AIB Answers

Q.  We use several contractors throughout the year for various tasks. What are the main items we should consider to ensure they understand our food safety and food defense rules?

A. Contractors are used by most food companies and are a valuable asset. However, contractors can present a risk if they are not provided with a sufficient level of training and education for your food safety and food defense policies. There are other topics that also need to be addressed with contractors depending on the job, including safety, evacuation, lockout/tagout, hot work permits, etc.

The specific type of training/education provided will depend on their level of access in your facility, proximity to product zones and areas, oversight by company personnel, etc. Most companies do a good job of covering the basic personnel GMP rules (e.g., jewelry, hairnets, hand washing, food and drink, etc.). However, your GMP/food safety training needs should go beyond the basics. If a contractor will be working in production areas, the training should be much more detailed to include other topics, such as:

• Glass and Brittle Plastics – Contractors may bring in their own work lights, trouble lights, chemicals in glass containers, glass fuses, etc. They need to understand that most of these items are not acceptable in a food plant.
• Chemicals – Contractors should understand they need to report any chemicals they need to use. These should be approved by the facility, Safety Data Sheets should be obtained, and chemicals should be controlled and secured when unattended.
• Color Coding – Most facilities color code utensils, containers, tools, etc. Have you provided your contractor with designated containers to collect their waste, debris, drill filings, etc.? Do they know not to use your white buckets and brushes for any purposes?
• Food Defense/Security – Do your contractors know which areas of the facility are restricted and in which they are allowed? How do they access doors to go to outside work areas or to their vehicles to collect tools? Do they understand they are not authorized to let anyone into the facility or prop doors open? Do they park in designated locations and keep their vehicles secure to prevent theft of tools or chemicals?
   

These are just a few examples of additional training that contractors may need. It is up to you to determine your specific training topics.

It is also important to determine if contractors fully understood the training provided. How do you assess your contractors? Some of the best contractor training programs I have seen include sending a copy of your rules to review in advance. When they arrive you can do abbreviated training or have a short orientation video.

Keep in contact with your contractors. Do they have a designated contact person to whom they report each day? Does someone review their work areas on a regular basis to ensure they are kept clean and organized? Does anyone inspect the condition and cleanliness of their tools, ladders, tool boxes, etc. before they are brought into the facility? A little bit of oversight can go a long way and help remind contractors to keep clean, organized, safe, and secure.

Do you have a question for Lance Reeve? If so, e-mail him at lreeve@aibonline.org