50 replies to this topic

[cocoabeanny]

hi guys,

we have just reviewed our personal hygiene rules and now our work council asks why we want to ban make-up from our people in the production. For us in the QA it is the normal thing that you should not wear it when producing food products, but we do not find a document, a customer requirement or standard that we can show.
They make a fuss around it now, that we can not forbid it if we can not show any evidence.
You find everywhere no varnish fingernails and no juwellry but nothing about make-up. Can anybody help me with this? We are located in Europe and produce Cocoa Products.

thanks you very much!

[GMO]

Now this is one I find odd. Ok, no heavy make up (you don't want mascara flaking into your product), no perfume and no nail varnish but really? What is the point in banning a bit of concealer or lipstick? I see no point to be honest and I'd rather fight the battles I feel are important and just say "no heavy make up" with specifics on no false eyelashes, perfume, nail varnish etc but then make sure people wash their hands! For a lot of women working in industry "no make up" is a really difficult thing for them to accept and in my opinion without good reason.

I say concentrate on the things that really matter rather than fighting this battle for the sake of it.

[Anne Z]

Hi

I know strong parfums / bodylotion are not allowed as well in some areas. I saw a documentary on discovery - painting a expensive car... I know not at all food related but it has to do with hygiene. The wrong chemicals in the air can make little bumps in the car. Of course a customer wants a smooth cover and not bumps or dents. Same goes for cocoa the smell of the parfum can get attached to the cocoa - but depends on the state of the cocoa (just PPP cocoabutter of ready to eat chocolates etc).

As for make up - you can rub into you eyes...and the products in on your hands...and then you touch the product and conteminate it. I guess it depends on how much make up anybody uses. In our policy make up is not mentioned and we don't have any problems. Maybe to do with the fact that only guys work in the prodcution area.

As for evidence...why do you want to ban it? You must have your reasons to ban the make-up.

Good luck!

Anne

[GMO]

If you're rubbing your eyes then touching the product there are more problems than just make up! It's a good point though Anne; why do you want to ban it cocoabeanny if you can't think of a valid reason to ban it?

[psunjka]

Principal – PIFSQN, it is not a matter of 'little' makeup, you want to set a standard that both employees and management should follow. The story is the same as for enforcing hairnets with bald people: you don't want to judge each and every case separately going from girl to girl and saying hmmm.. this is fine; hmmmm... no, this is too much lipstick... Each and every person in food industry should be uniformly dressed and groomed. I had a lot of troubles in two of my companies: first with older ladies and makeup, and then with older man not shaving. They even asked me what is the approved length of a beard!!! Right, I'll take a caliper and measure every hair on every employee's face.


Considering the topic starter, I can't believe that you can't find any reference to makeup in food safety standards. I guess that you have problems with your worker's union (work council) and my suggestion to you would be to have a meeting among management, QC team, and work council to clear this out. Another factor: who is going to certify you? Is it customer-driven, government-driven or it is your good will?

[Simon]

I find rules are best as yes or no, black or white; if you allow grey then individuals are able to determine what shad and then the consistency and control is gone.

I'd like to know the clause and wording that covers this in the various standards such a BRC, IFS, SQF etc. If anyone can copy that here. I'm quite surprised by your view point on this GMO as I had you down as uncompromising when it comes to hygiene - are you softening?

[Inesa]

Dear all,

General Food Law:
Article 2

"Food" shall not include:

(e) cosmetics within the meaning of Council Directive 76/768/EEC
(h) residues and contaminants

Regards
Inesa

p.s. forgot to add that I saw women cutting onions crying and getting mascara dirty faces. It can drop to food! Old mascara is felling down, women scratch eyes and scratching eyes is a risky thing etc. Isn't it an entry of cosmetics to the food!

Edited by Inesa, 05 December 2010 - 05:07 PM.

[Inesa]

Another:

Regulation 852/2004 Annex II- Chapter VIII
Personal hygiene:

1. Every person working in a food- handling area is to maintain a high degree of personal cleanliness and is to wear suitable, clean and, where necessary, protective clothing

Is that not enough? I don't keep a person clean if it has cosmetics on...

Where is a problem? If you seek for a high degree of cleanliness you say no to cos metics, thats all

[Charles.C]

Dear Simon,

My prediction is you will find no specific ban. Clearly, a risk analysis for onion handling might dictate a rule for this particular situation. Or issue glasses / keep on ice maybe.

BRC 5 – no mention of make-up or cosmetic as far as I could see.
US Food Code (2005) no mention in current context.

