14 replies to this topic

[Simon]

Any contemporary thoughts on removing clothing prior to eating, drinking, visiiting the bathroom etc.specifically for FOOD PACKAGING MANUFACTURERS.

In version 4 of the BRC/IOP it is still not a requirement, but says something like:

"the supplier must determine by risk assessment where work-wear can be worn outside of production areas"
 
Any packaging companies out there now removing clothing prior to (all or some of the activities) eating, drinking, visiting the bathroom etc. or conducted a risk assessment that concluded it is not required...that was accepted by the certification body.  

 

You must be doing one or the other.

 

Regards,

Simon

[AndrewR]

I know that we insist on the removal of workwear when leaving the High/Low Care areas for any reason. The only exception is for a fire alarm at which time the workwear is not to be worn on returning to the relevant areas.

 

Protective footwear was the only issue in the event of a fire alarm but we have put in place a portable foot trough in to which we put a sanitiser for all High Care staff to stand in prior to their return in to the High Care area to reduce the risk of contamination.

 

We use disposable hair nets and gloves and they are replaced every time someone leaves and returns to the areas.

 

I would imagine all this is pretty standard though so not very 'contemporary'.  

[Simon]

Hi Andrew are you talking about food or packaging?

 

Regards,

Simon

[AndrewR]

My apologies, I mean Food, not Food Packaging.

[Simon]

I thought so.

Anyone else?

 

I guess the only way to justify not doing it is by validation, maybe daily inspections? some swabbing of overalls?

 

Regards,

Simon

[Charles.C]

Hi Simon,

 

i rather thought (and from [non-UK] observation) that it was almost an unwritten rule in packaging factories that workwear is never removed unless some one can validate a reason to do otherwise, eg functional necessities in some locations.

 

ie the validation is negative release. No news is good news.

 

Maybe this is another UK deviation of course.

 

Is there a UK packaging analog to the FSA ?

 

Rgds / Charles

[mgwartney]

US food regulations (9cfr416.5) require workers to remove clothing if it is contaminated or the possibility of contamination occurred. This is one area I have had issues with the GFSI, the regs not truly going along with regulatory requirements (whether US or UK).

[Simon]

As mentioned instead of mandating you must change prior to blah, blah, blah, BRC/IOP cops out and says:

 

"the supplier must determine by risk assessment where work-wear can be worn outside of production areas"

 

All that happens then is that businesses try to justify not changing, because there is a cost in terms of logistics and time...and time is money.

 

In actual fact I don't believe it can be allowed (not to remove workwear), especially in direct food contact packaging.  Even if you have lot's of policies on changing clothing when visibly dirty. having daily change of workwear, clothing inspections etc.  Still the risk remains if you eat, smoke or use the bathroom whilst wearing overalls and then go back and work with food packaging.

 

Regards,

Simon

 

[Rosemary4]

We currently have uniform of polo shirts, sweatshirts & trousers. Our guys wear them at break time/ comfort break time but if they go outside they have to wear an item of external clothing. In the new year (after the BRC audit!), we are changing to production operatives (in direct food contact packaging) wearing white coats. They will be given guidelines as to what can be worn underneath - no sequins, no shorts or bare legs etc - the coats will be hung up on their own peg (back to school time!) in a dedicated room. Before they start their shift they will put their personal stuff in their personal locker in the changing room, put their mobcap on & then go into the room & put the coat on. There will be a door leding to the Production Area only. This will become the entrance & exit door. If they go for a break they will remove the coat. The coat only leaves the room for laundering purposes.

[Simon]

Thanks Rosemary.

 

Regards,

Simon

[davidj3110]

We are seeing this same requirement driven by customers, not from our HACCP auditors. Essentially, our customers are seeking the same level of security at the direct contact packaging manufacturer as at their own premises. 

 

The Reason effect at work I guess.

 

David

[Simon]

Thanks for your input David.  

 

In food contact packaging I have concluded with the following risk assessment:

 

Warehouse (goods in and despatch) all product covered

LOW RISK - Clothing removal not required

 

Printing / slitting.  Reel to reel, not much exposure of food contact side and operators not touching product with hands or clothing

MEDIUM RISK - Clothing removal not required

 

Packing.  Product in direct contact with hands and indirect contact with workwear

HIGH RISK - Clothing removal required

 

The only other considerations, what about operators who enter the department for example store man bringing materials or printer bringing printed reels.  Well as the frequency is very low and they are not near exposed product.

LOW RISK - Clothing removal not required

 

And finally, engineers/maintenance operators who work in the Packing room, changing and setting tools, fixing machine problems. Any product touched by these operators is disposed of and there is a hygiene clean down and safe handover of machine following maintenance.
LOW RISK - Clothing removal not required

 

Any comments on this approach and conclusion.

 

Thanks,
Simon
 

[Tony-C]

Thanks for your input David.  

 

In food contact packaging I have concluded with the following risk assessment:

 

Warehouse (goods in and despatch) all product covered

LOW RISK - Clothing removal not required

 

Printing / slitting.  Reel to reel, not much exposure of food contact side and operators not touching product with hands or clothing

MEDIUM RISK - Clothing removal not required

 

Packing.  Product in direct contact with hands and indirect contact with workwear

HIGH RISK - Clothing removal required

 

The only other considerations, what about operators who enter the department for example store man bringing materials or printer bringing printed reels.  Well as the frequency is very low and they are not near exposed product.

LOW RISK - Clothing removal not required

 

And finally, engineers/maintenance operators who work in the Packing room, changing and setting tools, fixing machine problems. Any product touched by these operators is disposed of and there is a hygiene clean down and safe handover of machine following maintenance.
LOW RISK - Clothing removal not required

 

Any comments on this approach and conclusion.

 

Thanks,
Simon
 

 

Did you consider something falling off the clothing onto the packaging?

[Simon]

Did you consider something falling off the clothing onto the packaging?

 

Like crumbs. No not specifically, the close proximity of overalls with packaging in the high risk department is a no brainer, has to be done, even discounting food debris falling off clothing.  I don't see it making any difference to the other decisions.  But quite right to mention it as it strengthens the argument.

[Jim E.]

Just reading up on this topic and recent discussions with other people in our sister plants.  Seems to be quite a variance in what is required when it comes to work clothing rules.

          Example 1: all plant personnel wear smocks or coveralls in work areas which must be removed for lunchroom, smoke shack, or toilets. Does not matter what department you work in from raw receiving to shipping.

          Example 2: all plant personnel wear plant supplied pants and shirt for production, cleaned in house daily, but they can be worn into lunch room, smoke shack and toilets.

         Example 3: staff wear own clothes into processing and packaging no cover.

 

Now this is the same comapny making the same product, we are all BRC certified and HACCP recognized.  Example 3 plant has done risk assessments and find no issue and acceoted by 3rd party audits.  We are low risk producer and wonder if some plants have gone too far?

What do you think?