Protective Clothing Risk Assessment

As required by the BRC Packaging Standard has anyone carried out a Protective Clothing Risk Assessment for wear away from the production environment such as when eating and drinking, smoking and visiting the toilet?

Although this question is posted in the packaging forum I would be happy to see any examples from food also, especially if anyone has managed to conclude through risk assessment that changing out of protective Clothing is not required.

Regards,
Simon

Surely somebody has addressed this difficult issue?

The simple answer is in food, we don't! We wear coats which are easily removed and put back on to avoid a full change and so there's no excuse not to remove the hygienic workwear for these activities.

I came up with about 3 pages of reasoning about where clothes should be changed, stored etc. but it basically came to the above conclusion!

We have been looking at this issue recently in our factory. We don't change to go to the canteen. Without being a microbiologist I don't know what bacterial contaminant introdued onto clothes from eating that would survive on our packaging - i.e. toxins, spores etc?? I am also trying to determine what organisms to test for as we are going to do some swabbing as many customers ask for this. Looking at the CFA (Chilled Food Association)guideline there is basically a minimum water content level below which vegetative organisms will not survive so thermoformed packaging does not have any water content. In a packaging environment I don't think we need to adopt a change of clothes as long as hands are cleaned and sanitised before going back to the factory but then again why do we even need to do this?

We have been looking at this issue recently in our factory. We don't change to go to the canteen. Without being a microbiologist I don't know what bacterial contaminant introdued onto clothes from eating that would survive on our packaging - i.e. toxins, spores etc?? I am also trying to determine what organisms to test for as we are going to do some swabbing as many customers ask for this. Looking at the CFA (Chilled Food Association)guideline there is basically a minimum water content level below which vegetative organisms will not survive so thermoformed packaging does not have any water content. In a packaging environment I don't think we need to adopt a change of clothes as long as hands are cleaned and sanitised before going back to the factory but then again why do we even need to do this?

Hi Roie

How do your operators handle the formed cups? do they put their fingers in the top cups to pack them into the boxes? (i've seen this being done, and you'd be surprised how many people think this acceptable!) Do you do hand swabs to verify that the operators are not carrying staphs or entros and that they are adequately washing their hands on return to production ? Do you check the micro quality of your cups using rinse water techniques?
How do your customers handle the cups? you need to have an informed decision on stopping hand washing. What products are going into these cups? are they high risk? who are the target population for their product? are they a susceptible group? you need to address this in your HACCP.

caz x

Hi Caz

All of these questions are perfectly valid in a food processing environment because once the contamination occurs the micro-organisme will breed - not so in our environmnent - they will have died off within 24 hours and will not pose a threat to our customer. However - I do stand to be corrected. I agree that we should have very high hygienic standards in our factory and indeed management enforce this as our customers are the food industry - I have no intention of stopping handwashing. Thanks for your feedback.

R.

Hi Caz

All of these questions are perfectly valid in a food processing environment because once the contamination occurs the micro-organisme will breed - not so in our environmnent - they will have died off within 24 hours and will not pose a threat to our customer. However - I do stand to be corrected. I agree that we should have very high hygienic standards in our factory and indeed management enforce this as our customers are the food industry - I have no intention of stopping handwashing. Thanks for your feedback.

R.

Your welcome Rosie

it's why we're all here..to help each other

caz x

Hi Caz

All of these questions are perfectly valid in a food processing environment because once the contamination occurs the micro-organisme will breed - not so in our environmnent - they will have died off within 24 hours and will not pose a threat to our customer. However - I do stand to be corrected. I agree that we should have very high hygienic standards in our factory and indeed management enforce this as our customers are the food industry - I have no intention of stopping handwashing. Thanks for your feedback.

R.

Rosie:

Just a warning, be careful of assumptions related to bacteria. Without knowing your process, I would just speak in general terms that the freezing process will kill off most vegetative bacteria, but not necessarily all. Additionally, bacterial spores - if produced by the type of bacteria that can be found in your products - will almost certainly survive and can germinate as soon as conditions are favorable.

There's my two cents for the day, now I'm broke until tomorrow. :-)

Jon

Thanks Jon

But we produce plastic packaging not food so there is nothing to support the growth of vegetative organisms. I am however concerned about toxins / spores as these will have the potential to hang about on the pots and activate when the pots are filled with yogurt / cream etc. I guess I need to consider testing for the presence of these rather than a standard TVC / entero plate. Does anyone else check for spores or toxins?

Rosie.

Thanks Jon

But we produce plastic packaging not food so there is nothing to support the growth of vegetative organisms. I am however concerned about toxins / spores as these will have the potential to hang about on the pots and activate when the pots are filled with yogurt / cream etc. I guess I need to consider testing for the presence of these rather than a standard TVC / entero plate. Does anyone else check for spores or toxins?

