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Protective Cloth Requirements for BRC Food v6


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#1 Skye

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Posted 21 March 2012 - 01:26 PM

Hi everyone,



I am working with a potato storage, processing and distribution company who supply chips, peeled and un-peeled potatoes to chip shops, takeaway outlets, public houses and wholesalers throughout the UK. They are currently working towards BRC certification. With regards to changing facilities and protective clothing, all employees are provided with a company uniform and each employee is responsible for laundering their own uniform at home. Uniforms are put on at home and are therefore worn for travelling to and from work. On arrival at the premises, staff remove outer clothing, coats, etc. and leave them in the portacabin located in the external yard area. They then walk across the yard and enter the premises via the potato warehouse area, prior to entering the processing area they change into protective footwear and put on protective aprons. On entering the processing area they are then issued with disposable protective clothing which consists of, oversleeves, gloves and head covering.

I am obviously aware that clause 4.8.1 states that ‘changing facilities should be sited to allow direct access to production, packing or storage areas without recourse to any external area’. Due to the nature of the operation, there are a lot of dust particles in the air from the storage and initial processing of unpeeled potatoes which causes more of a contamination hazard than the outside air. Therefore, IMO a risk assessment would conclude that this is acceptable. I would be grateful for opinions on this.

Of cause the other issue mentioned above is the laundering of their own uniforms with reference to clause 7.4.3 which states that ‘Washing of workwear by employees is exceptional but shall be acceptable where the clothing is to protect the employee from the product being handled and the clothing is worn in enclosed product or low risk areas only’. I intend to have documented procedures for the validation and verification of the effectiveness of the laundering process, i.e. swabbing, washing instructions, etc. does that sound acceptable?



#2 GMO

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Posted 22 March 2012 - 08:54 AM

Hmm. A tricky one. Difficult to validate xx numbers of different employees wash processes which is why, even as a low risk site ourselves, we have a laundry.

I agree there will be soil dust as a contaminant but you're forgetting that that's not the only hazard. By allowing home laundry and wearing from home (not just walking across a yard), then you are not just exposing the product to the yard contamination.

I'm just imagining with my son. If I was using cloth nappies at home, could I wash them with my work clothing? At 30 degrees...? Perhaps there needs to be some guidance on temperature for the washing?

It's difficult the argument re dust as well. If you brought that up, an auditor could say "control the dust then".

My gut feel is having these uniforms is no better than allowing staff in with their own clothes. Would it not be possible to have a small area where people put on boots, mobcaps and a coat over their normal clothing?

If I understand this correctly, they also enter in the warehousing which you've said is dusty. Would it be better if the dustiest areas are screaned off, perhaps just with plastic curtains and they enter another way?

I think there is probably some investment required here. I would be inclined as an auditor to raise a minor on the issue even if you did cover it with risk assessments because I think there is still a risk present. I'd be interested to hear what others think and what the result is. Only you can work out whether it's worth the investment prior to audit but you could always email BRC to ask for clarification on the clauses BRCGlobal.Standards@brc.org.uk

If you do decide to invest, you could think about it this way that with your current set up I don't think you could push for ready meal business but if you changed it and put in more controls, you could contact people like Northern Foods, Samworth, Bakkavor, Kerry Foods etc, etc to see if they would be interested. I'm sure all of them buy in cut potatoes for cooking in their facilities.



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#3 Skye

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Posted 22 March 2012 - 10:09 AM

Hmm. A tricky one. Difficult to validate xx numbers of different employees wash processes which is why, even as a low risk site ourselves, we have a laundry.

I agree there will be soil dust as a contaminant but you're forgetting that that's not the only hazard. By allowing home laundry and wearing from home (not just walking across a yard), then you are not just exposing the product to the yard contamination.

I'm just imagining with my son. If I was using cloth nappies at home, could I wash them with my work clothing? At 30 degrees...? Perhaps there needs to be some guidance on temperature for the washing?

It's difficult the argument re dust as well. If you brought that up, an auditor could say "control the dust then".

My gut feel is having these uniforms is no better than allowing staff in with their own clothes. Would it not be possible to have a small area where people put on boots, mobcaps and a coat over their normal clothing?

If I understand this correctly, they also enter in the warehousing which you've said is dusty. Would it be better if the dustiest areas are screaned off, perhaps just with plastic curtains and they enter another way?