Noted in one personal hygiene document (Canadian) for Non – RTE food :

Jewelry

• NO jewelry, earrings, bracelets, rings or watches, except for medical alert necklace and/or bracelet, is allowed to be worn in the food handling area/production area. Medical alert necklace and/or bracelet must be covered completely. Plain wedding band is allowed but has to be protected by the gloves. Any other religious bracelets that cannot be removed have to be protected by taping and covered by protective work gear. Personal effects and coats etc., are to be kept in the lockers provided.

REASON: Jewelry can easily fall into food products. It is very hard to clean and may carry microorganisms on the surface or in the crevices. Jewelry can contaminate food products as well as a safety hazard to the customer.


Hats / Make-up / Perfume

• Hats are not permitted.

• Makeup is to be worn in moderation.

• Perfume is not to be worn on your wrists.

Second one (slightly re-formatted)(US) –

Foodservice Experiences –
Includes all rotations in foodservice operations.
Includes food demonstrations.
Personal Hygiene - Shower daily and wear deodorant
Hair – Clean, If longer than collar length, must be pulled up. Completely covered with a hair restraint.
Facial Hair (men) - Shave daily or wear a facial covering.
Perfume - Not allowed.
Make-up - Minimal amount in neutral colors, if desired.
Fingernails - No acrylic nails or nail polish.
Gum - Not allowed.
Jewelry - No jewelry or watches.

I guess any internal decision comes back to perceived risk / reported incidents / consequences / local regulations. Have to draw lines somewhere or no workers.

Rgds / Charles.C

[majoy]

hi guys,

we have just reviewed our personal hygiene rules and now our work council asks why we want to ban make-up from our people in the production. For us in the QA it is the normal thing that you should not wear it when producing food products, but we do not find a document, a customer requirement or standard that we can show.
They make a fuss around it now, that we can not forbid it if we can not show any evidence.
You find everywhere no varnish fingernails and no juwellry but nothing about make-up. Can anybody help me with this? We are located in Europe and produce Cocoa Products.

thanks you very much!

This topic is interesting as this is one of the grey area in food safety.

As for our standards, we did not include the no make-up/cosmetic policy as most of our people do not wear it or either wear it lightly. Plus the fact that their whole face is covered anyway with the head gear and the face mask, so no point really in having it. But if i see someone with a heavy eye shadow, i make it a point to approach the staff and remind her of the consequences if it would be included in the food.

But yes, as we are so specific with clean, trimmed, unvarnished finger nails, we must include the make-up thing to avoid grey areas. I'll definitely include this in our HACCP review soon.


Majoy

[Charles.C]

Dear Majoy,

we must include the make-up thing to avoid grey areas.

Thks for the comment.

Prioritisation plus scientific validation is perhaps a more efficient safety policy?.

The mouth / face mask similarly appears to have a (remarkably?) low priority in Europe. Perhaps no meaningful validation could be found ?.

And please try and remember to post again when you can find some kind of validation.

Rgds / Charles.C

[GMO]

I find rules are best as yes or no, black or white; if you allow grey then individuals are able to determine what shad and then the consistency and control is gone.

I'd like to know the clause and wording that covers this in the various standards such a BRC, IFS, SQF etc. If anyone can copy that here. I'm quite surprised by your view point on this GMO as I had you down as uncompromising when it comes to hygiene - are you softening?

I do have a grey area you know and have worked in production before and so can see "both sides". Personally I would rather fight my battles on things which I feel constitute a real risk. The reason I say this isn't worth fighting for is because I worked in a factory where "no makeup" was the rule. Didn't bother me as I rarely wear any anyway but it bothered a lot of the older women; they felt insulted and demeaned by it. For me, losing the goodwill of a large portion of your workforce is not worth it for something that isn't really a risk. When I could make the rules, I always said "no heavy makeup" and never had a problem with people taking the p$$. If you are really worried, why not say "foundation and concealer only" as many women would be happy with that.

I'd much rather spend my time talking to people about handwashing with some really good reasoning on why and how they should do it rather than a rule I can think of no strong reason to have. After all, it would have to be properly caked on to be a risk; to me it the rule seemed to have more of an aesthetic reason than a food safety one. If that is your reason then IME you shouldn't hide behind food safety as it devalues you in the eyes of your staff.

[Inesa]

When I could make the rules, I always said "no heavy makeup" and never had a problem with people taking the p$. If you are really worried, why not say "foundation and concealer only" as many women would be happy with that.

