[AIB Safety and Training] Contractors in the Food Industry

You 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 following 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 containers 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 surgical instruments that were washed in the hydraulic fluid instead of the intended detergent.

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:

• Welding and grinding in the warehouse near pallets of products with no protection between the pallets and work area
• Carrying items, such as tools, pens, etc., in shirt pockets
• Propping open doors that led into the facility from outside
• Cutting PVC pipes in a packaging room and not containing the dust from the saw
• Filing PVC pipes on top of product totes
• Storing non-food-grade chemicals in production rooms next to packaging and food items
• Using finished product containers as trash containers in production 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, it was rather limited and covered only basic GMPs, such as hand washing, jewelry and hair net policies. It was evident that this training 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. Upon arrival, I had to check-in at the security guardhouse before entering 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.

Go beyond the basic GMPs to include food safety, food defense and occupational safety rules that may affect their actions. Consider the following questions when designing or evaluating your contractor training program:

• 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?
  
  Contractors should be required to provide government and 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 persons within the operation and know if they are approved.
  
• What are contractor clothing requirements?
  
  If your operation requires all employees to change into uniforms 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 materials 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?
  
  Contractors should be restricted to only the areas of the facility 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 contractors are using?
  
  Contractors may need to use their own forklifts, high lifts, gang or tool boxes, etc. These items should be cleaned and inspected before entering the facility. Forklifts may have dirt, debris or pest 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 unauthorized 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?

The author is Director, Food Defense, AIB International.