7.2.2 Personal Hygiene - Hand cleaning on entry to production areas

Please can anyone give some advise on the following clause:


BRC Section 7.2.2 Hand cleaning shall be performed on entry to production areas and at a frequency that is appropriate to minimise the risk of cross contamination

Is the clause asking for hand washing to be the last step before entry or that hand washing should be carried out before entering a production area.

The procedure in our low risk areas is Hair net, Boots, Hand wash, coat and then enter production area. Do we need to add another handwashing step?

Dear Techny,

This requirement asks for hand washing before entering the production area. It does not say where this hand washing needs to be performed. Your procedure seems fine to me.

Can you explain to me, what you think is different between hand washing to be the last step before entry and hand washing should be carried out before entering a production area.
Staff should not wash there hands and then go to canteen/ toilet/ storage rooms/ offices/ etc. before entering production area.
This requirement says that each time you enter the production area, hands should be cleaned. A disinfection gel is no enough.

Dear Techy,

Offhand i would say it is impossible to give a meaningful answer due to insufficient info. Product / process / layout probably.

Rgds / Charles.C

Hi Techny

Your procedure looks good assuming that after the donning procedure you describe above there is a hand washing step. I have seen this step addressed in a number of ways including a dedicated 'hygiene junction' before production or washing inside the preparation area near the door entrance.

In some high risk cooked meat plants supplying retailers I have observed a two stage hand washing procedure whereby employees wash their hands in a dedicated unit before changing into protective clothing and wash their hands again after changing prior to entry into production.

George

Dear techy,

The procedure in our low risk areas is Hair net, Boots, Hand wash, coat and then enter production area. Do we need to add another handwashing step?

The simplest general answer (but not necessarily the BRC one for yr case) is yes, if yr situation requires it.
There is also a possible overlap with what the Americans call a sanitising hand/glove-dip station, standard practice in many countries for some products although i expect BRC/UK do not use this practice

Rgds / Charles.C

Dear Techy,

This might be of your interest regarding hand wash facilities. It is extracted from the FAQ published by the BRC.

Clause 4.8.6 dictates the requirements for hand washing facilities to be used before entering production. Does this mean that roller towels can’t be used?
This requirements clearly specifies what can and can’t be used and includes that roller towels cannot be used at hand washing stations in production areas as they are not ‘single use’; they can however, be used in toilets but only if they are not the only facilities provided before re-entering production.

Clause 4.8.6 Is there a relaxation of the requirement for hand cleaning facilities in low risk factories for example flour mills, breweries, produce pack houses.
There remains a requirement for providing hand cleaning facilities to enable employees to wash their hands before entry to production areas (note this may be in a changing or toilet area). The use of gel sanitisers alone does not provide a suitable alternative as this does not clean the hands but provides only a partial sanitising effect.

Thank you all for the replies.

Is the clause asking for hand washing to be the last step before entry or that hand washing should be carried out before entering a production area.

The procedure in our low risk areas is Hair net, Boots, Hand wash, coat and then enter production area. Do we need to add another handwashing step?

IMO hand washing should be the very last step before entering the production, as you touch your hair to put hair net, you touch boots, generally getting ready, maybe blowing nose? And then, when you're ready, you wash your hands and go clean and proud to meet the challenges of the day

Please can anyone give some advise on the following clause:


BRC Section 7.2.2 Hand cleaning shall be performed on entry to production areas and at a frequency that is appropriate to minimise the risk of cross contamination

Is the clause asking for hand washing to be the last step before entry or that hand washing should be carried out before entering a production area.

The procedure in our low risk areas is Hair net, Boots, Hand wash, coat and then enter production area. Do we need to add another handwashing step?

Dear Techy,

The clause simply requires everyone to wash their hands on entry to productions areas, meaning before entering a production area.

In my experience, we require everyone to wash their hands on entry to every production area. This is to reduce risk of cross contamination from hazards acquired by touching a surface, plastic strips, or any item from a certain production area since our hands are the most common vehicle for cross contamination.

just a comment to your procedure, I believe you should do it in the following order:
1. wear hairnet
2. wear boots / shoe cover
3. wear coat
4. Hand wash.


regards, foodsafetyboy

It depends on your product. BRC probably won't complain at that if it's low risk but it is atypical.

The typical procedure is as follows for low risk:

Hair net / mob cap / beard snood
Shoes (if necessary)
Coat
Wash and sanitise hands
Enter production

For high risk and high care, this is the typical procedure (which is along the lines identified by the chilled food association):

Hair net / mob cap / beard snood
Remove outside shoes
Swing legs over physical barrier
Put on dedicated captive shoes
Wash and sanitise hands (to protect the coat)
Put on coat
Wash and sanitise hands (to protect the product)

That last handwash step is sometimes just before entering production or sometimes just afterwards (I've seen barriers used to funnel people past the sink on entry which works pretty well.) The benefits of it being after entry is that you don't then touch a door handle.

What are your thoughts on visitors and maintenance? The new wording is quite clear but non specific so we just make sure everyone washes hands on entrance whether they are working with products or not. However, I now get plenty of moaning from people saying they are not working with products and their hands are drying out so why do they have to do it (mainly visitors and engineers who flit back and forth to the workshop when they find they don't have what they need for the job).

Given that we have very low risk products and enclosed processes it is difficult to justify the need so I just quote the standard and the "JFDI" I found on here is the last resort...