Just a small comment: I can see foundation on the paper after I've blown my nose. For sure, foundation remains on my fingers when I touch my face. Do I hurry to wash my fingers because of that? No. Our faces don't absorb foundation it remains as an outer layer. We don't know what can stick to it. Some women use lot's of it, and they hurry to put it (fix it) during breaks.

It might be ok in dry production areas, but where is heat and sweat I would keep it unacceptable

p.s. I can imagine that it's difficult to change rules and old habits, much easier to tell to new employee "no cosmetics here" (or find another job) I think each place/ production is different and the situation must be evaluated from hygienic side.

Edited by Inesa, 06 December 2010 - 10:37 AM.

[Charles.C]

Dear All,

My prediction is you will find no specific ban.

I guess one can’t be right all the time. Only females have that power.

6.2 Personal Hygiene
A.Personal hygiene is a most important element of health quality assurance in a fish processing plant. According to Thorpe (1992) the essential requirements for personnel working in production area and stores are those mentioned below:
1. Protective clothing, footwear and headgear issued by the company must be worn and must be changed regularly. When considered appropriate by management, a fine hairnet must be worn in addition to the protective headgear provided. Hair clips and grips should not be worn. Visitors and contractors must comply with this regulation.
2. Protective clothing must not be worn off the site and must be kept in good condition. If it is in poor condition the supervisor should be informed immediately.
3. Beards must be kept short and trimmed, and a protective cover worn when considered appropriate by management.
4. Nail varnish, false nails and make up must not be worn in production areas.
5. False eyelashes, wrist watches and jewellery (except wedding rings or the national equivalent, and sleeper earrings) must not be worn.
6. Hands must be washed regularly and kept clean at all times.
7. Personal items must not be taken into production areas unless carried in inside overall pockets (handbags, shopping bags must be left in the locker provided).
8. Food and drink must not be taken into or consumed in areas other than the tea bars and the staff restaurant.
9. Sweets and chewing gum must not be consumed in production areas.
10. Smoking or taking snuff is forbidden in food production, warehouse and distribution areas where 'No Smoking' notices are displayed.
11. Spitting is forbidden in all areas of the site.
12. Superficial injuries (cuts, grazes, boils, sores and skin infections) must be reported to the medical unit or nurse via the supervisor and clearance obtained before entering production areas.
13. Dressings must be waterproof and contain a metal strip as approved by the medical unit.
14. Infectious diseases (including stomach disorders, diarrhoea, skin conditions and discharge from eyes, nose or ears) must be reported to the medical unit or nurse via the supervisor. This also applies to staff returning from travel abroad where there could be a risk of infection.
15. All staff must report to medical unit on return from both certified and uncertified sickness.

http://www.fao.org/docrep/w0495e/w0495E06.htm

B. The presence of loose jewellery is a very high risk for foreign body presence in food products. Only single chain wedding rings might be allowed. Other jewellery including any type of body piercing should be prohibited. Similarly face make up, nail varnish are sources of foreign bodies in the product. Injuries from stones present in the food product are very common. These foreign bodies may cause injuries, they may be a source of contamination and finally they are loathsome for consumer. Perfume or after shave worn by the personnel are as important because they cause odour contamination.

http://www.unido.org...mtHygiene.4.pdf

Rgds / Charles.C

PS Cute Avatar

[GMO]

Just a small comment: I can see foundation on the paper after I've blown my nose. For sure, foundation remains on my fingers when I touch my face. Do I hurry to wash my fingers because of that? No. Our faces don't absorb foundation it remains as an outer layer. We don't know what can stick to it. Some women use lot's of it, and they hurry to put it (fix it) during breaks.

It might be ok in dry production areas, but where is heat and sweat I would keep it unacceptable

p.s. I can imagine that it's difficult to change rules and old habits, much easier to tell to new employee "no cosmetics here" (or find another job) I think each place/ production is different and the situation must be evaluated from hygienic side.

We have had "if you touch your face you wash your hands" rule in every place I work in, so IMO you should wash your hands if you touch your face. There are microbiological (s. aureus) reasons for that, whereas there is no food safety risk I can think of if some foundation did get in your food; (unlikely though I think that is). Admittedly my experience has mainly been in cold environments.

As you said, each production environment on its merits. If I found people being ridiculously excessive, then I might bring in a "no make up" rule but I haven't. Just like I trust people not to bring nuts in with their sandwiches; I don't check each lunchbox. I think sometimes it pays dividends to treat people like adults and fight the really important battles rather than the petty ones and IME people find this to be petty.

