19 replies to this topic

[jaredk]

Is there a specific uniform policy for the BRC? Should all employees be required to change into their uniforms when they get into the plant in segregated changing stations or locker rooms? Should a cleaning policy be developed for cleaning of the uniforms rather than just stateing that all employees should wear clean clothes to work?

[tsmith7858]

Is there a specific uniform policy for the BRC? Should all employees be required to change into their uniforms when they get into the plant in segregated changing stations or locker rooms? Should a cleaning policy be developed for cleaning of the uniforms rather than just stateing that all employees should wear clean clothes to work?

The level of uniform needs vary greatly depending on what you are producing. Can you give some detail of your processes?

BRC states that the use of uniforms shall be based on risk assessment considering high risk and low risk areas. Changing areas are the same. As for laundering, it must meet whatever criteria is established based on risk assessment whether done in house or by outside services.

[jaredk]

We produce cookies so we have some elmployees working with raw materials and some that work with the finished product.

There was also another issue that was brought up. If there were employees working one a line producing one type of product and got transfered to another line that was producing another type of product, there would be cross contamination issues. Is this a nonconformance according to BRC?

Also, would it be an issue if the employees were to wash their own uniforms?

[GMO]

We produce cookies so we have some elmployees working with raw materials and some that work with the finished product.

There was also another issue that was brought up. If there were employees working one a line producing one type of product and got transfered to another line that was producing another type of product, there would be cross contamination issues. Is this a nonconformance according to BRC?

Also, would it be an issue if the employees were to wash their own uniforms?

With BRC the emphasis is on risk assessment. They want to see you've considered the risks and controlled them accordingly.

For me I'd want to see you'd considered the risk of allergen cross contamination and; if you consider there is a risk, you may decide to use disposable aprons, oversleeves and gloves in distinctive colours and also warn the consumer on the packing (obviously putting all that into a procedure).

On washing their own uniforms, again risk assess but my gut feel is it would be a tough one to get a BRC auditor to approve as there is little control. How do you know people are washing their uniforms at high temperatures like you'd get in an industrial laundry or are they just washing at 40oC and using nice smelly fabric softeners tainting your product?

Also personally I would recommend that ideally you have full physical segregation between raw and cooked cookie dough and have visually distinctive clothing for each area due to the risks of micro cross contamination; particularly Salmonellae and I would at least expect to see some kind of risk assessment on the raw / cooked cross contamination risks not just the risks between products.

[jaredk]

Thanks a lot for your answers and tips. They are very helpful with our implementation of BRC.

I just thought of another issue with our uniform policy that might cause a problem for us. We do not have an actual locker room for changing, it's more like part of the plant that is sectioned off with lockers. Would be worth the time and money to put up a wall and segregate the locker room and make the employees change into their uniforms when they get to work?

[GMO]

Thanks a lot for your answers and tips. They are very helpful with our implementation of BRC.

I just thought of another issue with our uniform policy that might cause a problem for us. We do not have an actual locker room for changing, it's more like part of the plant that is sectioned off with lockers. Would be worth the time and money to put up a wall and segregate the locker room and make the employees change into their uniforms when they get to work?

I'm guessing from your descriptions that it's a small site? To be pragmatic; perhaps it would be a good idea to review what you're asking them to wear before building walls. I'm guessing from your description, the team are changing fully. I would question, is that necessary? Most high risk food manufacturers I know use long sleeved coats which are at least knee length and fully cover the person's clothing. This has the benefit that it can be put on hygienically (you can't hygienically put on trousers as they drag on the floor) and also can be easily removed for breaks etc. You could still provide other workwear if you want to but it would be the coat which is the "hygienic" workwear.

Also it's good practice to have a gowning procedure; this is to minimise the risk of hair contamination and ensure hands are clean. This is what I'd expect ideally for a RTE plant but in practice this level of control is only normally in place in chilled factories.

Remove outside clothing where necessary (e.g. coats) and hang in a dedicated area (eg a coat rack or dedicated locker)
If you have dedicated footwear for the area, remove outside footwear
Put on mobcap
You may chose to have a physical barrier into the production area like a bench; in which case swing your legs over the bench
Put on your dedicated footwear (if used)
Wash hands with soap and sanitiser
Dry hands thoroughly
Put on dedicated coat for production area
Wash hands again (or just use sanitiser; you can decide on the risk here)
Enter production area

[StephB]

Hi JaredK,
Where I used to work we were BRC certified, we ran apples, not cut or sliced, pretty low risk, we had to have a laundry room, they did not allow them to be taken home, we had an area sounding similar to yours, we had hooks for the employees to hang thier smocks and aprons, we painted a 6" yellow line to show them the area that they had to change in, of course their coats and personal belongings had to be put in the locker area away from the work attire. The line to show the changing area was approved. Just something to think about, of course we were low risk also.

[Charles.C]

Dear jaredk,

You need HACCP for BRC.

Most of the questions you are asking seem to be basic GMP issues which would be fundamental stuff for HACCP. especially for a RTE product.

Do you have an approved HACCP system yet ?

Rgds / Charles.C

[jaredk]

We do have a HACCP system but we were unsure on how strict the BRC would be in regards to our uniform policy since really the only requirement we have is that employees wear white shirts and pants, and of course hair and beard nets. These were a few thoughts that I was told to look further into and I knew that there was a lot of good answers here so I decided to give it a shot.