I think there is probably some investment required here. I would be inclined as an auditor to raise a minor on the issue even if you did cover it with risk assessments because I think there is still a risk present. I'd be interested to hear what others think and what the result is. Only you can work out whether it's worth the investment prior to audit but you could always email BRC to ask for clarification on the clauses BRCGlobal.Standards@brc.org.uk

If you do decide to invest, you could think about it this way that with your current set up I don't think you could push for ready meal business but if you changed it and put in more controls, you could contact people like Northern Foods, Samworth, Bakkavor, Kerry Foods etc, etc to see if they would be interested. I'm sure all of them buy in cut potatoes for cooking in their facilities.



#4 Skye

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Posted 22 March 2012 - 10:11 AM

Thanks for your comments, I will take them into consideration. I think that I will ask the same questions to the BRC and see what sort of response I get.



#5 gloriaeho

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Posted 22 March 2012 - 11:25 AM

Hi Skye,

I'm afraid I agree with GMO on this issue . . and I've got to say that if I were a BRC auditor (have done them in the past . . long, long ago, in another galaxy . . ) I would be giving you a minor on the washing of protective clothing at home and wearing it to come to work and unfortunately, possibly a major for the contamination risk to the processed product from the clothing and dust.

You say that the staff come to work in their protective clothing underneath their outer clothing and then remove their outer clothing and leave it in a portacabin. Would it not be better for the staff to come to work in their normal clothes, change into protective clothing provided for them in the portacabin and then make their way into the processing area? If you have a laundry service, the protective clothing can then be laundered and kept in the portacabin.

In terms of health and safety, to have your staff changing into protective footwear after they have moved through the potato warehouse might also pose a forseeable risk to safety.

IMHO clause 7.4.3 is intended to deal with the situation where the protective clothing only performs one function, to protect the worker from the product or from other materials, for example if the product is a corrosive/toxic chemical contained in packaging, but with the risk of residual chemical on the packaging or risk of soillage/breakage or for example in engineering areas or loading bays (low risk areas). I don't think it is intended for use in areas where low risk food processing is carried on.

In terms of the contamination risk from warehouse generated dust, I am assuming that you use forklift trucks and rollertrucks to move pallets around and stack them, and although you don't mention it, from what you do say, I have a feeling that deliveries of potatoes and finished processed product go straight into/out of the warehouse through the same entrance as the staff. If this is the case then the risk isn't just dust from the potatoes in the warehouse. There may also be a risk from external dust, airborne debris, vehicle exhaust emissions etc.

Producing peeled and chipped potatoes means that you may be treating the peeled/chipped potatoes in some way to de-contaminate them during processing, perhaps with water containing Sulphur Dioxide or raised levels of Chlorine? The dust from potatoes in the warehouse isn't just potato dust, its basically the earth they were grown in and small fragments of potato skin, other dust particles and airborne debris, and is very likley to contain all the bacteria, viruses, moulds, fungi etc., normally found in soil, including food poisoning bacteria. Having the potential for this dust/debri to to get into the processing area and the processed product, either on personnel protective clothing, or just simply by being airborne, is something which the auditor may consider to be a major deviation. From your company's point of view too, if the product is being contaminated by the dust/debris, then you are probably wasting your money on de-contaminating the product during processing because the presence of the dust defeats the object of doing this.

Again, IMHO, I would either have the production area accesses totally separated from the warehouse, or at least, have an intervening ventilated space in the access to the production area to mitigate the risk of dust getting into the production area, using a slight positive pressure in the IVS. Both of these would then permit staff changing into protective clothing adjacent to the production area without the need for them to expose their protective clothing to contamination by walking through the warehouse. If you were able to re-position the portacabin to an external wall of the processing area, you might be able to open up an access route with an IVS thay way and seal off the access from the warehouse. This would achieve all the objectives of the requirements and improve staff/warehouse safety too.

AS GMO says, having a risk assessment won't prevent the auditor from giving you a minor (or a major) contravention, if the risk is still present. It might actually make things worse, because you have identified a problem and haven't done anything about it other than document the risks . . and in truth this may incur another contravention. Whereas, making the relatively small investment, might present added business opportunties for the company, not just with people like Northern Foods, Samworth, Bakkavor, Kerry Foods etc, but also the NHS, Education Authorites (schools) and Social Services/meals on wheels, Univerisites and Colleges, large residential care home businesses and distributors such as Brake Brothers and 3663, and you could also increase your catalogue of finished processed product to include other vegetables/fruit as well.

