/aprons?  Only reason I can think of to not allow lunch boxes in employee lockers would be if the employees are storing any of their working clothing or items in these lockers during breaks/lunches.  I've always allowed the lunch boxes in lockers, as every operation I've worked thus far wouldn't let GMP related clothing or anything beyond a designated changing area well separated from the breakroom.

 

 

 

So, if I work at your company can I put my peanut butter and jelly sandwich in my locker with my bottle of beer?

 

One of my first companies had an SQF auditor find a couple bottles of whiskey in our "janitorial chemical storage" area, which happened to be under the sink we designated for washing dishes in the breakroom, which was basically the one open office where the owner and his secretary worked all day.  Really small operation, literally one full time production employee getting backup from the owner when things were busy.  Auditor gave us a fair amount of leeway on small liberties he found because the process itself was safe and intact and we operated out of an incredibly small space.

[TimG]

Just to answer some questions:

• Alcohol (and MJ since it's legal here) is addressed and trained on, not allowed in facility
• No smocks, employees wear street clothes, our GMP training calls out clothing 'must be clean' and has a 'supervisor (and up) can and will ask you to leave premises to change' caveat at supervisor and up discretion
  • It's wear clothing in and work in what they wear in. I will be circling back to that at a later date, it is in the current RA but I want to watch a few more shifts and see if I agree with the justification
• lunch/break room is directly pathed to entrance, and there is a clearly defined and trained on 'no food or unauthorized drink' termination point
• Not a PPE storage/changing area

 

I will most likely have to wait until the auditors visit this year to pick his brain on what risk he feels we needed to address. When I read the correspondence, the final consensus was "SQF code prohibits food in lockers, without making exceptions for lunchroom lockers." 

[Scampi]

We have an identical situation TimG---never has an auditor brought up the lockers HOWEVER we DO NOT allow food in them         Mainly because they only get cleaned once/year and the rest of the lunchroom is daily

 

We have provided ample open storage for lunch bags

[ChristinaK]

If there are shelves, bins, or refrigerators in the lunch room, people should keep their food there. Unless lockers are checked by supervisors/management regularly, I would prohibit food from being stored in them.

 

If there was not an appropriate alternative place for personnel to store their lunches, you'd have to make sure to address locker room cleanliness and inspections regarding food debris, pests, and spills if they were allowed to store their lunch in their personal locker.

In that case, I would add something like this to the "personnel" section of the GMP policy/procedure: "If food, ex: employee's lunch, is kept in a personal locker, it must be contained in a non-permeable lunch bag, box, or cooler fit for purpose that limits the risk of contents spilling and contaminating the locker or adjacent areas and attracting pests. Plastic "grocery" bags, paper bags, and open bags are prohibited due to the likelihood of spills and easy pest access. Loose food or food kept only in "tupperware" containers are also prohibited from being kept in personal lockers. Lockers and locker room may be checked at any time as part of GMP inspections to ensure compliance, cleanliness, and lack of pest activity. Personnel must report any spills, odors, or pest activity immediately to management so corrective action may be taken. Corrective actions will depend on the nature of the incident, but may include cleaning and sanitizing all impacted areas, pest control measures, or disciplinary action."

 

Most places I've worked prohibited storing food in lockers, but people will still do it. I have seen a cockroach infestation happen even when there's no food/lunch stored in a locker, simply because someone brought it in via purse or backpack and came from a home that was infested. Ended up having to supervise everyone open, empty, clean and sanitize their locker, and had people keep all personal items in a sealed plastic bag until we were sure it was finally taken care of. Total pain and absolute nightmare.

[TimG]

Thanks for your feedback guys. I believe I will be working with production manager on this one. Leaning toward removing the lockers completely and putting in cubby hole style lunch cubbies. Can anyone see anything wrong with that idea? 

[jfrey123]

Cubbies are fine from a cleanliness standpoint, but keep in mind an auditor will take advantage to look at anything they can see and touch.  My auditors open unlocked lockers during audits and rifle through the contents (not opening personal items like a lunch box, but anything they can see just by shifting things around becomes fair game).  Having it wide open will give them cause to question things like half eaten sandwiches just wrapped in paper (pest attractant) or visible granola/candy bars (does your allergen program account for employees having nuts, dairy, wheat in their lunches?), so on and so forth.  Cubbies eliminate the confusion around "lockers" that are mentioned in the code, but they're not without their own potential pitfalls.