[Inesa]

quote name='GMO' timestamp='1291651975' post='40051']
We have had "if you touch your face you wash your hands" rule in every place I work in, so IMO you should wash your hands if you touch your face. There are microbiological (s. aureus) reasons for that, whereas there is no food safety risk I can think of if some foundation did get in your food; (unlikely though I think that is). Admittedly my experience has mainly been in cold environments.
[/quote]


By not washing my hands, I mean generally, that most woman don't see make-up as a dirt until the end of the day.. It's invisible on hands. Make-up is not a dirt until it comes on a white dress...
In food production it should be treated as a dirt as all other dirts no matter how often they wash hands.

Another question, what is a "heavy make up"? Why the foundation is more "lucky" than others? It's the same cosmetics. Probably same amount mascara can fell down to food with tears as foundation in tears. Depends on if it's water resistant.
Lets take other make -up. Lipgloss, lipstick or eye shadows, eye-pencils. All of them are same creamy stuff just like foundation. (shadows can be dry powder) The only thing foundation wins is the neutral colour.

Theoretically I can only see here a "yes" or "no" about cosmetics. If Yes- make up must be "invisible", only neutral colours, so you pretend that everyone is clean
But if you seek a high degree of personal hygiene you say No.

Practically things are always much more complicated, I don't have same big experience as GMO, and I believe what she says.


Men say: woman is as a wall, minimal paint is needed

Best regards
Inesa

[Charles.C]

Dear All,

Assuming that any response to make-up is based on an objective risk assessment , it seemed to me that there are some similarities to jewelry. Both hazards surely of low/very low occurrence, severity chemical vs physical (mainly).

So one might hv thought make-up more hazardous than jewelry. How about beards ? False nails ? One suspects that a subjective factor is also present.

My guess is that BRC simply looked at a range of available GMP / HACCP documents etc and followed the majority opinion.

Some knowledge of the other standards opinion regarding make-up would be interesting. Nil ??

A purely subjective decision is easy – ban everything.

Rgds / Charles.C

[GMO]

Kinda having everything I write picked apart in the minutest detail here!

Ok, no foundation and concealer aren't much different to lipstick (but I was suggesting a compromise position for something I disagree with anyway so you could avoid eye make up) but I would argue they are different to mascara which if applied very heavily could flake off.

Ok - makeup cannot fall off on its own (unless very heavily applied mascara). Jewellery can, especially "butterfly" backed earrings, stones in necklaces and rings etc; also complicated jewellery on the hands makes hand cleaning difficult. If a piece of jewellery fell into food it could harm someone (e.g break a tooth), a flake of mascara is not a chemical hazard, you will not be poisoned by it and are unlikely to see it so there is no "urgh" factor either. As I said anyway, I would include mascara in my definition of "heavy make up".

You shouldn't go "oo look, my hands look clean therefore they don't need washing", you don't rely on people to only wash their hands when they look dirty therefore makeup not showing up on hands is a moot point. In GMP training on starting, it is clearly stated that whenever my staff touch their face they must wash their hands.

All I was trying to say is that there are more important hazards. If you want to do this; go ahead but I'm just speaking from experience on working in sites where they have had this rule and where they haven't and I have found it causes a lot of resentment and alienation for IMO no good reason. After all if you can't convince me it's a good rule to have how will you convince someone on the shop floor? Likewise if people are waiting till their hands look dirty to wash them you have much bigger problems on your hands (if you excuse the pun.)

[Anne Z]

I agree with GMO...there are more important hazards. I don't think you will die from a little bit of mascara in your food. If someone died of some make up in food please let me know.

How about beards...when is it too long? I think you should consider the production area and the risks before you can so yes or no. Every situation is different.

[sabarina]

Another:

Regulation 852/2004 Annex II- Chapter VIII
Personal hygiene:

1. Every person working in a food- handling area is to maintain a high degree of personal cleanliness and is to wear suitable, clean and, where necessary, protective clothing

Is that not enough? I don't keep a person clean if it has cosmetics on...

Where is a problem? If you seek for a high degree of cleanliness you say no to cos metics, thats all

agreed with u inesa...Malaysian Food Act 1983 amendment 2009 also mentioned this clause 1) maintain a high degree of personal cleanliness includes the keeping of short and clean fingernails..
women with make up is considered cosmetic is put on your face..this must be removed which also mean 'clean' it before you go to sleep.we usuallu dont sleep with make up..am i rgiht?..so does it mean when the make up is on our face, it is considered not clean... isn't?