[Charles.C]

Dear jaredk,

fair enough

I hope you hv a copy of BRC as well.

Rgds / Charles.C

[Chzwhz]

Good Morning,

I browse these forums quite often and enjoy reading the discussions. I am dealing with a similar issue in my facility. We are a cheese manufacturer and my issue is mainly what procedure should be followed when employees are going to break. We have laundered uniforms. We have good sanitation practices upon entering from break. We do not have employees wearing smocks or any other protection other than the uniforms provided. I feel the only risk involved is the potential of contamination on break. I am thinking that instead of making my employees wear smocks in the production that we have them wear smocks while they are on break. Does that make sense?
We are currently working towards BRC certification.

Thanks

[GMO]

I see what you mean but IMO it's not a good solution because it's not only breaktimes but toilet trips that need to prevent contamination.

I'd be interested to hear what other peoples opinions are on this because having worked in cheese packing, we had removable coats (as I said earlier in the thread a few months back) and IMO this is the best option, however, I know it's not common in low risk manufacture (but then I would argue cheese is not low risk.)

[Dr Ajay Shah]

I am of the opinion that uniforms must be removed during break times and when going to visit the toilets to prevent contamination. I

f people were wearing uniforms at break with smocks, and if they were consuming food with soy sauce for example, the soy sauce may accidentally fall on the smock and get transferred onto the uniform clothing. As we all know that soy sauce is an allergen as it contains soy. This is just one example that I am using here to demonstrate possible allergen contamination that can occur. I hope this helps.

Regards

Ajay

[jaredkkrischel]

Hello everyone,

What about requiring employees to wear aprons while in production areas and not allowing them to wear them in breakrooms or restrooms?

[Charles Chew]

Hello everyone,

What about requiring employees to wear aprons while in production areas and not allowing them to wear them in breakrooms or restrooms?

If risk base assessment (i.e. direct food contact surface) is applied, I would like to think that if apron is your key uniform which is not taken out of the production areas during breaks, I personally do not see any problem with this approach. Furthermore, the aprons (as a primary uniform attire) covers the (secondary attire) which is probably home laundered.

Like to hear the views of other forum members esp. BRC auditors on why this should not be acceptable alternative approach.

[jaredkkrischel]

FYI, employees wear white shirts and pants with aprons over top. The employees wash their own clothes and wear them to work.

Does anyone else have thoughts or recommendations regarding the apron policy proposed above?

[JamesMadsen]

I have a similar question, but different. We are a sliced meat and cheese RTE facility. Our "Production Rooms" are the only place product is exposed/processed. We require all PPE, smocks, hairnets/beard nets, aprons, sleeves and over shoes. The products pass through a window to the Pack Off area, fully packaged. We currently require Burgundy smocks in all areas except the Process rooms. Before employees enter a process room, they remove the Burgundy smocks and put on a different color smock and visa versa when leaving the Productiion rooms. My questions is, based on low risk of packaged product and travel through out the plant being low risk, do I really need the Burgundy smocks in all areas? Wouldn't it be enough to require employees to follow all GMP's, PPE, washing / sanitizing hands etc, but not wear the Burgundy smocks in the Pack Off Area or travel to and from other areas? The cost of the Burgundy smocks for 300 people daily is painful. We would still require the employees that load the RTE material into the production rooms to wear Burgundy smocks. I appreciate any insight you can give.

[JamesMadsen]

I.E. this means that employees would be traveling in their street clothes. Remeber they would be donning smocks to go into Production Rooms, accessed through a enclosed vestibule.

I have a similar question, but different. We are a sliced meat and cheese RTE facility. Our "Production Rooms" are the only place product is exposed/processed. We require all PPE, smocks, hairnets/beard nets, aprons, sleeves and over shoes. The products pass through a window to the Pack Off area, fully packaged. We currently require Burgundy smocks in all areas except the Process rooms. Before employees enter a process room, they remove the Burgundy smocks and put on a different color smock and visa versa when leaving the Productiion rooms. My questions is, based on low risk of packaged product and travel through out the plant being low risk, do I really need the Burgundy smocks in all areas? Wouldn't it be enough to require employees to follow all GMP's, PPE, washing / sanitizing hands etc, but not wear the Burgundy smocks in the Pack Off Area or travel to and from other areas? The cost of the Burgundy smocks for 300 people daily is painful. We would still require the employees that load the RTE material into the production rooms to wear Burgundy smocks. I appreciate any insight you can give.

[catherinepc]

Hi all ! 

I came across this topic and recently there is a customer audit at our plant. 

They issue us a minor CAR  because our production staff does not cover their hand and there is a potential of hair contamination.

For your information, we are a food flavouring manufacturing company. Is it compulsory to wear long sleeves ? I don't think it is a high risk process. 

 

Looking for advice. 

 

Thank you. 

[NicholasChai]

Dear Catherine,

 

Hi all ! 

I came across this topic and recently there is a customer audit at our plant. 

They issue us a minor CAR  because our production staff does not cover their hand and there is a potential of hair contamination.

For your information, we are a food flavouring manufacturing company. Is it compulsory to wear long sleeves ? I don't think it is a high risk process. 

 

Looking for advice. 

 

Thank you. 

Hi Catherine, I believe you will have to ensure that your operators wear long sleeves, as hand hair can be a form of physical contamination towards the product. Unless your product does not require operators to handle any products directly(eg. machine operated,automated transfer etc.) or else long sleeves will be best practice.