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Assessing Personal Hygiene, Hands As a Vehicle of Contamination, and Proper Implementation of Employee Health Policies

Special attention should be given to the potential for hands as a vehicle of contamination. An effective management system for prevention of hand contamination involves three elements:

  • Employee health policy

  • Proper handwashing

  • No bare hand contact with ready-to-eat foods.

There are a wide range of communicable diseases and infections that can be transmitted by an infected food employee. Proper management of the risks associated with ill food employees begins with employing healthy people and implementing a policy that excludes or restricts ill employees as specified in Chapter 2 of the Food Code. Employees must be aware of the symptoms, illnesses, or conditions that must be reported to the person in charge. In addition, the person in charge must be knowledgeable regarding the appropriate action to take should certain symptoms, illnesses, or conditions be reported.

With regard to the employee health policy, inspectors should ask a series of open- ended questions to ascertain whether the employee health policy in place complies with the Food Code. The following are example questions that may be asked:

  • What kind of policy do you have in place for handling sick employees?

  • Is there a written policy? (Note: a written policy is not required in the Food Code, but having a written policy may give an indication of the formality of the policy being discussed.)

  • Describe how managers and food employees are made knowledgeable about their duties and responsibilities under the employee health policy.

  • Are food employees asked if they are experiencing certain symptoms or illnesses upon conditional offer of employment? If so, what symptoms or illnesses are food employees asked about? Is there a written record of this inquiry?

  • What are food employees instructed to do when they are sick?

  • What conditions or symptoms are reported?

  • What may some indicators be of someone who is working while ill?

  • When are employees restricted from working with exposed food or food- contact surfaces? When are they excluded from working in the food establishment?

  • For employees that are sick and cannot come to work, what policy is in place for allowing them to return and for notifying the regulatory authority?

Special attention should be given to the potential for hands as a vehicle of contamination. Ensuring that hands are washed using the proper procedure and at the appropriate times must be a top priority during every inspection. Data show that viruses

Annex 5 – Conducting Risk-based Inspections 531

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