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Are hairnets required in Self Adhesive Label Printers?

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STICKY13

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Posted 01 August 2011 - 11:01 PM

I work at a self adhesive label printers who are compliant with BRC regulations and certified. For years we have not had to wear caps/hair nets and this was the case when we passed the BRC accreditation. We are now owned by a larger company and they are now insisting on us wearing caps/hair nets. I don't understand that if it was good enough for us to pass an inspection whilst not wearing them then why would that now change. It does seem to me that it all depends on who does the inspection and exactly how they interpret the rules and regulations. Due to an email telling us to wear them now, I do wear mine ( as it was sent in a uniform pack although no one else recieved one). My manager though has a moustache and I was wondering, If we all have to wear these caps/nets then does he have to wear one of these 'snoods' for his moustache?
On another note, despite all of the BRC regulations and inspections, my local supermarket dont seem to clean the trolly handles or baskets. Even if everything inside the store had arrived perfectly clean, this lack of cleaning would negate any steps taken so far as 99% of shoppers use either a trolly or basket.
Any advice and info much appreciated.



Dr Ajay Shah

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Posted 02 August 2011 - 07:21 AM

Hello Sticky 13,

I do agree with what you have said and it do feel for you. It is all about conducting risk assessment and analysing the risk and the chance of it occuring. If hair happen to fall onto the sticker and attach then it would appear unsightly even if the sticker was placed on the outside of the packaged product. it is littele things like this that will make a difference and it is good from a due diligence perspective.

I do agree that supermarkets should have a policy of cleaning their shopping trolleys / baskets on a cleaning schedule or cycle as they seem to demand everything from manufacturers and they should also be doing their part.

Cheers


Edited by Dr Ajay Shah, 02 August 2011 - 07:21 AM.

Dr Ajay Shah.,
BSc (Hons), MSc, PhD, PGCE(FE)
Managing Director & Principal Consultant
AAS Food Technology Pty Ltd
www.aasfood.com


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Foodworker

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Posted 02 August 2011 - 09:01 AM

With respect to your BRC/IoP certification, the auditor's position is likely to be correct.

If your labels are not for direct food (or other high risk product) contact then you would have been Category 2 or 3 for Issue 3 of the Standard. Only Category 1 had the requirement for scalp or beard/moustache covering, and then only if a hazard analysis had identified a risk.

If you do make labels for direct contact, you will fall under the High Hygiene risk category of Issue 4 of the Standard and again you only need to wear them if a risk has been identified. (6.56 & 6.57)

If you don't make for direct contact, Issue 4 has made it a bit more complex in determining which risk category you fall into, partly because of the BRC's inconsistent use of the words "absolute barrier" (in the decision tree) and "impermeable" (as an example in Appendix 2)

For example, if you made self adhesive labels which are applied to a paper or perforated film bag used for bread such as in an in-store bakery you would come into the High Hygiene risk category.

Your new owners may have different reasons for making you wear hair covering outside of the BRC requirements - standardisation, marketing etc (or even just lack of understanding) and in reality, if they make the rules you have to obey them.

The supermarkets universally take the approach of do as I say, not do as I do, and some of the practices I see in stores makes me cringe. Washing trollies and baskets is just one of a long list of things that would not be permitted by the BRC or even the supermarkets' own technologists if they saw them in a supplier's factory. Unfortunately, they rule us.



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GMO

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Posted 02 August 2011 - 10:53 AM

The supermarkets universally take the approach of do as I say, not do as I do, and some of the practices I see in stores makes me cringe.



Yep, the trolleys aren't your problem. You just have to work on what you control. I say, ask the reason for the change and challenge it if you don't think it's justified. Interestingly version 6 of the food standard (mine's in the post...) I believe makes a clearer demarkation between areas and product risk.

On supermarkets, don't get me started. I once got sworn at by suggesting tipping packets of bacon on the floor before stacking them in the chiller was unhygienic! I have decided not to buy food from the deli counter after looking at the slicer hygiene, the person on the counter said "well, I could clean it for you", I replied "no, clean it because it needs cleaning!" Last time I looked at the deli counter the woman had multiple ear piercings and long, painted, acrylic false nails! I said to her "if you worked in my food factory, you'd be sent home"!


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