28 replies to this topic

[Max]

Hello,

I would like to have your opinon on a discussion with a fellow Quality Manager this morning:

What are the risks associated with piercings in the food industry?

Actually we are currently working out new hygiene rules for our company and we wondered whether we have to forbid piercings in the production area. Is it necessary to forbid all kinds of jewelry (and therefore including piercings) or can we make a difference between the different types (visible / invisble)? Which risk can be associated with a piercing in the tongue for example?

I would be curious to hear your opinon on this as this is always subject to discussion whether these piercings should be forbidden...

Regards,
Max

[Simon]

Hi Max,

Most hygiene codes allow only one pair of sleeper earrings (hoops) and one plain ring like a wedding band, not stud earrings or stoned rings as they could come apart and contaminate. However, why not two, three or four sets of hooped earrings? I suppose you have to set an exact number so that you can control and monitor, but the real v's perceived risk is very difficult to assess.

How would one go about monitoring piercings in invisible places??? Moreover, is it a problem if an employee has their willy pierced? Maybe a tongue piercing makes one drool more - I don't know. I know this post is sounds facetious, but I'm just showing how complicated this subject is, as you well know, hence your question.

How about this for something to ponder - people also where jewellery for religious or medicinal reasons e.g. copper wristband. Are we OK to ban employees wearing these under our countries law?

Maybe we should set our rules and any other additional visible piercings must be covered with a blue metal detectable plaster - OK on an eyebrow but hell to stick to a tongue.

Has anyone implemented a pragmatic solution for this most complicated of problems?

Regards,
Simon

[Charles.C]

Dear Max,
As indicated by Simon, you may find the local employment regulations have a definite opinion on this subject.
There are variations, I found this in the Personnel requirements of the USA, GMP regulations -

'4) Removing all unsecured jewelry and other objects that might fall into food, equipment, or containers, and removing hand jewelry that cannot be adequately sanitized during periods in which food is manipulated by hand. If such hand jewelry cannot be removed, it may be covered by material which can be maintained in an intact, clean, and sanitary condition and which effectively protects against the contamination by these objects of the food, food-contact surfaces, or food-packaging materials.'
The link is -
http://www.cfsan.fda...obat/cfr110.pdf
I guess this solves many of Simon's invisible places (assuming a not too exotic working uniform - environment) but I still wonder how they classify earrings, lipobjects etc ?
Rgds / Charles.C

Added - I should have remembered to add that some objects may be easily ruled out on the basis of possible self-danger from machinery in the work area.

Edited by Charles.C, 24 August 2006 - 04:41 AM.

[Max]

Dear Charles C/Simon,

Indeed this is a very complicated question. If one-pice earrings and wedding rings are allowed, then so should be one piece piercings in the nose for example (don't know if that exists actually...) or eyebrow piercings. But is that kind of jewellry more secure than the other ones? I guess that might also depend on the quality of the jewelry...

Another company here in luxembourg has banned all jewelry except wedding rings that cannot not be remowed (which has to be proven to the Quality Manager). Yet these people permanently have to put a glove on that hand and change it AT LEAST every hour or more if the type of products handled requires it. This actually works in the sense that some people even cut off the ring in order not to have to follow that rule. So should it be all about setting rules that discourage people from wearing jewelry?

Concerning the issue of religious jewelry, this has been discussed some time ago on the french discussion group I told you about. Yet the opinons differe on this subject. Some people say that people have to follow the rules of the country they live in, others say that it should be allowed. I think this is more of an issue in countries where there are actually a lot of people that have different religous beliefs like the UK and France. Here in Luxembourg however there are quite few of them so there never was a real problem associated with this kind of jewelry. Do you have examples of religous jewelry?

Some companies allow invisible jewelry like chains under the working clothes, as long as they are invisible and can't fall into the product. To me, this might be a solution to both problems, invisible piercings and religous jewelry.

Regards,
Max

[Charles.C]

Dear Max,

I don't know the size of yr workforce but they are beginning to sound a bit like Pirates of the Caribbean. What kind of numbers bearing visible rings (other than wedding rings on the hand) are we talking about? If only one or two, maybe not obvious / problem, if a lot maybe you can temporarily replace them on audit day (assuming that yr operation requires an audit) ?

If you can do what you like, simply banning ear-rings as per other factory is a direct solution unless it will provoke a revolt. The glove changing you refer is extreme unless the gloves are damaged. Could use a sanitising dip and get some nice swab results as a backup.

You are correct I think when you say there are no absolute standards since everyone knows the difficulties including the auditors (although they can certainly vary in their rigorousness).

Yes, the cultural variations will occur and my experience is that auditors will usually accept the kind of approach you refer as long as there is no obvious or potentially unacceptable interaction with the product or environment, safety, whatever (chains are obviously a risk near some machines). Again, if faced with a small army of deviationists, the conclusion might not be so easy, classified as case-by-case in English, = the auditor covering his back.

