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#1 mherranz

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Posted 06 October 2016 - 10:01 AM

Hello Everybody

 

My name is Miriam and I need same help, please

 

I am woking in a Bakery Industrie and the auditor said me I must do a risk assesstment to justify that the clothes are cleaning by our employees.

 

Somebody shall help me??'

 

Thanks a lot

 

Miriam


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#2 Gerard H.

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Posted 06 October 2016 - 11:54 AM

Dear Miriam,

Herewith you receive some ideas to perform the risk assessment. It may also be a hint from the auditor to think about the process :

  • The risk assessment shall be carried out against the "home" wash instruction that each employee has signed off.
  • You carry out the risk assessment based on HACCP principles. So will there be dangers by "home" washed clothes worn by employees, that may become a risk to the final product. (Microbiological, Chemical, Physical, Allergen).
  • As you probably know, for BRC High risk/care areas, there are specific requirements on the clothes.

I hope to have informed you sufficiently. In case of further questions, please don't hesitate to contact me.

 

Kind regards,

 

Gerard Heerkens


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#3 Charles.C

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Posted 06 October 2016 - 02:13 PM

Hello Everybody

 

My name is Miriam and I need same help, please

 

I am woking in a Bakery Industrie and the auditor said me I must do a risk assesstment to justify that the clothes are cleaning by our employees.

 

Somebody shall help me??'

 

Thanks a lot

 

Miriam

 

Hi Miriam,

 

Unfortunately there are not so many IFS users on this Forum. It is not so unusual that different Standards may have their own idiosyncratic requirements and, based on previous threads here, IFS does have some self-determined  expectations.

 

Assuming IFS version6 is current (?) (I am not a user) the relevant clauses and instructions to auditors seem to be as per attachment below.

 

Attached File  ifs clothing requirements.png   70.82KB   6 downloads

 

Perhaps you could inform as to the details of yr current laundering procedure ? (I assume yr business is primarily RTE products but are they classified as Low or High Risk by IFS ?)

 

Did the auditor have any specific criticism ?


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Kind Regards,

 

Charles.C


#4 mherranz

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Posted 06 October 2016 - 03:52 PM

Thank you everybody for your help.

 

The auditor didn't say exactly what `s the problem. He said  the decision about not use a laundry for work clothes are not consider in risk assessment.

 

I was thinking to include it in APPCC as a risk in places where the product isn´t packaged- contamination with work clothes (physical, chemical and microbiological) and consider probability and severity to  justify it. 

 

What do you think??? Could be enough???

 

Kind regards

 

Miriam


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#5 Charles.C

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Posted 06 October 2016 - 08:09 PM

Hi Miriam,

 

I deduce you are not using a Laundry. This tends to worry Auditors.

 

I have no practical experience of IFS but you might like to see my attempt to (Risk analysis) respond to a similar IFS clause about hand hygiene -

 

http://www.ifsqn.com...isk-assessment/

 

Maybe some helpful IFS user will see yr query soon and offer a tested solution. Hope so.


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Charles.C


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#6 Charles.C

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Posted 06 October 2016 - 11:28 PM

addendum

 

It is possible that IFS implicitly adhere to a BRC-type Risk-based philosophy with respect to Laundering of clothing. For example from BRC7 -

 

 

Laundering of protective clothing shall take place by an approved contracted or in-house laundry

using defined criteria to validate the effectiveness of the laundering process. The laundry must operate

procedures which ensure –

---------------

-----------------

protective clothing for high-risk or high-care areas is commercially sterile following the washing and

drying process

------------------

 

Washing of protective clothing by the employee is exceptional but shall be acceptable where the

protective clothing is to protect the employee from the products handled and the clothing is worn in

enclosed product or low-risk areas only.

 

Where protective clothing for high-care or high-risk areas is cleaned by a contracted or in-house

laundry, this shall be audited either directly or by a third party. The frequency of these audits should be

based on risk.

 

Protective clothing shall be changed at an appropriate frequency, based on risk. For high-risk and

high-care areas the protective clothing shall be changed at least daily

 

 

Just a thought.

(Traditional haccp for RTE finished products tends to regard stages prior to a pathogen elimination stage [eg cooking] as Low Risk and subsequent ones involving non-enclosed goods as High Risk from a micro. contamination POV although there are some (BRC) caveats with respect to baking)


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Charles.C


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#7 Charles.C

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Posted 07 October 2016 - 04:01 AM

addendum 2

 

Again, assuming you do not presently use a Laundry, you can, by risk assessment, demonstrate the validity  of your current choice versus, say, using a Laundry.