Anyway, apologies for rattling on a bit! Nuff' said!

Regards

Gloria



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#6 GMO

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Posted 22 March 2012 - 11:59 AM

^^ What she said, more eloquently :thumbup:



#7 Skye

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Posted 22 March 2012 - 02:25 PM

Unfortunately, the company went ahead and bought uniforms for staff without letting us know, so rather than having to tell them they have wasted their money I have been struggling to find a way round the situation. In the end I totally agree with all comments made thus far and intend to address the matter with the directors next week.



#8 gloriaeho

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Posted 22 March 2012 - 03:04 PM

Hi Skye,

I don't think (and I'm sure GMO will agree with me on this), your client has wasted money buying uniforms/protective clothing for the production staff . . production staff should have proper protective clothing, they just need to have appropriate arrangements in place for the laundering and storing of them and and adequate changing facilities. TBH I think the bigger problem is definately the contamination issue.

Good luck with your meeting with the Directors next week . . I would be interested to hear from you how that goes!

Regards

Gloria



#9 Charles.C

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Posted 22 March 2012 - 04:31 PM

Dear Skye,

This thread has somewhat strayed from the original post so i will add to the OT. :smile: I am not exactly sure what the term "direct" access means in the quoted 4.8.1 however many facilities i hv audited (not for BRC) contain intervening connections by design, eg an in-line, screened, hand-dip stage. Personally, I see no objection to such ?

IMEX in seafood industry, it is almost hygiene 101 that where the first stage of a process has a significantly "dirty" scenario (eg inky whole squid) where quality (especially, but not only, safety related) concerns are involved, it is often standard practice to implement some form of segregation. Some countries go even further, for example requiring final pre-freezing stages of an intended frozen raw , non-RTE product to be segregated from the central steps resulting in at least 3 segregated areas. I am curious what typical format applies in the potato industry as referred here ?

IMEX the issue of substantially changing clothes as against simply adding (demarcated) protective over garments was hardly mentioned 15-20 years ago for low and high risk commodities but has become progressively emphasised for both in recent years. The ideal situation is I suppose self-evident but I hv never actually seen any reported data on perceived consequences ? It may also overlap cultural issues similar to the difficulties over setting absolute standards for jewelry.

Additionally the aspect of in-house but out-door eating facilities in break periods can be another grey area involving changing of clothing.

As a more quantitative adjunct to the previous discussion, i assume you are producing the finished product to some kind of specification ?. Including microbiological criteria ??. Assuming yes, has there been any suggestion that the finished product has been contaminated from the, presumably, more bacterially loaded outer peel, environmental debris etc. An obvious comparison would be with respect to the results for a "hygienically" peeled test sample.

Rgds / Charles.C


Kind Regards,

 

Charles.C


#10 Cranberry

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Posted 22 March 2012 - 04:54 PM

Having worked in a vegetable processing facility there is a certain amount of scope for having 'dirty areas’ around goods in/preprocessing and presumably your HACCP controls contamination issues during processing (peeling, washing, sulphites?). My concern with washing at home and BRC v6 would be the lack of control you have over the laundering process with regards to allergens and microbiological/chemical contamination of the PPE. A decent contracted laundry service should have validated procedures in place regarding washing of mixed loads, time/temperature of the wash, allergen cross-contamination. I had a conversation with an auditor during my last BRC audit about allergens on PPE at a nut free site.



If you can validate the controls you have in place, then you could cover yourself but it seems like a bit of a headache to me.



Best of luck



#11 GMO

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Posted 23 March 2012 - 06:55 AM

Just a quick fourpenneth, just because clothing has been purchased does not mean an external laundry cannot process it. You don't have to hire clothing through a laundry. Many people do as it can work out to be more cost effective but as you already have the workwear, it seems sensible to use it as long as the design is ok.

In reply to Charles, in section 4.8.1, "direct" I believe means "without going outside" and is in relation to where people get clothed not the product. There is provision to clean shoes but I suspect that the auditor would think travel through an external area should be exceptional if present at all.

