The FSMA Requirement (21 CFR ยง117.10): Management must take all reasonable measures to ensure that no person affected by disease or illness works in any capacity where they could contaminate food. This includes a legal mandate to follow hygienic practices, such as maintaining personal cleanliness and wearing appropriate, clean outer garments.
Recommended Solution & Expert-Level Pitfall:
- The Solution: Go beyond the breakroom poster. Your hygiene program must be a clearly documented, verifiable system. This includes a written policy that explicitly instructs employees to report specific symptoms (e.g., vomiting, diarrhea, jaundice). It also means implementing a “return to work” procedure that requires clearance (e.g., symptom-free for 24 hours) before a sick employee can handle food.
- The Pitfall to Avoid: A weak “food safety culture.” Many violations stem from employees feeling pressured to work while sick or cutting corners on glove-use policies. Your solution must include robust training, demonstrated management buy-in, and a non-punitive culture where reporting illness is encouraged and supported.