 

I suggest a logical approach is to construct a simple 3x3 matrix based on the probability (P) of the laundering  procedure failing (and thereby generating a hazard of micro. contamination) versus the consequence (severity)(S) of such an event. The two together giving a Risk = (P x S).

I suggest that the probability could be Medium (to be based on micro. evaluation after laundering).

This probability would then be associated with the severity at the various stages in yr process.

As an example, I suggest that the outcome severity in a Post-baking handling stage might be High so that the combination of (P x S) would yield a significant risk.

Such a result would invalidate yr choice not to use a laundry if the latter’s probability of failing were (validatably) Low thereby yielding a non-significant risk.

 

Alternatively, if you are determined to not use a laundry, it will be necessary to demonstrate that a suitable improvement (ie reducing the probability of failure) can be implemented and validated.

 

If necessary, a scale of frequencies of subsequent micro. testing  could be associated with a specific L/M/H risk result.

 

Of course any  actual result will depend on your (validatable) choice of  Probability/Severity.

 

I recommend  you watch the webinar on Oct 14th on the topic of risk assessment which I anticipate will discuss  risk assessment techniques such as above for some GMP-type activities.

 

PS - you can see a generalised matrix presentation of the above in the attachment in post below although some of the details got a bit confused -

 

http://www.ifsqn.com...ts/#entry102047


Edited by Charles.C, 07 October 2016 - 09:03 AM.
edited webinar date !

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Kind Regards,

 

Charles.C


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#8 Simon

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Posted 07 October 2016 - 06:09 AM

Home laundering is allowed, but not often done as it requires a lot of additional documented procedures on how employees should do it and also checks/tests that they have done it effectively...therefore it is much easier to outsource to a professional laundry that can handle hygienic workwear.  Then you only need specifications, supplier approval and controls and perhaps some copies of their testing results.  That said in my experience of laundries they are very poor in terms of service and quality of wash (stains/smells) and poor ironing.  I am sure with proper risk assessment and controls home wash could be better. 

 

Good luck.

 

Regards,

Simon


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#9 mherranz

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Posted 07 October 2016 - 11:35 AM

Hi,

 

Thank you everybody for your ideas. I'm so grateful. Finally I did it using your indications and I've just send it to my auditor. 

 

In one week I will tell you his opinion

 

Kind regards

 

Miriam


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#10 FurFarmandFork

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Posted 07 October 2016 - 10:34 PM

Clothing is tough, and I can appreciate an auditor thinking that home-washing PPE or other production clothing would be a weak point in verification. That being said, they're appropriate in asking for a risk assessment to either justify your current practice with no change or have a real evaluation of whether it puts your product at risk.

 

Depending on the size of your establishment, it may be worth considering including laundry on-site or having a service pick it up. Otherwise you might end up in a situation where you're asked to inspect clothing prior to startup, which is always awkward, followed by potentially sending someone home for not appropriately laundering their equipment, to which your corrective action is now..have them take it home and launder it? It puts you in a poor position for both corrective action and subsequently makes you less likely to enforce it.

 

A risk assessment for clothing will focus on three things, foreign material, allergens, and biological hazards. Foreign material ultimately comes back to inspection on clothing condition, and you can't get away from that. Allergens, depending on what products you run, could also be easy if you have a single allergen facility, but really hard if you don't. Biological hazards come down to frequency of cleaning, working with visible clean (and dry) clothing, and determining how much contact with clothing you tend to see on the line.

 

Make sure you use your risk assessment as an opportunity to truly evaluate your current process, either in favor or to drive a change in procedure.


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For discussions related to food safety, production, and agriculture. Check out my blog at http://furfarmandfork.com/.

 


#11 Charles.C

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Posted 08 October 2016 - 04:04 AM

Clothing is tough, and I can appreciate an auditor thinking that home-washing PPE or other production clothing would be a weak point in verification. That being said, they're appropriate in asking for a risk assessment to either justify your current practice with no change or have a real evaluation of whether it puts your product at risk.

 

Depending on the size of your establishment, it may be worth considering including laundry on-site or having a service pick it up. Otherwise you might end up in a situation where you're asked to inspect clothing prior to startup, which is always awkward, followed by potentially sending someone home for not appropriately laundering their equipment, to which your corrective action is now..have them take it home and launder it? It puts you in a poor position for both corrective action and subsequently makes you less likely to enforce it.

