7 replies to this topic

[S Maddux]

I just got back from a 3 day BRC Preparation, Development, Implementation, and Internal Auditing training class. This was a very good class. The big thing I learned is the Guide book comes in handy, however as we all know issue 6 will not come out for a while. One big question I have that the trainer/BRC auditor couldn't answer was from Clause 4.8.4 and 4.8.5. In a high risk or high care area it says;

• Clear instructions for the order of changing into dedicated protective clothes to prevent the contamination of clean clothing.

My question is this, the trainer/BRC auditor said this means that everyone that goes into a high risk or high care area must change their cloth! At the plant I work at we don't change our clothes we have the employees change into colored smocks (cook room and fresh meat room). The smocks are long sleeve and go down to about the knees. They also wear rubber boots. I take it the way it is worded "changing into dedicated protective clothes" which is what a smock is. The part that gets me is the rest of the bullet point "to prevent the contamination of clean clothing." This is a little confusing. So can we continue to use smocks to cover our "street clothes" or is this telling me we need to have work clothes for all our employees and a place for them to change? Thank for the help.

[qsa]

Agree with the trainer/BRC auditor in the aspect of "must change their clothes".
Don't see an issue with the change into smocks by your plant employees as meeting "dedicated clothing" requirement so long as they cover "street clothing".

With regard to "to prevent the contamination of clean clothing", yes there is validity to it from a cross contamination prevention requirement and hence the reason for "order of changing" and the "specially designated changing facility at entrance" requirements to be placed.

One thing not clear in your post is if the rubber boots are changed or not?
Not changing them at this point could potentially lead to cross contamination into the high risk area from staff facility areas / traffic pathways.
If they are changed, then this is where the "order of changing" becomes essential to prevent transfer of contaminants from footwear used outside of high care area, onto "clean dedicated clothing" or into the high care area.
4.8.5 states "dedicated footwear shall be provided to be worn in the high risk area". We translate this as shall not be worn outside of the high care area.

Sorry to be a bit longwinded above. For your original question and IMO, YES, your employees are required to have "dedicated protective clothing" and a specially designated changing facility". for a high care area.

Our practices / procedure include dedicated footwear being the last item placed on prior to washing hands after bench system where dedicated clothes are put on within a designated changing facility. We have been compliant to requirements within 4.8 for quite a while due to prevention of product contamination risks.

Greg

[Mark Munro]

I just got back from a 3 day BRC Preparation, Development, Implementation, and Internal Auditing training class. This was a very good class. The big thing I learned is the Guide book comes in handy, however as we all know issue 6 will not come out for a while. One big question I have that the trainer/BRC auditor couldn't answer was from Clause 4.8.4 and 4.8.5. In a high risk or high care area it says;

• Clear instructions for the order of changing into dedicated protective clothes to prevent the contamination of clean clothing.

My question is this, the trainer/BRC auditor said this means that everyone that goes into a high risk or high care area must change their cloth! At the plant I work at we don't change our clothes we have the employees change into colored smocks (cook room and fresh meat room). The smocks are long sleeve and go down to about the knees. They also wear rubber boots. I take it the way it is worded "changing into dedicated protective clothes" which is what a smock is. The part that gets me is the rest of the bullet point "to prevent the contamination of clean clothing." This is a little confusing. So can we continue to use smocks to cover our "street clothes" or is this telling me we need to have work clothes for all our employees and a place for them to change? Thank for the help.

The way I read the clause is that they are looking for a step by step procedure on how a person goes about entering the high risk/ high care area. We had to do this to meet M&S reequirements last year even though we are a low risk primary processor of salmon. Goes something like this:

• Remove out door footwear and coats and place in locker.
• Put on hair net (and beard net if required).
• Apply hand sanitiser.
• Cross over bench/ barrier and put on boilersuit.
• Collect boots from rack and cross over second bench/ barrier then put boots on.
• put on waterproof overalls.
• Wash hands.
• Put on gloves.
• Apply sanitising gel to gloves.
• Enter production area through boot wash.

Then you will probably need a procedure for when they come out which runs sort of in reverse to the above. We did it with photos incorporated into it to help with foriegn workers. So it is basically a detailed, step by step, instruction of how to put on the protective clothing in a way that will not contaminate the clothing before they enter the work place. In high care/ high risk you may need to add in hand washing prior to putting on the smock as well. Seems like BRC coming more into line with likes of M&S on some things. They will be looking for segregation, such as phsical cross over bench/ barriers, for certain stages so some one cannot just walk straight into where the clean smocks are with outdoor clothing on.

Needless to say once it has been drawn up all the staff will have to be trained against it and sign off to say they have been taught it. Our QA manager did a full run through demonstration for all the workers.

Hope this is of help.

[Charles.C]

Dear All,

One can see that the potential increase in high care/high risk areas may lead to various queries.

As an illustration of some of the points in the nice previous post, here is one possible layout and associated personnel instructions. Most steps sort of agree with previous post but not all, eg bootwashing (fear of increased risk of xcontamination).I suspect Mark's "boot" version is the more typical in practice.

 low-high risk transition hygiene.png   118.81KB   250 downloads
 low-high risk transition hygiene (2).png   60.48KB   228 downloads

Rgds / Charles.C

[S Maddux]

I truly appreciate the help but I'm still a little confused.

qsa said Agree with the trainer/BRC auditor in the aspect of "must change their clothes".
Don't see an issue with the change into smocks by your plant employees as meeting "dedicated clothing" requirement so long as they cover "street clothing".
My quesiton is do they need to change their cloths or is wearing a smock over the street cloths acceptable for working in a high risk area?

