Nut Policy Relating to Foodstuffs Brought in by Employees

Hi all,

The age old debate of being a "Nut-Free" site again.

As a processor, we are 100% Nut free with regard to Raw Materials, Process, Processing Aids & Finished Product.

What we cannot prove is the status of Foodstuffs bought in by Staff & Factory Operatives.
In the UK, as well as many other countries, Food operatives originate from far & wide. This is reflected in the Ingredients used to cook food.

Currently, we have an Allergen Policy in place.
With regards to this area, the policy states that "Staff, Visitors & Contractors should be aware of Allergen's which may be bought on site through their own foodstuffs, and the ways in which to control cross contamination"
This Is displayed in key area's around the site and staff Facilities.

This is currently not monitored.

What are peoples thoughts on this subject? Also point of view from auditors?
Apologies if it's been bought up beforehand.

Regards
SP

The age old debate of being a "Nut-Free" site again... What we cannot prove is the status of Foodstuffs bought in by Staff & Factory Operatives.
In the UK, as well as many other countries, Food operatives originate from far & wide. This is reflected in the Ingredients used to cook food.

I think you have to trust your staff a certain amount, trust they understand what the no nuts rule is and why. You don't check they wash their hands after the toilet at home or cook food properly at home but both could (and are probably more likely to) contaminate your food eventually.

One 'check' you could do is a random locker check; for starters we have a no food rule in there anyway but it'll be the place nuts will be hidden if anywhere.

Not bringing in nuts is only one of the controls on not spreading them into the food; another could be effective handwashing prior to food handling which presumably you are verifying?

Do operators change workwear prior to visiting canteens to eat? That along with handwashing is another control. If you have vending machines nothign with obvious nuts like snickers - or you could ask the vendor for a nut free menu / machine.

I think you have to trust your staff a certain amount, trust they understand what the no nuts rule is and why. You don't check they wash their hands after the toilet at home or cook food properly at home but both could (and are probably more likely to) contaminate your food eventually.

One 'check' you could do is a random locker check; for starters we have a no food rule in there anyway but it'll be the place nuts will be hidden if anywhere.

Not bringing in nuts is only one of the controls on not spreading them into the food; another could be effective handwashing prior to food handling which presumably you are verifying?

Hi GMO, thanks for the reply.

As I mentioned, the whole "Allergen" pathway is covered and verified. The only part not included is Staff Food items. I understand there is an overlap, where staff should be adequately made aware of controlling possible cross contamination, with processes such as hand washing etc.
Over the last few years, i've noticed its a grey Area for auditors, and as with anything, they have different benchmarks.

I do think however, I can justify that random locker checks are a strong enough verification process for checking staff foodstuffs.

my main quarm is the effectiveness of such a "policy". I can instigate the paperwork, introduce the checks and verification.....but I will not be 100% happy that it can be constantly monitored.
Maybe this is asking too much anyhow...?

Lots to think about lol

Do operators change workwear prior to visiting canteens to eat? That along with handwashing is another control. If you have vending machines nothign with obvious nuts like snickers - or you could ask the vendor for a nut free menu / machine.

Hi Simon,

Staff are not allowed any work wear in the canteen, and this practice is effective as there is a huge window from my office, the production managers office, and the MD's office into the canteen!
No vending machine, just a drinks machine & water dispenser, along with the usual kettle, microwave & toaster.

I think control is the key measure here, again dependent on auditor discretion

oops, i meant monitoring!

I think you have tight controls sp13 - the risks must be minute and you appear to have done everything reasonably practicable.

One question what is the definition of a nut free site? Does it extend to everyone and everything or only prodcution/warehouse areas?

By the way welcome to the forums sp13.

Regards,
Simon

Dear All,

I guess the sensitivity might also relate to the type of product / process ??

Rgds / Charles.C

added - if the audit referred is BRC, I imagine there is surely a requirement for a risk evaluation somewhere (haven't looked it up) since this currently seems to answer all their woes

added(2)

random locker checks

does this mean that you are allowed to randomly open personal lockers ?

I think you have tight controls sp13 - the risks must be minute and you appear to have done everything reasonably practicable.

One question what is the definition of a nut free site? Does it extend to everyone and everything or only prodcution/warehouse areas?

"Nut free" normally means no nuts on site anywhere.

Part of the BRC standard normally involves changing clothes before going into canteen areas.

Also on the question of locker searches, the way we normally do it is to have the person there with you. It means there are no questions about what was found, no worries about security and also you can deal with things there and then.

I've never worked in a food company and encountered the pressures that exist there but I have to say I find the idea of locker inspections worrisome. Personally I’m a theory Y person and this kind of practice goes against my principles of getting to where you want to be based on a foundation of mutual trust. Personally I would say the net loss would be greater than the gain delivered from such a practice. Maybe I live in a dream world but it’s just my personal belief.

True, it's not ideal but I suspect that despite being trained and asked not to, there are staff storing food in the lockers. It's not ideal but we agreed in the end that having the locker owner present is the best way. I agree it's not pleasant and to be honest I'm not looking forward to the task but the BRC auditor may ask to look. I have had that situation in the past.

I recently had something taken out of my work drawers, read and handed to another manager. The item was intensely personal so I can understand the privacy argument but I think by having the person there and explaining what you're looking for (and lack of interest in other items) makes it better.

Not ideal, I agree and I'd rather trust people.

True, it's not ideal but I suspect that despite being trained and asked not to, there are staff storing food in the lockers. It's not ideal but we agreed in the end that having the locker owner present is the best way. I agree it's not pleasant and to be honest I'm not looking forward to the task but the BRC auditor may ask to look. I have had that situation in the past.

I recently had something taken out of my work drawers, read and handed to another manager. The item was intensely personal so I can understand the privacy argument but I think by having the person there and explaining what you're looking for (and lack of interest in other items) makes it better.

Not ideal, I agree and I'd rather trust people.

I understand it's difficult and safety comes before everything else. If there is no other way then I suppose it has to be done...in a nice, friendly way.