24 replies to this topic

[awilders]

We recently had the BRC pre-assessment and look to be BRC by next summer. We are mostly there already by the way we do things, so that is refreshing.

So one item we found was something we are not sure of, so I am asking what others are doing. The auditor had told us that no pockets on any uniform item was allowed. We have no pockets on the uniform shirts and have always been that way, but all of the pants are either slacks or jeans for the maintenance team and the sanitation team. The auditor said no pockets on pants. Is any one actually doing this, or is a risk assessment enough to allow pants pockets?

Thanks!

[D-D]

The auditor had told us that no pockets on any uniform item was allowed.

I don't see detail like that in the standard.

It says you have to risk assess so depends on what sort of product / process etc you have. We have low risk products in tanks that get filtered and have specified no pockets above waist level i.e. trousers (pants) are fine but we have changed our shirts and lab coats (actually they have no pockets on the outside now). Then again, we are not accredited yet so let's we what the others say?!

[GMO]

Hmm. I wouldn't be happy with that personally. Pockets accessible encourage using those pockets! You will then have money, sweets (candy) etc being walked into your plant, men stopping and having a rummage now and again (look, you know it happens). Are you happy with that?

I would argue if you've decided you need hygienic clothing (which you have) then it should be hygienic. Why don't you look at changing to a longer coat? That way you can still have the employees wearing their own jeans or slacks underneath but the pockets are covered so it's less of a temptation.

[Charles.C]

Dear awilders,

I suppose one possible preventive method is as usual to be draconian - the auditor's comment does eliminate the risk of a pen / watch / mirror etc being sneaked in (or falling on the floor perhaps ?)

My guess is the auditor was not too enthusiastic about wedding rings either ?

Any comment regarding zips and buttons below the waist ? Necessary evil ?

Suspicion of nit-picking IMO

Rgds / Charles.C

[Dr Ajay Shah]

Hmm. I wouldn't be happy with that personally. Pockets accessible encourage using those pockets! You will then have money, sweets (candy) etc being walked into your plant, men stopping and having a rummage now and again (look, you know it happens). Are you happy with that?

I would argue if you've decided you need hygienic clothing (which you have) then it should be hygienic. Why don't you look at changing to a longer coat? That way you can still have the employees wearing their own jeans or slacks underneath but the pockets are covered so it's less of a temptation.

I would like to see staff wearing clothing supplied by the company and all personal clothing to be placed in the lockers in the change rooms supplied.

[Dr Ajay Shah]

Dear awilders,

I suppose one possible preventive method is as usual to be draconian - the auditor's comment does eliminate the risk of a pen / watch / mirror etc being sneaked in (or falling on the floor perhaps ?)

My guess is the auditor was not too enthusiastic about wedding rings either ?

Any comment regarding zips and buttons below the waist ? Necessary evil ?

Suspicion of nit-picking IMO

Rgds / Charles.C

The best option is to wear elasticated pants and have press buttons but they are a necessary evil if they are not placed properly.

[Foodworker]

This is the last official BRC Position Statement on pockets in workwear.

Attached Files

•  FO27_BRC_position_statement_-_pockets_in_protective_clothing11.pdf   116.36KB   217 downloads

[jaredkkrischel]

Foodworker,

That was very helpful. Where can I find more BRC position statements?

[Charles.C]

Dear foodworker,

Right on the button as usual.

BRC are certainly expert at covering their diligent backs.

IMEX, auditors seem to think that below the waist, the risk is not of great significance. I suppose it might depend on the level of the table.

@ AS

The best option is to wear elasticated pants and have press buttons but they are a necessary evil if they are not placed properly

I presume you are referring to a commando type risk. No doubt BRC hv a prognostication on that also

Rgds / Charles.C

[Simon]

In my opinion if you have no pockets you can move on to the next question.

[awilders]

We currently have company supplied uniforms with no pockets, buttons, etc., above the waste. Teh pants are either blue jeans or slacks, both with pockets. Our office staff wears regular clothes, but wears a smock over them when entering the facility.

In either case, my bet would be that things like keys and money (wallets) are kept in those pockets while in the facility. I know my wallet and keys are always in my pockets. I have keys for anything locked with me at all times. So, they keys will be either in my hands, which can be dropped (and have been dropped), on a key holding device on my side, which can fail and fall (and they have here), or in my pocket, has never failed me so far. Never an incident whare the items have entered the food stream.