So, here's a first step "halfway house" if you like which isn't going as far as I would eventually like but it is progress:

Move the portacabin to the side of the building and put a direct door into production.
Allow staff to wash clothing at home but insist on them changing at work.
Issue guidance on clothing washing including temperature and suitable / unsuitable items to wash with them.
Do clothing swabs.
Screen off the dirty from clean sides within your production process, this could be as simple as using plastic curtains.

I reckon you could do all of the above for less than £500.



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#12 D-D

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Posted 23 March 2012 - 08:42 AM

We picked up a minor because we have mulitiple buildings with people in and out all day. Our lads also have uniforms/work wear and we were told that we could overcome that by having a "top layer" work coat that is removed before going outside and remains in the work area. So the question here might be, is your "uniform" your protective work wear or is it really the apron, oversleeves, gloves etc? If you have a full length apron and oversleeves (I assume it they are daily disposables?), maybe that is your protective layer and the uniform is no different from personal clothing...? Just a thought.



#13 wijit

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Posted 23 March 2012 - 09:59 AM

Interms of uniform, I have worked at sites where colleagues have t-shirts/polo shirts and sweat shirts issued, which are laundered at home, but once at work these are worn underneath whites and work issue trousers. The question was specifically asked regarding this to our BRC auditor, who confirmed this was acceptable even on a nut free site.
I would sugest that if the clothing (all of it) is washed at home this will leave you open to how the individual auditor interprets the situation. This could in theory leave you with even a major. Although a robust swabbing procedure may ease this, I still think at least a minor would be issued, and the best thing would be to contract an outside laundry.
I would query, as mentioned in a reply above, the positioning of the portacabin and try to get it as close to the building entrance as possible. Furhter to this (and not knowing if it is already in place) I would have a maked walkway to avoid as much as possible, with safety barriers and painted with a suitable paint which would make cleaning easier. This would help to minimise cross-contamination.



#14 Bag man

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Posted 23 March 2012 - 10:21 AM

Hi All. John here.

I have only quickly glanced through the foregoing so forgive me if someone has already covered this.

I should state that my company does not directly handle food, but supplies food contact packaging to the industry.

The arrangements I have in place meet the requirements of the BRC Packaging Standard (High Risk) Grade A.

  • Staff are permitted to launder their own protective clothing if they wish. Appropriate training is given and laundering instuctions (as per the garment manufacturer) are issued to those individuals who do not want their clothing put into the company laundry.
  • Protective clothing may not be worn off the premises.
  • Polythene bags are provided for the transport of clean protective clothing to work.
  • Further washing instructions are posted in the staff changing areas along with notices to say that personal and protective clothing should not come into contact.
  • Changing facilities are part of the hygiene controlled area and in the form of a direct route from the outside world that opens into production without having to pass through uncontrolled areas.
  • Protective clothing is regularly inspected/audited.
I hope this will be of some small assistance.
Best wishes,
John.




#15 Harminnie

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Posted 25 March 2012 - 08:51 PM

We used to have employees wash/dry clothes at home and wear them in. We then compared ATP and plate results on their home laundered clothes, and our inhouse laundered uniforms. Inhouse definitely won. So we searched all over for info about how to wash and dry to kill the most germs and came up with an inhouse procedure. We periodically verify with a test. So, a less expensive option may be to get your employer to install a washer and dryer on the premises, and then establish your prodedure for inhouse washing and drying. We are not a high-care or high-risk production site. I've attached the instruction sheet I posted at the washer/dryer for those who are challenged by them or have panic attacks when they approach one, or for those who have never seen one before i.e. most male species! :whistle: Good Luck

Attached Files



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#16 Charles.C

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Posted 26 March 2012 - 02:39 AM

Dear Harminnie,

Thanks for yr input.

Not sure what kind of (food) process is involved but yr attachment rather suggests an uncontrolled, self-service launderette. Seems rather debatable.

Perhaps I have misunderstood the implementation. :smile:

Rgds / Charles.C


Kind Regards,

 

Charles.C


#17 GMO

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Posted 26 March 2012 - 03:36 AM

I think getting staff to wash their own uniforms at work is a little better than doing it at home, only points I'd make would be I'd include in the procedure a few items with the reasons why, i.e.:

Please use the detergent provided X because this has been shown to remove bacteria (germs) from the clothes
Please wash at temperature X because this helps kill bacteria (germs)
Please fully dry your clothes because this helps ensure bacteria (germs) don't grow on the clothes as they are drying

I'd also document control the procedure.

