8 JULY/AUGUST 2008 AIB UPDATE

Contractors in the Food Industry

By Lance Reeve

Safety and Training

Foreign Territory?

Y ou would be hard pressed to find a food company that doesn’t provide some form of food safety, food defense and occupational safety training for

its employees in today’s industry. But, the same training is not as commonly provided for contractors, such as equipment technicians, pest control operators, vending service personnel, uniform suppliers and so on. Many contracted workers are not familiar with food safety, food defense, occupational safety and other rules specific to the facilities they service. Maybe it’s time to evaluate your training program to ensure that contractors understand that they are expected to follow the same general rules that your employees follow.

CONTRACTORS AFFECT YOUR OUTCOME. The fol-lowing unfortunate example reveals how contractors can affect the outcome of a product. In 2005, maintenance contractors were called to service an elevator at a hospital. The workers drained hydraulic fluid from the elevator into several empty detergent drums they acquired from another hospital, but did not mark the contents on the containers. When the job was finished, the contractors left the drums at the hospital. Since the hydraulic fluid and detergent were very similar in color and the contain-ers were labeled for their original usage (detergent), the hospital unknowingly used the hydraulic fluid to wash surgical tools. Over 3,800 patients were exposed to surgi-cal instruments that were washed in the hydraulic fluid instead of the intended detergent.

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Although the previous example occurred in the healthcare industry, similar events are just as serious in the food industry. Mislabeled containers are a major concern for many food plants. This may occur when contractors are not aware of the food plant’s container usage requirements and can lead to significant food safety or personnel safety issues.

Earlier this year, I visited a facility to evaluate their food safety practices. One of my concerns was the lack of education and training provided to contractors. Some of the potentially harmful contractor practices I observed included:• Weldingandgrindinginthewarehousenearpalletsofproducts

with no protection between the pallets and work area• Carryingitems,suchastools,pens,etc.,inshirtpockets• Proppingopendoorsthatledintothefacilityfromoutside• CuttingPVCpipesinapackagingroomandnotcontaining

the dust from the saw • FilingPVCpipesontopofproducttotes• Storingnon-food-gradechemicalsinproductionroomsnextto

packaging and food items• Usingfinishedproductcontainersastrashcontainersinproduc-

tion rooms

After observing these significant food safety and defense issues, I evaluated the training that was provided before contractors were allowed in the food plant. Although training had been provided, itwasratherlimitedandcoveredonlybasicGMPs,suchashandwashing, jewelry and hair net policies. It was evident that this train-ing was not detailed enough to cover the issues noted.

TRAIN CONTRACTORS ABOUT COMPANY EXPECTATIONS. An effective contractor training and education program covers all of the information required for contractors to conduct their work in various areas of the facility. Some companies develop complete manuals that are provided to contractors before work begins. These manuals should be specific to the tasks that will be completed by the various contractors. Obviously, the training required for a vending

service contractor is not as extensive as the training needed for a contracted production equipment technician. It is critical to review various policies with contractors to ensure that they understand and will abide by the rules established. It is also a good idea to require contractors to sign a commitment to follow your company’s policies in the service contract.

I recently was scheduled to provide training for a food facility. Uponarrival,Ihadtocheck-inatthesecurityguardhousebeforeentering the property. While in the guardhouse, I was required to review their written visitor and contractor policies, watch a short training video of company rules, and sign a form indicating I had reviewed and understood the rules. This was a very effective form of training and I felt quite confident that I understood their expectations.

DESIGN A COMPLETE CONTRACTOR TRAINING PROGRAM. Once you have identified your facility’s expectations, you’ll need to evaluate your current contractor training program or develop a new program to ensure that all contractors understand and agree to follow your policies.

GobeyondthebasicGMPstoincludefoodsafety,foodde-fense and occupational safety rules that may affect their actions. Considerthefollowingquestionswhendesigningorevaluatingyour contractor training program.

Safety and Training

When contractors are not aware of the food plant’s requirements and policies, it can lead to significant food safety or personnel safety issues.

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Training DVD aVailableIn august, aIB introduced a new training product design to train contractors in the food industry. The Food Safety and Food Defense awareness for contractors DvD is a 20-minute interactive tool that comes with a trainer’s guide.

For more information, go to www.aibon-line.org.

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• Have you established a designated route that contractors will use to enter the property and building and travel within the facility?

Identify the driveway or gate contractors should use to enter the property, a designated parking area and specific doors they should use to enter the building. Minimize travel routes within the facility. Extra precautions should be taken in a microbiologically sensitive facility. You would not want a contractor working in a raw material area of a dairy or meat facility to travel to a finished product area without taking necessary measures to address microbiological concerns.

• Who are the contractors entering your facility? Contractorsshouldberequiredtoprovidegovernmentand

company-issued identification that can be verified by company personnel prior to entering the property. The contracting company should provide a list of authorized employees who will receive all necessary training as outlined by your company before performing any work.

• Do you provide contractors with visitor badges or other identification?

Employees should be able to recognize contractors working at your facility. By providing visitor badges or another method of identification to your contractors, employees can monitor per-sons within the operation and know if they are approved.

• What are contractor clothing requirements? If your operation requires all employees to change into uni-

forms prior to entering the facility, does it make sense for contractors to be allowed in the facility with street clothes? It may be necessary to provide contractors with smocks or other outer garments before entering sensitive areas.

• What level of oversight is provided for contractors? It is important to establish this responsibility with company

personnel. A company representative should maintain close contact with contractors to ensure the company’s policies are followed. The representative should be available to answer any questions the contractors may have while conducting their work.

• Have you established designated work areas? Typically, equipment and building contractors will be assigned

to a designated area where pre-fabrication work is conducted. These areas should be properly cleaned and maintained to ensure they meet the facility’s expectations. Even outside work areas should be kept tidy and organized.

Often, long-term contractors will have a designated location where their trailers, trucks and mobile offices are located. It is important to keep these areas organized, to make sure materi-als are stored off the ground, and to keep break areas free of debris and trash to assist in the pest control efforts around the facility. You may consider periodic inspections of these areas to provide oversight and feedback to the contractors.

• Which areas inside the facility are contractors allowed? Contractorsshouldberestrictedtoonlytheareasofthefacility

necessary to perform their jobs. If a contractor is servicing the boilers in the boiler room, he should not be found wandering in the production or warehouse area.

• Does the work being performed have the potential to contaminate food or equipment?

If such work is being performed, set expectations about the precautions that must be taken to properly segregate their work. It may be necessary to provide temporary shields, tarps or other means to contain the dust and debris generated.

• What is the condition of tools and equipment the contrac-tors are using?

Contractorsmayneedtousetheirownforklifts,highlifts,gangor tool boxes, etc. These items should be cleaned and inspected beforeenteringthefacility.Forkliftsmayhavedirt,debrisorpest issues present from previous jobs. High lifts should be kept clean and the platforms free of debris to prevent it from falling off during work. Gang or tool boxes should be inspected prior to entering the facility to determine if they are free of unauthor-ized chemicals, that tools are relatively clean, and that there is no food, drink, tobacco, glass, etc. stored in them.

These questions can help you develop a complete program to manage the contractors in your facility. The food industry relies on contractors to maintain facilities and equipment and assist in daily activities. Are you confident that these activities are carried out in a safe manner that will not jeopardize your employees, product or brand? AIB

The author is Director, Food Defense, AIB International.

Safety and Training

Make sure you can identify the contractors operating in your plant. (Photo courtesy Ecolab.)

10 JULY/AUGUST 2008 AIB UPDATE