[Simon]

This is proving to be quite a controversial topic.

[Inesa]

You shouldn't go "oo look, my hands look clean therefore they don't need washing", you don't rely on people to only wash their hands when they look dirty therefore makeup not showing up on hands is a moot point. In GMP training on starting, it is clearly stated that whenever my staff touch their face they must wash their hands.

Dear GMO,
thanks for this discussion it gives stuff to think about.
My point was, that maybe women don't realize that cosmetics "moves" from the face to the other parts of body

hands or neck-->clothes

I have a suspicion that it can also serve as better transmitter of microbes from face pimples, as it's sticky. It can also move to clothes together with a sweat if applied on the neck or from dirty hands. Do people feel to wash hands when they touch work clothes?

It's just an one of explanations I would give if someone would ask me to explain the reason for banned make-up.

And of course everyone has to wash hands frequently no matter if they look dirty or clean, or if they touch a face or a rump.

As Charles says, risk assessment is needed, every situation is different.

Respect
Inesa

[Simon]

I wonder what an auditor from Tesco or Marks & Spencer would say about this?

[Inesa]

agreed with u inesa...Malaysian Food Act 1983 amendment 2009 also mentioned this clause 1) maintain a high degree of personal cleanliness includes the keeping of short and clean fingernails..
women with make up is considered cosmetic is put on your face..this must be removed which also mean 'clean' it before you go to sleep.we usuallu dont sleep with make up..am i rgiht?..so does it mean when the make up is on our face, it is considered not clean... isn't?

exactly Sabarina,

In the end of the day we treat it as a dirt- we clean before we go to sleep.

I try to imagine staff that just have put a clean white shirt on and suddenly neck became brown from foundation. Would it be attractive for the consumers if they saw it?

I think when it's only few staff and you know all, trust them and can observe their behaviours it's maybe possible to make compromises. But when it comes to many people it's hard to be flexible and be friends with everyone..

Edited by Inesa, 07 December 2010 - 11:22 AM.

[Charles.C]

Dear All,

Perhaps a by-product but a genuinely fascinating exposition on feminine night-time practices.

A little more food input –

Make-up/cosmetic/mascara do not appear in SQF 2000 or its associated guidance text.

Expanding my previous post, 2 particular list approaches are maybe in use –

(a) an indiscriminate compilation of all possible hazards, often associated with mainly NO criteria. Exceptions due to aspects like local culture, medical devices, regulatory allowances etc may nonetheless be include.
(b) A list with some (mainly implicit) use of risk assessment, possibly often due copying rather than intentionally science based.

I suggest that where a list uses any HACCP-type prioritisation, the ranking could vaguely follow something like –

1. high / medium likelihood of occurrence of a microbiological hazard, eg direct / indirect contact to food (eg, clothes, hair, hands/ gloves, [some] jewelry, spitting, mouth/nose/face – touching)
2. high / medium likelihood of ocurrence of non-micro hazard, eg direct contact to food (eg 1 step process, eg false nails, nail varnish, [some, loose] jewelry)( physical / chemical weighted similar to be concise)
3. lower likelihood of ocurrence of non-micro hazard, eg indirect contact to food (eg 2 step process, eg make-up)
4. (perhaps = 3), likelihood of occurrence is problematic, ie contact to food could be direct and perhaps micro.related but is not easily assessed (eg [some] body jewelry, lip-rings, tattoos)


My list is (obviously) somewhat contrived, ie partly deduced from observations of items which are frequently not included in “hit-lists. For example, some (to various degrees) ins/outs are make-up, wrist watches, beards, spitting, perfume, after-shave, lip-rings, tattoos. Spitting is an exception to my suggested ranking, maybe in some locations simply regarded as inconceivable. Buttons (appear in BRC5) have yet to see anywhere else (not in SQF 2000).
Another factor in previous paragraph is that a ranking may, like the first (a) method, be interacted by culture / regulatory / medical factors, etc.
And yet another possible interaction of particular relevance to the make-up hazard is, as GMO pointed out, the possible existence within the list of a specific hazard control measure (CM), eg an (implicit/explicit) requirement to wash hands after touching face/mouth/nose. In practice, I would have guessed that the effectiveness of such a CM is similar to tossing a coin.

Rgds / Charles.C

PS - just noticed that some make-ups are apparently (skin) allergenic, relevant or red herring ?? maybe irrelevant food consumer-wise in view of still common use of latex gloves, eg see -

 revision swiss food law 2006, enews_9_e-1.pdf   714.98KB   122 downloads