Rosie.

I have just realised how stupid i've been - main toxin of concern will be from S aureus and the spores will come from yeasts / moulds. So if I do hand swabs for S aureus and check pots for yeasts / moulds on Rose Bengal agar that should cover it shoudn't it or do I need to do coliforms as well - do these produce toxins?

There's my two cents for the day, now I'm broke until tomorrow. :-)

Well that’s a couple of cents more than I got.

Thanks for all of you r input on this. I think my conclusion for a packaging company who has effective hand washing, and workplace sanitation backed up by negative product, process, employee and perhaps even work wear swab results and an absence of biological contamination complaints just may by the skin of their teeth be able to conclude that removing work wear prior to visiting the toilet, eating, drinking and smoking is not required. Trying to convince an auditor or customer of this on the other hand may well be difficult as it just does not seem right and is not acceptable in food processing.

If you were going to implement the procedure the best way is to provide easily removed clothing such as coats, adequate and convenient places to hang coats and maybe start with this procedure on changing before visiting toilets and then when in place expand it to cover eating and drinking and smoking. It may be able to be risk assessed so that certain employee groups are exempt such as printers or warehouse operatives as they are not in direct contact with the end product.

I have just realised how stupid i've been - main toxin of concern will be from S aureus and the spores will come from yeasts / moulds. So if I do hand swabs for S aureus and check pots for yeasts / moulds on Rose Bengal agar that should cover it shoudn't it or do I need to do coliforms as well - do these produce toxins?

Again reading my own response (I'm going mad!) does the absence or S aureus on a tandard test (I presume a standard test is to detect vegetative organisms) necessarily mean absence of toxin? - and does absence of vegetative Y+M mean no spores? You would need a degree in microbiology for this - but seriously where could I get some expert advice on this - I emailed CCFRA for a quote but heard nothing back.

Dear Simon,

I notice you don't discuss the control of cleaning the relevant clothing. This is probably even more contentious.

@Rosie - I think the evaluations involved in yr queries are fairly bread and butter to professional food microbiologists (not criticising - I am a converted chemist, been there, done that, and more ! )(Caz's comments graphically illustrate the opportunities). Perhaps you should look for some typical specs to start with.

Packaging not my exact area but my guess is that, as per food surfaces, one tendency is to minimise pathogenic hunting and use indicator groups like Enterobacteriaceae due to sampling/microbiological/environmental reasons. However I guess it may depend somewhat on yr specific product / target consumer.

Rgds / Charles.C

I think the other question though is why not remove clothing? If you have well designed clothing, it should be easy to remove. There's no need from a food safety point of view to have food handlers in hygienic trousers, a knee length coat is fine. As long as that's not a risk from your machinery point of view; why not bring in similar rules? Just a thought. Sometimes we can bring in something which is 'good enough' but next month face an auditor who wants more. Standards also move on and change. If you were starting from scratch, to go for something which is a 'future proof' solution seems sensible.

It's not only bacteria which could be a concern though because by not having good clothing controls, you then risk the debris (carrying bacteria) being carried into production areas. I bet there are loads of hairs on my work chair (I'm not as bald as my photo) which would adhere to any hygienic workwear if I didn't follow my own rules (unlikely I assure you!)

(Also consider the cross contamination allergen risks from canteens btw...)

Again reading my own response (I'm going mad!) does the absence or S aureus on a tandard test (I presume a standard test is to detect vegetative organisms) necessarily mean absence of toxin? - and does absence of vegetative Y+M mean no spores? You would need a degree in microbiology for this - but seriously where could I get some expert advice on this - I emailed CCFRA for a quote but heard nothing back.

LOL don't worry,we all get blonde moments Rosie!

You can get dipslides to test for staphs with the back being Entros. I'd test for entros just as a GMP.
You may need to look at the legislation regardin testing for staph spores or toxins on site. it may be that you have to do that at an offsite lab.

cazx

I notice you don't discuss the control of cleaning the relevant clothing. This is probably even more contentious.

Good point Charles, most of them I've come across are absolutely hopeless.

I think the other question though is why not remove clothing? If you have well designed clothing, it should be easy to remove. There's no need from a food safety point of view to have food handlers in hygienic trousers, a knee length coat is fine. As long as that's not a risk from your machinery point of view; why not bring in similar rules? Just a thought. Sometimes we can bring in something which is 'good enough' but next month face an auditor who wants more. Standards also move on and change. If you were starting from scratch, to go for something which is a 'future proof' solution seems sensible.

I agree and you are right to suggest putting in solutions that are effective and mitigate the risk. It is a bit difficult in packaging as you have operations such as printing and coats here are not ideal - then again printing process is less of a risk than final product packaging where there is more operator handling and more exposure of the product to to people and the environment.