 

A risk assessment for clothing will focus on three things, foreign material, allergens, and biological hazards. Foreign material ultimately comes back to inspection on clothing condition, and you can't get away from that. Allergens, depending on what products you run, could also be easy if you have a single allergen facility, but really hard if you don't. Biological hazards come down to frequency of cleaning, working with visible clean (and dry) clothing, and determining how much contact with clothing you tend to see on the line.

 

Make sure you use your risk assessment as an opportunity to truly evaluate your current process, either in favor or to drive a change in procedure.

 

Hi Earth,

 

I agree with yr practical caveats but in practice, the expected auditorial validation often seems a bit simpler than you suggest. Typically a few random swab tests for APC and maybe Coliform/E.coli.

The home results may well be rapidly disillusioning of course. :smile:


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Charles.C


#12 Tony-C

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Posted 08 October 2016 - 04:33 AM

I think that the key here is if the products are RTE and exposed at some stage.

 

BRC guidelines state - Home laundering may be deemed acceptable in low-risk operations such as produce packing or enclosed process areas where the clothing is worn primarily to protect the worker from the product (e.g. raw root vegetables). IFS is more flexible but I do fail to see how home laundry would be deemed acceptable for a RTE product.

 

Kind regards,

 

Tony


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#13 Charles.C

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Posted 08 October 2016 - 04:44 AM

I think that the key here is if the products are RTE and exposed at some stage.

 

BRC guidelines state - Home laundering may be deemed acceptable in low-risk operations such as produce packing or enclosed process areas where the clothing is worn primarily to protect the worker from the product (e.g. raw root vegetables). IFS is more flexible but I do fail to see how home laundry would be deemed acceptable for a RTE product.

 

Kind regards,

 

Tony

 

Hi Tony,

 

I guess it might also relate to the fact that many Bakery RTE products are seemingly classified as low risk. For BRC also from memory.


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Charles.C


#14 Tony-C

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Posted 08 October 2016 - 05:21 AM

Hi Tony,

 

I guess it might also relate to the fact that many Bakery RTE products are seemingly classified as low risk. For BRC also from memory.

 

Hi Charles,

 

The products could well be classified as low risk depending on the additions.

 

BRC 7.4.3

Laundering of protective clothing shall take place by an approved contracted or in-house laundry using defined criteria to validate the effectiveness of the laundering process......
Washing of protective clothing by the employee is exceptional but shall be acceptable where the protective clothing is to protect the employee from the products handled and the clothing is worn in enclosed product or low-risk areas only.

 

Kind regards,

 

Tony


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#15 Charles.C

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Posted 08 October 2016 - 05:27 AM

Hi Tony,

 

Yes, see the quote in Post 6.

 

This category is seemingly in specified cases one of the BRC "exceptions" as detailed in their F0 document.. From memory again.

 

But IFS no idea.


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Charles.C


#16 Tony-C

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Posted 08 October 2016 - 04:01 PM

Hi Tony,

 

Yes, see the quote in Post 6.

 

This category is seemingly in specified cases one of the BRC "exceptions" as detailed in their F0 document.. From memory again.

 

But IFS no idea.

 

Hi Charles,

 

I'd prefer if you can quote an exact reference rather 'From memory again' as I refuse to believe that BRC would advocate that home laundry is acceptable for food processors unless it is to offer protection to the workers.

 

Kind regards,

 

Tony


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#17 Charles.C

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Posted 08 October 2016 - 11:41 PM

OT IFS

 

Hi Tony,

 

The file is in these posts -

 

http://www.ifsqn.com...ndpost&p=103992

http://www.ifsqn.com...indpost&p=98962

http://www.ifsqn.com...indpost&p=91250

http://www.ifsqn.com...indpost&p=60177

 

14 Bakery

High risk or high care production zones are not applicable for products in this category.

Note chilled bakery products such as cream cakes, egg custards, cheesecake are in category 10.

 

10 Ready Meals

All products in this category will require either high risk or high care environment for the preparation and packing of finished products.

 

Interpretations/Deductions based on the above may of course vary. It is admittedly difficult to see why a worker would need to be protected from attack by a loaf of bread.

 

Regardless, IFS seem to not evidence concern over such philosophical niceties and appear to merely require a "risk assessment". However from memory of (at least one) previous IFS threads i would be reluctant to place too high a confidence level on such assumptions. Hopefully Miriam will shortly offer further corroborative information one way or the other.


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Charles.C


#18 CernencuLaura

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Posted 28 December 2016 - 09:51 AM

I believe you should do sanitary test for clothing - NTG and total coliforms for each stuff member


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