BRC Clause 7.3.3 - are tongue rings allowed?
Started by jenmaw, Aug 23 2010 02:38 PM
This requirements stats that rings and studs in exposed parts of the body, such as noses, tongues and eyebrows shall not be worn. We allow tongue rings in a food processing/packaging plant but the person must sign a declaration notice to the company. IS this acceptable?
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In my opinion it is not acceptable.
What do you think this would count as? a minor non-conformity?
must sign a declaration notice
Declaring what exactly ? that you guarantee to keep your mouth closed at all times on the production floor ? is there some particular consequence of the declaration, eg segregated to the packaging area ?
And are you required to wear mouth closure masks as well ?
Re yr non-conformity question - this in theory relates to risk, eg what is yr product / specific process step involved ?
Not sure if Simon's answer meant that he thought the practice itself was unacceptable or the signing of a declaration ??
Rgds / Charles.C
Declaring what exactly ? that you guarantee to keep your mouth closed at all times on the production floor ? is there some particular consequence of the declaration, eg segregated to the packaging area ?
And are you required to wear mouth closure masks as well ?
Re yr non-conformity question - this in theory relates to risk, eg what is yr product / specific process step involved ?
Not sure if Simon's answer meant that he thought the practice itself was unacceptable or the signing of a declaration ??
Rgds / Charles.C
Its declaring that they have a tongue ring and if it falls out they will report it. This is for a food processing/food packaging plant. Some of these employees are on inspection tables with direct contact with the product. If I did a risk assessment saying we have a metal detector after the product is packaged that it would cover it? Or would it be best to say no tongue rings allowed?
If it is a requirement of the standard you must comply, unless you can justify an exemption to the requirement and I don't think you can even with a metal detector in place.
If the auditor sees a tongue ring being worn during the audit they will raise a minor nonconformity, which will require corrective action, being a change in your policy and ensuring that it is complied with. All nonconformities must be closed out within 28 days of the audit.
Repeat nonconformities identified for the same thing on subsequent audits could result in a major nonconformity.
If the auditor sees a tongue ring being worn during the audit they will raise a minor nonconformity, which will require corrective action, being a change in your policy and ensuring that it is complied with. All nonconformities must be closed out within 28 days of the audit.
Repeat nonconformities identified for the same thing on subsequent audits could result in a major nonconformity.
1 Thank
I find it somewhat strange that 7.3.3 is preceded by 7.3.2 which states -
And taking a relatively extreme example, if you were producing baby food and the bejewelled operator was packing the final product into its consumer designated container, I think the conformity might be rather more than minor.
(must be an interesting situation in countries where the use of lip-rings can be a stipulated worker's right, eg Australia I believe. Have also seen the same controversy occur in fast-food retail establishments in USA).
Rgds / Charles.C
It appears to me that via 7.3.3, BRC have done the bulk of the risk evaluation for you and thereby ruled out the use of a declaration policy.Based on risk assessment, the company shall document its jewellery policy
And taking a relatively extreme example, if you were producing baby food and the bejewelled operator was packing the final product into its consumer designated container, I think the conformity might be rather more than minor.
(must be an interesting situation in countries where the use of lip-rings can be a stipulated worker's right, eg Australia I believe. Have also seen the same controversy occur in fast-food retail establishments in USA).
Rgds / Charles.C
It is common to not allow tongue rings but this is not only because of the physical or foreign object hazard. Many view a tongue ring as the same as having a piece of candy in the mouth - it encourages more movement of the tongue one might 'play' with it as the day goes by and this increases risk of saliva from that person.
This requirements stats that rings and studs in exposed parts of the body, such as noses, tongues and eyebrows shall not be worn. We allow tongue rings in a food processing/packaging plant but the person must sign a declaration notice to the company. IS this acceptable?
The clause quite clearly states that rings or studs in exposed parts of the body such as a tongue shall not be worn.
Therefore this is not acceptable and a probable minor although could be interpreted as a major non compliance "where there is a failure to meet the requirements of any clause of the standard".
You may be able to persuade the auditor otherwise if you have a risk assessment (BRC do seem to love risk assessments) as per Charles' post regarding clause 7.3.2 but it wouldn't wash with me.
This requirements stats that rings and studs in exposed parts of the body, such as noses, tongues and eyebrows shall not be worn. We allow tongue rings in a food processing/packaging plant but the person must sign a declaration notice to the company. IS this acceptable?
The strange thing (in my mind anyway) is that 7.3.3 allows for the wearing of "...sleeper earings (continuous loop). Rings and studs in exposed parts of the body, such as noses, tongues and eyebrows, shall not be worn".
Simply enough, but my argument (though I'd never try with an auditor!) is that a ring in the nose / tongue / eyebrow is no more likely to fall out than one in the ear. Surely if one 'exposed' area is a percieved risk, then they all are.
Ss
Hello
This reminded me of the topic I started...the mouth grill. Also in your mouth but well not mentioned in the BRC guidelines.
Someone reminded me that there is always something new wich you can 'wear'. I think it is better to banned all types of studs. I think sleeper earings should be banned as well. As you will get some discusions with the employees and then you need to define what sleeper earings are etc.
Good luck!
This reminded me of the topic I started...the mouth grill. Also in your mouth but well not mentioned in the BRC guidelines.
Someone reminded me that there is always something new wich you can 'wear'. I think it is better to banned all types of studs. I think sleeper earings should be banned as well. As you will get some discusions with the employees and then you need to define what sleeper earings are etc.
Good luck!
This requirements stats that rings and studs in exposed parts of the body, such as noses, tongues and eyebrows shall not be worn. We allow tongue rings in a food processing/packaging plant but the person must sign a declaration notice to the company. IS this acceptable?
No it isn't acceptable, it states very clearly that tongue rings aren't allowed. I have found over the years that the best method is to have NO exceptions to the sleeper/ wedding band criteria as somebody always tries to push the limits
Thanks everyone! We are now no longer accepting tongue rings
On the sleeper rings allowed thing, I've had one production facility which allowed this then tightened up their policy. I suppose the argument is that they are a single largeish piece which is difficult to open / close and so unlikely to fall off or if it did would fall off as one piece.
Still, I agree a zero tolerence approach is better and easier for people to understand. When we brought in the new tighter rules it made it very difficult and rule violations were common for a good 3 YEARS! (Not the most robust Technical department though tbh.)
Still, I agree a zero tolerence approach is better and easier for people to understand. When we brought in the new tighter rules it made it very difficult and rule violations were common for a good 3 YEARS! (Not the most robust Technical department though tbh.)
Yeah our policy was always no jewellery except tongue rings which makes no sense. Oh and Medical Alert Bracelets. But really if you can't wear a plain wedding ring why a tongue ring? Oh well its changed now
SQF Clause 5.2.1 - Artwork customer approval
Distance allowed to place containers in the wall
BRCGS Storage and Distribution - Clause 1.1.9
As per SQF are employees allowed to have neckless or anything hanging around their neck?
Is touching boxes and par cooked bacon allowed while scaling and packaging?
BRCGS Clause 3.11.3 - Incident management test must include a recall test?
Clause 8.5.1.2 - Characteristics of raw materials, ingredients and product contact materials
FSSC 22000 Clause 2.5.1 - Management of Services and Purchased Materials
BRCGS clause 3.5
BRCGS Clause 3.7.5 - Supply Chain Traceability