Would be nice to hear from some professional auditors.

Rgds / Charles.C

[cazyncymru]

When we reviewed our Pre-requisites program and standardised it to encompass all of the company, we were very aware of the need to address our jewellery policy.

After a lot of research as to who wore what, we looked at the stance ACAS took with regards to discrimination. Was asking a member of staff to remove a piece of jewellery that had a religous connotation to them, indirect discrimination? However to apply a criterion, provision or practice which disadvantages a persons religon or belief if suitably justified is not discrimination.

I'm sure that to justify these actions there are a number of clauses that can be lifted from The Food Safety Act. Can we really allow a woman who wears a glass bracelet in lieu of a wedding ring to work in a food area?

As an auditor i audit against standard procedures etc. Our procedure is no jewellery except for a plain metal band, so any other forms of jewellery is not allowed. I know that the COP's issued by some of the supermarkets allow staff to wear sleeper earrings, but how can you get by it during the implementation of HACCP ? The risk is there. The whole idea is to remove any risks.

I don't think a blue plaster covering an eyebrow piercing is adequate.
I would ask for a tongue piercing to be removed for the same reasons as we don't allow people to eat in a production area. Am i too strict? maybe, but id be very upset if i found a earring from someones eyebrow or tongue in my food.

If they want to stick things in their nether regions, then go for it, but the minute its exposed in the workplace, it comes out

[Max]

I would ask for a tongue piercing to be removed for the same reasons as we don't allow people to eat in a production area. Am i too strict? maybe, but id be very upset if i found a earring from someones eyebrow or tongue in my food.

Dear cazyncymru,

I don't really understand what you are meaning when you compare a tongue piercing with eating in the production area? Could you explain that to me?

Is there a bigger risk related to a tongue piercing than to another "invisble" piercing on any part of the body?

Actually I would appreciate to see some examples of accidents, cases of problems in relation with piercings for example to illustrate the problem during training and to show people that this kind of jewelry has already been involved in problems with food products. Is there anyone having links to articles in relation with this kind of accidents?

Regards,
Max

[Gaskit]

Dear cazyncymru,

I don't really understand what you are meaning when you compare a tongue piercing with eating in the production area? Could you explain that to me?

Is there a bigger risk related to a tongue piercing than to another "invisble" piercing on any part of the body?

Actually I would appreciate to see some examples of accidents, cases of problems in relation with piercings for example to illustrate the problem during training and to show people that this kind of jewelry has already been involved in problems with food products. Is there anyone having links to articles in relation with this kind of accidents?

Regards,
Max

Tonge piercings not only give the wearer a lisp, they tend to constantly play with them with their tongue and lips and end up generating spit when speaking and playing with them (comparable to eating in the production area).

Face piercings in my opinion just look unsightly and could be covered with a blue waterproof plaster (as long as they are the sleeper type), but all jewelrey is indeed a hazard, recently a well known food packaging firm had to dump a full shifts woth of "take a break" 2 finger chocky bars (on land fill) due to one member of staff loosing her wedding ring during the shift and didn't notice until the shift had ended.

Just my twopenny worth (having both ear and body piercings).

Regards,

Steve

[cazyncymru]

recently a well known food packaging firm had to dump a full shifts woth of "take a break" 2 finger chocky bars (on land fill) due to one member of staff loosing her wedding ring during the shift and didn't notice until the shift had ended.

Wonder if the management broke two of her fingers Steve!!

[Charles.C]

Dear All,

While not personally disagreeing with the above opinions, some defences can be found, for example the W.Australians seem to be into this -

'(1) That the occupational health, safety and welfare of our members are the prime consideration when determining the suitability of any cosmetic jewellery. This includes the likelihood and consequences of this jewellery being caught in machinery, injuring other workers - eg excessively large, sharp, pointy etc.

(2) Food Safety & Hygiene - any jewellery that cannot be securely fastened by means of a fine thread connecting the two pieces (bars, studs or bolts) or does not need specialised tools to remove them would be deemed to present an unacceptable risk of contaminating the meat product.
The jewellery must not contain any stones (precious or otherwise) that may be dislodged and contaminate the meat product.
The jewellery must be made of a non-oxidising metals or amalgams; eg gold platinum, silver or surgical grade stainless steel to ensure that there is no build up of scale, oxide or other substances that are capable of collecting and multiplying bacteria.

(3) Acceptable Community Standards - Providing the jewellery meets the above criterion and is not offensive - eg racist, sexually explicit, obscene etc. and is of a small enough design not to draw undue attention to it or to cause the slurring of speech (in the case of tongue or lip studs) then this Union does not believe a heavy handed approach by employers is appropriate on what is really a question of changing fashion."
.
(The prioritising seems a bit questionable from the consumer's point of view though).