That all said, how much of your employees time does it take to do this on site? Is it worth it financially with the upkeep of the machines / detergent etc vs. a contract laundry?



#18 trubertq

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Posted 27 March 2012 - 10:59 AM

Lets expand this conversation a bit.....

First of all, my opinion on PPE is that, it is never taken home, and is washed either in house by a dedicated laundry person, or use an outside contractor. That is the only way you will have control over the wash cycles used and be sure of segregation.


We have a lady who has a launderette and is contracted to wash and dry our coats. Now we have to validate her process, as she is a sole trader and has a small business. I don't want her to lose our contract as she gives and excellent service and is flexible with regard to our busy and quieter periods. A large contractor would not provide this bespoke service IMO, plus where out factory is situated is not on the main drag, we have trouble getting couriers to deliver to us! We have used this launderette for the past 13 years and have a complete historical record of clear swab tests.

Anyhoo....

I have made a flow diagram of her process, and have written up work instructions regarding segregation of high and low risk garments. I am sourcing detergents which are appropriate for use in the food industry, and am attempting to get the specifications for her machines.

I wonder do I have to go the extra mile and try to validate the actual temperatures of the machines and the driers. Everyone I have spoken to, service engineers etc... think I have gone potty.... personally I don't know how I would even start to validate a washing machine... or a tumble drier, surely the tumbling action would play havoc with whatever instrument you put in there...

If you guys think there is something else I can do to validate this lady's process would be greatly appreciated.


I'm entitled to my opinion, even a stopped clock is right twice a day

#19 Cranberry

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Posted 27 March 2012 - 11:40 AM

Just had a flick through the HACCP for our PPE provider and they do indeed use calibrated washing machines and drying tunnels and record temperatures of each load.

How far you have to go to validate the process used by your laundry would, I guess, depend on your product and product risk. BRC6 requires you to audit the laundry to ensure they operate procedures that are affective and leave the clothes commercially sterile after wash/dry. If you can put in place procedures for the laundry and validate the results you could demonstrate some control over the process. You would probably need to monitor the performance of the systems to show compliance.



#20 Kamwenji Njuma

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Posted 27 March 2012 - 12:24 PM

Hi Skype i would also agree with GMO on high possibility levels of contamination for allowing staff to go home and launder the "PPEs".Also i would give aminor non conformance as you have not shown anywhere that these clothing from home are sanitised to reduce any microbial load thus you end up easily contaminating the potato chips albeit low risk product which i presume is wash and cook.Thus instead of disposable aprons,head gear ,etc,you should advise the management to provide clean dustcoats and head gears which should be laundered at the workplace and should never leave the site.You can get some members of the hygiene team to do the laundering if the company finds it a cost to hire a laundering company.

Regards,
Kamwenji Njuma



#21 trubertq

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Posted 27 March 2012 - 03:06 PM

Just had a flick through the HACCP for our PPE provider and they do indeed use calibrated washing machines and drying tunnels and record temperatures of each load.

How far you have to go to validate the process used by your laundry would, I guess, depend on your product and product risk. BRC6 requires you to audit the laundry to ensure they operate procedures that are affective and leave the clothes commercially sterile after wash/dry. If you can put in place procedures for the laundry and validate the results you could demonstrate some control over the process. You would probably need to monitor the performance of the systems to show compliance.


hmmm I was afraid of that......

as I said before, we have extensive records showing the laundry is doing it's job. I can't ask this lady to start monitoring machines etc, she works alone and I feel it is overkill. Unfortunately we have a high risk product ( sous vide shellfish) . I am loath to take the business away from her. I shall have to see if I can find someone who would validate the programmes in the machines. Next stop manufacturers I suppose.......
I'm entitled to my opinion, even a stopped clock is right twice a day

#22 Charles.C

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Posted 27 March 2012 - 06:45 PM

Dear All,

With respect to validation of laundrys, a little searching for something like "laundry" is suggested. More quantitative threads do exist on this.

With respect to location of washing clothing, I appreciate / applaud that "developed" countries understandably prefer to take the high ground and outsource. Unfortunately there are various locations, I suspect many, where I anticipate the exact opposite is logistically unavoidable. I suppose the originally quoted paragraph is BRC's attempt at compromise. I daresay that the validation requirement also encompasses some variations in detail / rigor.

Rgds / Charles.C


Kind Regards,

 

Charles.C





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