Foodworker, thanks for the Statement from BRC. Very helpful. I also would like to know where you get more documents like this statement.

[mgourley]

This is the last official BRC Position Statement on pockets in workwear.

I suppose this is a good time to ask for the definition of "protective clothing".
Surely a standard pair of uniform pants and uniform shirt are not "protective" other than in the broadest terms.

Marshall

[Charles Chew]

the auditor's comment does eliminate the risk of a pen / watch / mirror etc being sneaked in (or falling on the floor perhaps ?)

A good example of a "push approach" rather than a "pull approach" in food safety management but that this is expected of a descriptive standard. I guess the view of the BRC's auditor has just increased the cost of production but is the view valid when you have trainings supporting code of hygiene practices and GMP, supervision controls, environmental controls and process controls.

Are we over doing it? There are a whole lot of other concerns in the entire establishment other than just these possibilities because of some pockets in the pants...... IMO, its just getting more and more absurd. It looks like wearing space suit to work would be a practice to get used to in future.

Edited by Charles Chew, 14 June 2011 - 02:29 AM.

[FOQUS]

Hi,

I agree with the "no pockets" policy, even for below waist + would vote high for companies supplying change rooms and uniforms for work- the temptation for many workers to sneak in personal stuff into the plant seem to be so high..

Elastic pants with no zips depending on the product, table level, risk to the worker in case of magnetic attraction possibility.

But a company I worked for 2 years back had a BRC pre-audit did not have that pocket pant issue: maybe because the coat was knee length and all working surfaces were above wasit?

FOQUS

[Dr Ajay Shah]

Dear foodworker,

Right on the button as usual.

BRC are certainly expert at covering their diligent backs.

IMEX, auditors seem to think that below the waist, the risk is not of great significance. I suppose it might depend on the level of the table.

@ AS
I presume you are referring to a commando type risk. No doubt BRC hv a prognostication on that also

Rgds / Charles.C

yes Charles I was referiing to that exactly...

Cheers

[D-D]

I don't see detail like that in the standard.

It says you have to risk assess so depends on what sort of product / process etc you have. We have low risk products in tanks that get filtered and have specified no pockets above waist level i.e. trousers (pants) are fine but we have changed our shirts and lab coats (actually they have no pockets on the outside now). Then again, we are not accredited yet so let's we what the others say?!

I take it back. Indeed in the Interpretation Guideline it does say no side trouser pockets. Also, where do you get those position statements? Yet another document with further detail. Do ISO and the other standards work like this too i.e. issue a basic description in the standard that does not tell you what to do until you buy further publications from them...?

In my opinion if you have no pockets you can move on to the next question.

I like this. A lot. Also, we have a confusing nut policy (no nuts in production, canteen or sandwich boxes but okay in the offices). Nuts come nowhere near our products and the current policy is about employee convenience and tins of choccies at Christmas. [I could be even more popular by insisting on "Nut-free" - but it would make it so much easier to just move on to the next question as Simon says.]

[GMO]

Also, we have a confusing nut policy (no nuts in production, canteen or sandwich boxes but okay in the offices). Nuts come nowhere near our products and the current policy is about employee convenience and tins of choccies at Christmas. [I could be even more popular by insisting on "Nut-free" - but it would make it so much easier to just move on to the next question as Simon says.]

I agree that is confusing and I would find that confusing if I was auditing you as a supplier; in fact I'd find it so confusing, I'd raise a non conformance. What do the offices have some kind of urgent KP need?! Just ban them everywhere!

[Charles Chew]

We currently have company supplied uniforms with no pockets, buttons, etc., above the waste. Teh pants are either blue jeans or slacks, both with pockets. Our office staff wears regular clothes, but wears a smock over them when entering the facility.

In either case, my bet would be that things like keys and money (wallets) are kept in those pockets while in the facility. I know my wallet and keys are always in my pockets. I have keys for anything locked with me at all times. So, they keys will be either in my hands, which can be dropped (and have been dropped), on a key holding device on my side, which can fail and fall (and they have here), or in my pocket, has never failed me so far. Never an incident whare the items have entered the food stream.

In light of recent relelation on "no pockets below the waist" - does your company intend to use biometrics to go keyless. It would interesting to note what the response from current users of BRC-Food would be?