The link is - http://wa.amieu.asn....es.php?recid=51

Rgds / Charles.C

[okido]

Hallo Max,

I have a naval background and I am often surprised that people not take their personal safety more serious. For peronal safety reasons alone I would ban al jewellery on the industrial workplace.
Under BRC IoP we follow the rule that everything that is visible should be covered with blue plasters.
Exceptions: one plain wedding ring and a pair of closed loop ear rings, no stones allowed.
This gave a lot discussion in the beginning about the difference between one pair ear rings uncovered and two pair needed to be covered.
We follow the BRC IoP standard is our reply although I have to admit that I do not understand the logic between the difference of 1 or 2 pairs.
I think practicality prevailed here, maybe some BRC guru can comment on this.
Regarding religious jewellery I have no experience so far.
For new employees it would be quit simple. You can work for us and follow the rules that apply on our site and that are intended to safeguard the society.

Remember to share good fortune with your friends, Okido

[Charles.C]

Dear All,

The following are a few extracts I selected from the SOP (genuine I think) of a food service establishment. I thought the jewelry philosophy was rather interesting to this thread but some of the other guidelines seemed to indicate problems with the workforce.

Jewelry is a form of self-expression, which we at Anon support. Anon is a business, and as a food business, customers expect to feel safe consuming their food. The perception that excessive jewelry gives is not that of a clean and safe food-handling environment. Many piercing items encourage a person to touch or play with the item, an unsafe and unsanitary act.
Some jewelry also poses the potential hazard of falling into food, in part or in whole. The following applies while on duty:
.......
Tongue piercing jewelry will not be played with in any way. Display of or play with a tongue piercing will result in the requirement to remove the piercing while on duty.

However -

Only pre-approved baseball caps, bandanas or hair nets are authorized. Authorized caps include those issued by Anon, caps with tasteful athletic team logos, etc.
Political party hats, or political pins on hats (or uniforms), obscene language or images are not authorized. Visors are not authorized.

Pants will be worn at the waistline (exposure of boxers, lingerie, tribal tattoos or lower backside is unacceptable) and will extend to the ankle. This is a SAFETY and SANITATION issue as well as a matter of professional image projection.

Rules for pants apply to skirts and dresses except for length. Skirts or dresses will extend to at least knee length but will not drag on the floor or ground.

Culottes, peddle-pushers, Capri pants, skorts, clam-diggers or any other like item are not authorised

Take a daily bath. Use deodorant.

Change gloves whenever you change tasks, touch your face, touch a door handle or touch any other non-food item.

Never serve food dropped on the counter, floor or into other pans.

Ensure that food is appealing when it is handed to the customer. Sloppy food gives the perception of unclean and unsafe food.

Rgds / Charles.C

[Max]

Dear Charles,

Thanks a lot for these interesting links! The part on " how to wear one's trouser,etc." is also very interesting. I've never seen something like this in hygiene rules but it is interesting to see that some companies might have problems with this since it's getting more and more common!!
The risk associated with playing with a tongue piercing is also very interesting.

This gave a lot discussion in the beginning about the difference between one pair ear rings uncovered and two pair needed to be covered.
We follow the BRC IoP standard is our reply although I have to admit that I do not understand the logic between the difference of 1 or 2 pairs.

Okido, to me it sounds really strange to set an limit for this kind of rule. I don't see the sense in that either. Therefore, I would tend to send that either every ring has to be covered or none has to be... This can avoid lots of discussions!

Concerning the blue plasters, I think that this would not be helpfull to us as we do not have metal detector and therefore I think it would make no sense except for the blue color which makes it easyier to detect

[Charles.C]

Dear Max,

Regarding yr query on actual incidents caused by food contaminated by pierced jewelry. This kind of data seems to be much less accessible than microbiological since it is frequently part of Consumer Complaint statistics. (links anybody ?)
The item reported in this thread by Gaskit is a rare 'documentation' in my observations. Nonetheless I am equally sure that other jewelry cases will exist.

The only directly related case (though inconclusive) I found referred to is -
http://www.caspersta...fc4006051e7.txt

Even data on injuries from foreign objects in food is limited however you can get some idea of rankings and issues from -

Food and Drug Administration Surveillance of the Role of Foreign Objects in Foodborne Injuries
http://www.pubmedcen...i?artid=1403330

Food Recall Statistics
http://www.foodstand...tsinclu2957.cfm

The Dirty Dozen: Ways to Reduce the 12 Biggest Foreign Materials Problems
http://www.foodsafet.../feat0304-2.htm

The Do's and Don'ts of Food Plant Personal Hygiene Practices
http://www.foodsafet...itation0412.htm

Basically, Regulatory rules I noticed on the IT are usually based on the styles already discussed in this thread, in some cases even stricter, eg all jewelry prohibited.
So I guess the choice comes down to Company Policy and Regulatory Rules.