As for the boots, our team members wear their boots all over the plant, however we do have automatic boot washers they must use before entering a processing room. What I'm understanding is that will have to stop and we will need to build dedicated smock/boot/hand washing rooms before entering the high risk processing area. And this room MUST have segratgation from one step to the other so not to cross contaminate.

Again I see Mark mentioning: They will be looking for segregation, such as phsical cross over bench/ barriers, for certain stages so some one cannot just walk straight into where the clean smocks are with outdoor clothing on.

This has be thinking we must change cloths and that we can not just use a smock to cover out street clothes.

Thank you all for the help. This web site is so helpful.

[trubertq]

I truly appreciate the help but I'm still a little confused.

qsa said Agree with the trainer/BRC auditor in the aspect of "must change their clothes".
Don't see an issue with the change into smocks by your plant employees as meeting "dedicated clothing" requirement so long as they cover "street clothing".
My quesiton is do they need to change their cloths or is wearing a smock over the street cloths acceptable for working in a high risk area?

As for the boots, our team members wear their boots all over the plant, however we do have automatic boot washers they must use before entering a processing room. What I'm understanding is that will have to stop and we will need to build dedicated smock/boot/hand washing rooms before entering the high risk processing area. And this room MUST have segratgation from one step to the other so not to cross contaminate.

Again I see Mark mentioning: They will be looking for segregation, such as phsical cross over bench/ barriers, for certain stages so some one cannot just walk straight into where the clean smocks are with outdoor clothing on.

This has be thinking we must change cloths and that we can not just use a smock to cover out street clothes.

Thank you all for the help. This web site is so helpful.

My understanding is that... the outer coat has to come off in a separate area, and is stored along with their personal belongings, like handbags etc....
They proceed to the high risk changing area where they put on the mob caps, beard snoods.........put on white coats, boots, aprons, sleeve covers or whatever, then ..wash hands and sanitise before going into production area. Obviously if they have just come from the toilet they will have washed their hands already but they must wash again after robing and before entering the food production area.
Having a whole change of clothes ain't gonna happen where I work!! The advice I have been given is operators clothing is covered from neck to knee.. oh and boots not taken outside the high risk changing area.


Trudy

[GMO]

I truly appreciate the help but I'm still a little confused.

qsa said Agree with the trainer/BRC auditor in the aspect of "must change their clothes".
Don't see an issue with the change into smocks by your plant employees as meeting "dedicated clothing" requirement so long as they cover "street clothing".
My quesiton is do they need to change their cloths or is wearing a smock over the street cloths acceptable for working in a high risk area?

As for the boots, our team members wear their boots all over the plant, however we do have automatic boot washers they must use before entering a processing room. What I'm understanding is that will have to stop and we will need to build dedicated smock/boot/hand washing rooms before entering the high risk processing area. And this room MUST have segratgation from one step to the other so not to cross contaminate.

Again I see Mark mentioning: They will be looking for segregation, such as phsical cross over bench/ barriers, for certain stages so some one cannot just walk straight into where the clean smocks are with outdoor clothing on.

This has be thinking we must change cloths and that we can not just use a smock to cover out street clothes.

Thank you all for the help. This web site is so helpful.

Yes, it is normally considered to be fine to wear a full long sleaved coat over normal clothing.

You don't necessarily need separate rooms. This is 'normal' practice for entering a high care or high risk area:

One side of a barrier, you will have lockers for personal items where outdoor coats etc are stored and outdoor shoes. In this area, you would put on a mob cap and beard snood if necessary. You would then swing your legs over a low barrier.

Then you would pick up your high care / high risk captive boots or shoes. Put them on.

At this point you then need to wash and sanitise your hands. This hand wash step is to protect the clean coat from contamination.

You then put on your clean coat. Then you wash and sanitise your hands again (this second hand wash can be at the entrance of the production room if you like). This second hand wash is to protect the product.

It's not realistic and not safe to expect a full clothing change. The reason for this is it's impractical; do people really get changed all the time from underwear up if they're popping out for one thing? No! The second reason is you cannot put trousers or a boiler suit on hygienically. They always drag on the floor to some degree. Therefore a long sleeved, knee length (or longer) coat is often the best idea from a hygiene point of view and used in high risk factories in many places I've worked in.

You can if you like issue work trousers to staff but they should not constitute part of the hygienic workwear for high risk / high care staff (fine for low risk).

[PAL]

At this point you then need to wash and sanitise your hands. This hand wash step is to protect the clean coat from contamination.

You then put on your clean coat. Then you wash and sanitise your hands again (this second hand wash can be at the entrance of the production room if you like). This second hand wash is to protect the product."

 

 

I'm looking for more motivation for the second hand wash step. This is also described by a retail standard (Tesco).

In my opinion the step between the first en second hand wash step is verry close to each other (when this 2nd step is also in the chaning area).

 

Would like to hear what the reason is behind this second step ?

 

PAL

Edited by PAL, 23 October 2013 - 07:52 AM.