[mgourley]

I would still like to know what the definition of "protective clothing" is.

Marshall

[Tony-C]

I see some contradiction here in policy in that high risk is usually related to microbiological control and this relates predominantly to foreign body control.

Regards,

Tony

[Tony-C]

The auditor had told us that no pockets on any uniform item was allowed. We have no pockets on the uniform shirts and have always been that way, but all of the pants are either slacks or jeans for the maintenance team and the sanitation team. The auditor said no pockets on pants. Is any one actually doing this, or is a risk assessment enough to allow pants pockets?
Thanks!

Please let us know what sort of operation you have.

Regards,

Tony

[D-D]

I agree that is confusing and I would find that confusing if I was auditing you as a supplier; in fact I'd find it so confusing, I'd raise a non conformance. What do the offices have some kind of urgent KP need?! Just ban them everywhere!

I have since persuaded the management to go "nut-(& sesame)free" as a company. This won't be popular in the offices with their tins of Roses etc at Christmas but never mind; who's popular in a QA role anyway? At least I will have consistency across the company - being unpopular in the offices and production now.
As for the pockets issue, draft V6 seems to have relaxed this a little: it has gone from "no external pockets" to "no external pockets above the waist".

Edited by D-D, 28 June 2011 - 11:17 AM.

[Rosemary4]

In our plastic packaging factory we have trousers with side pockets. The operatives are only allowed a pen, their locker key and swipe card in their pockets. The pen is placed on the table with the machine paperwork to be completed whilst it is running and not kept in the pocket.

The Supervisors carry out a random pocket check 3 times a week at different times during the shift and I carry out a hygiene audit each month which also includes a uniform check.

This practice has satisfied our BRC auditor for the last 4 years and we have not had any incidents of lost keys or pens in our product causing a complaint so we shall carry on regardless!

[awilders]

My facility is a dry grain processing facility, producing human consumption products in bulk.

We plan on creating a risk assessment for the pockets on the pants, but the issue would be how to spot check our employees for personal items in our pockets with the staffing we have now. So many new checks and re-checks, it is fast becomming a labor adding issue to comply with any audit, thus a cost prohibitive venture that is necessary. Food Safety is always important, but the paperwork being the proof you are food safe is maybe getting a little crazy. Thankfully, our issues are just documenting our current program. Not much change in how we produce safe products, we got that covered quite well. The paperwork is the issue.

I see that the BRC Issue 6 Draft for Consultation is considering changing the uniform wording in respects to pockets:

7.4.2

· Protective clothing shall be available that:

o Is provided in sufficient numbers for each employee

o Is of suitable design to prevent contamination of the product (as a minimum contain no external pockets above the waist or sewn on buttons).

o Fully contains all scalp hair to prevent product contamination

o Includes snoods for beards and moustaches where required to prevent product contamination

[mgourley]

My facility is a dry grain processing facility, producing human consumption products in bulk.

We plan on creating a risk assessment for the pockets on the pants, but the issue would be how to spot check our employees for personal items in our pockets with the staffing we have now. So many new checks and re-checks, it is fast becomming a labor adding issue to comply with any audit, thus a cost prohibitive venture that is necessary. Food Safety is always important, but the paperwork being the proof you are food safe is maybe getting a little crazy. Thankfully, our issues are just documenting our current program. Not much change in how we produce safe products, we got that covered quite well. The paperwork is the issue.

I see that the BRC Issue 6 Draft for Consultation is considering changing the uniform wording in respects to pockets:

7.4.2

· Protective clothing shall be available that:

o Is provided in sufficient numbers for each employee

o Is of suitable design to prevent contamination of the product (as a minimum contain no external pockets above the waist or sewn on buttons).

o Fully contains all scalp hair to prevent product contamination

o Includes snoods for beards and moustaches where required to prevent product contamination

Once again, I have to ask...what is the definition of "protective clothing"? From the above snippet from BRC Issue 6 I get hair and moustache/beard nets... but those would more than likely not contain pockets in the first place, yes?
I consider "protective clothing" to be anything above and beyond a standard uniform shirt and pants.
We do not allow pockets on shirts, we do not allow sewn on buttons on any item of clothing and the only "protective" clothing we have are aprons and gloves, which have no pockets.

Good to see that Issue 6 is being realistic, otherwise I'd have a rather large bone to pick with an auditor.

Marshall