Rgds / Charles.C

added - you should probably get a metal detector - it simplifies the HACCP plan

Edited by Charles.C, 28 August 2006 - 08:23 PM.

[Simon]

Concerning the blue plasters, I think that this would not be helpfull to us as we do not have metal detector and therefore I think it would make no sense except for the blue color which makes it easyier to detect

A few years ago I asked an auditor why plasters needed to be blue in the food industry, and he said "have you ever seen blue food?" - I just hadn't put two and two together.

I cannot think of any, but are there any 'natural' blue foods? Except foods that are coloured blue like cake icing. I like colour coding.

ON TOPIC

So after the discussion did you conclude your jewellery policy Max?

Regards,
Simon

[MartLgn]

I cannot think of any, but are there any 'natural' blue foods? Except foods that are coloured blue like cake icing. I like colour coding.

What about blueberries ? a bit dark maybe but under certain lights they really appear blue, judging by the mess they make during a muffin related mis-hap they are most definitely blue

[cazyncymru]

Pants will be worn at the waistline (exposure of boxers, lingerie, tribal tattoos or lower backside is unacceptable) and will extend to the ankle. This is a SAFETY and SANITATION issue as well as a matter of professional image projection.

Rules for pants apply to skirts and dresses except for length. Skirts or dresses will extend to at least knee length but will not drag on the floor or ground.

Rgds / Charles.C

I feel a shopping trip coming on so that i can buy sensible pants and skirts!!

My tongue is very firmly in my cheek here!!

[Gaskit]

A few years ago I asked an auditor why plasters needed to be blue in the food industry, and he said "have you ever seen blue food?" - I just hadn't put two and two together.

I cannot think of any, but are there any 'natural' blue foods? Except foods that are coloured blue like cake icing. I like colour coding.

ON TOPIC

So after the discussion did you conclude your jewellery policy Max?

Regards,
Simon

After whatching the smarties advert on TV, there are no longer any blue ones because there isn't a natural blue colourant available.

Just my two-pennys worth.

Regards,

Steve

[Simon]

After whatching the smarties advert on TV, there are no longer any blue ones because there isn't a natural blue colourant available.

Just my two-pennys worth.

I think the blue was removed because it made kids go loopy.

Regards,
Simon

[Charles.C]

Dear Gaskit,

Frankly, i don't think you'll get many of any colour for two pennies.

Rgds / Charles.C

[Charles.C]

Dear Max,

Please don't forget to tell us if you reach a decision on the rings-piercings.
My expectation would have been that Luxembourg is a pretty conservative area which is why your query / associated details were rather fascinating (to me anyway) and seemed to indicate that perhaps the opposite was the case, at least in the vegetable sector (or perhaps you are something of a rebel?).
In addition, I will stick my neck out and guess that this issue represents one of the most difficult 'personnel hygiene' subjects that many of the QA people reading this have met (particularly if a cultural factor is involved also). Whether this anxiety (visions of kids choking or breaking teeth for example) is justified in the risk evaluation sense is much less sure compared to, say, handwashing but the easy avoidance of an unarguably visible hazard surely carries some weight.
I also earlier noticed 2 or 3 actual audits published on the net and as stated by Cazyncymru previously in this thread, their viewpoint was quite simple, 'jewelry observed was not in accordance with the relevant audit standard and therefore a non-conformance'. Period. Subsequent corrective actions were not discussed unfortunately. Worth thinking about IMO.

Rgds / Charles.C

[Max]

Dear all,

finally I decided to ban all visible jewelry (tongue piercings not included) from all food contact areas. There will be no exceptions made for "one-piece jewelry". This has been decided with the management and will be applied with the new hygiene rules.

Thanks to all of you for your comments on that issue!!!!

Edited by Max, 08 September 2006 - 01:39 PM.

[Charles.C]

Dear Max,

I deduce from this that tongue piercing has become very popular which is an interesting fact in it's own right for me. It will now be equally interesting to see if there is an increased frequency in yr staff (assuming that is possible).

Rgds / Charles.C

[Max]

Dear Charles,

I don't think that the number of tongue percings is still increasing, I think it was more popular a few years ago (at least here in Luxembourg). But, as the question about that kind of piercings occured on the forum, I wanted to discuss it with the management. Yet we decided not to include it in our hygiene rules.

Regards,
Max

[Charles.C]

Dear Max,

This is more of an afterthought. I recently noticed several other threads in the forum which relate to personnel / jewelry / watches which might help in case you have to support yr current decisions at some future point .

http://www.saferpak....h...141&hl=ring
http://www.saferpak....h...ic=1076&hl=
http://www.saferpak....h...ic=1058&hl=

Rgds / Charles.C