Regards,
Simon

A few other things to consider:

• glove use
• environmental sampling (testing areas other than the actual product, such as drains, surfaces) for microbiological contaminants
• exclusionary measures to prevent contamination of product (covers over conveyors, etc)
• Gas or UV treatment of product (or any of various other options) to sanitize/sterilize it - would likely be effective on toxins, but not necessarily for spores

Hi all

Spoke to one of the environmental hygiene guys at Campden today.
For packaging we would only need to consider TVC and Y&M. The counts are likely to be so low we will have to place approx 10 pots into a sterile bag with approx 100ml of ringers and then use membrane filtration to try and get a real picture of what might be a about - swabs will most likely prove or disprove nothing.
Regarding S aureus - only 2% of the population will carry on their hands (albeit 50% will carry in their ear and nasal passages) and you would test to move these people away from high risk environment - again little point in hand swabbing in our environment. Air testing will also be pointless in our environment.
So there you go that is what the experts say - so I am away to devise a method for my pots. If we start to get counts we will then try to find out what they are.
Hope you all find this information useful.

Rosie

Dear Rosie,

Did your "expert' suggest an acceptable limit(s) for TVC at ?degC ? and similarly yeast and mould ?

I find the figure for hands / Staph. rather surprising. Any validation offered ?

Rgds / Charles.C

TVC at 22C and 37C he would be surprised if we got a count at all but we would need to carry out over period of months - if we start getting counts we need to look at identifying and quantifying. Said that we would have to experiment to find a meaningful method suitable for our purposes.
We don't have any kind of laboratory here so we will have to contract this out.

TVC at 22C and 37C he would be surprised if we got a count at all but we would need to carry out over period of months - if we start getting counts we need to look at identifying and quantifying. Said that we would have to experiment to find a meaningful method suitable for our purposes.
We don't have any kind of laboratory here so we will have to contract this out.

We used to do rinses on plastic milk bottles. i'm more than happy to send you a test method if you like ~( so at least you know what to ask the external lab to do)

caz x

Caz - that would be great - thank you very much. Can you access my email through the website or do I need to post it?

Rosie

Hi Rosie

A typical method here:

1. Take bottles from the end of the production line (So all areas where possible contamination can occur will be captured). Label using the mould number and machine identification. Place a sterile closure on top.

2. Add 25mls of diluent and re-close the bottle. (This can vary with bottle size)

3. Hold the bottle horizontally and rotate 12 times in 1 direction so that the whole of the internal surface is wetted.

4. Stand for 20 minutes to allow contact time. Repeat step 3 and return diluent to its original container.

5. Rinses must be tested within 6 hours. Store in a fridge at 1 – 5o C if you are not testing immediately.

6. Test for TVC and Yeasts & Moulds as per standard Laboratory test method.

7. Calculate the colonies per bottle: Count X mls of rinse/mls plated = Colonies per bottle.

If you do not have a Laboratory then I would consider sending the final sealed packs to the external laboratory to be tested. My biggest problems with packaging in the past have been Yeasts & Moulds. Problems do not necessarily come from the bottles in packs themselves but from contamination on the outside of the packs when stored which can then contaminate the bottles when the wrapping is removed. If you talk to your customers then maybe they will give you some guidance.

Did you make a decision regarding coats? It seemed to me that you were going to a lot of effort when one preventative measure eliminated many hazards - removing coats on exit from production area.

Regards,

Tony

Hi Tony

Thanks for this. Our guys and girls don't wear coats - uniform is t-shirts and trousers neither of which are removed going to the canteen or toilet.

Rosie

Hi all

 

After 7 years let me remind you this contentious topic.

 

We are converters of flexible food packaging films. To be more specific we print, laminate, slitting and bag making flexible packaging for foods.

Our operators wear working uniforms (tshirt, trouser, shoes) which they should remove upon completion of their shift. Also they have specific instruction for the cloth washing. 

what do you think about our procedure?

 

Furthermore the top management believes that we don't need any har band because we don't faced such problem in the past. The auditor said ok :shutup: but I have scruples in that. Should I stated that on our risk assesement ? And if yes how I would explain that?  

 

Regarding the microbiological control, we send annually samples from each machine (final and intermediate production step) to an external laboratory (accredited) to be tested only for TVC. Till now we have no result over 5 cfu/100cm2. So we think that we are ok and we don't have to control TVC more often in the year. We are right?

Until last year, additional to the external we did internal swab testing (Hygicult TPC, validation approved by AOAC and NMKL) every two months to determine the total aerobic bacteria on the surface of our final product. We have stoped this test because based on the results (not over 5 cfu/100cm2) and the nature of our products we thought that the only external test will be ok. Do you think that we are doing the right thing or not?

It meant that we have instructions for hand washing prior the entering in the production area. 

 

Looking forward for your answer 

 

Thank you,

Polin