BRC 7.4 Protective Clothing Interpretation

We are a low risk IQF vegetable producer. We have been certified for the last 2 years. Our grades have increased from a C to an A for our facilities. Overall I think our auditor is fantastic. She is reasonable yet challenging, and has a number of good insights. Our last audit, however, resulted in a difference of opinion (amicable). We were given a minor because we do not require Management & Contractors to wear protective clothing. We do require them to wear a hair and beard net at all times on the floor. In addition, they must glove up if they must handle product. Our auditor, however, said we must provide additional protective wear to our management team. Our supervisors are provided laundered smocks or shirts. Our upper management wear their own clothes, which are laundered at home. As for contractors, they do not perform work during the season (though I see the value in having policy to handle the exception).

So here is my question(s): What clothing is required? Can we perform a risk assessment and determine what is necessary? Is it just me or is 7.4 poorly written and unclear? It just seems silly to have management wearing white smocks around the plant. They are more than visitors and that clothing is not practical. In addition, the benefit to food safety is miniscule relative to the cost to implement a full uniform program for upper management. On a final note I have another facility who has had two different auditors that did not note this finding (they have the same procedures and processes).

Bottom line I am looking for work around that accomplishes two things: 1) Keep the financial cost minimal. 2) Avoid having management wear uniforms or smocks who are on the floor frequently, but not handling product.

We also are a low risk vegetable producer, certified "A" with BRC. We met this standard by writting up a risk assessment, which has satisfied 3 different auditors.

We recently implemented uniform smocks/shirts for employees for our SQF audit, and it requires the smocks/shirts for any employee who is actively on a production line, including management/supervisors.

Say you get a policy on your uniforms saying something similar, you could also prohibit any employee/visitor/contractor from approacing your production line without said uniform. Then train and verify that floor employees know the policy and are aware they need to enforce the policy, and train non-uniform employees of the same practice. I don't know where to find text of the BRC code, but could something like that work?

As noted earlier, it will all revolve around the risk assessment. Remember, a risk assessment is not a "justification for not doing something" but a clear evaluation of the potential risks, their relevance, and mitigating strategies.

One thing to keep in mind, we need to be concerned not only about evaluating the microbiological risks, but the physical as well. Consider what physical contaminants might be carried into the open product areas (hair, pet hair, outside soil loads) that would have a negative impact on the product, should they contaminate the line, product, or open packaging materials.

For contractors working off season, I could see the risks being managed through a preseason cleaning and inspection. For contractors working while product is open, the unknowns of where they were before they come into the facility require consideration for control.

The other consideration about managers - don;t forget they set the culture of the organization. Making a statement about the effort they go through to protect the product by their actions, sets the tone for everyone else in the organization.

Happy risk assessing!

We are a low risk IQF vegetable producer. We have been certified for the last 2 years. Our grades have increased from a C to an A for our facilities. Overall I think our auditor is fantastic. She is reasonable yet challenging, and has a number of good insights. Our last audit, however, resulted in a difference of opinion (amicable). We were given a minor because we do not require Management & Contractors to wear protective clothing. We do require them to wear a hair and beard net at all times on the floor. In addition, they must glove up if they must handle product. Our auditor, however, said we must provide additional protective wear to our management team. Our supervisors are provided laundered smocks or shirts. Our upper management wear their own clothes, which are laundered at home. As for contractors, they do not perform work during the season (though I see the value in having policy to handle the exception).

So here is my question(s): What clothing is required? Can we perform a risk assessment and determine what is necessary? Is it just me or is 7.4 poorly written and unclear? It just seems silly to have management wearing white smocks around the plant. They are more than visitors and that clothing is not practical. In addition, the benefit to food safety is miniscule relative to the cost to implement a full uniform program for upper management. On a final note I have another facility who has had two different auditors that did not note this finding (they have the same procedures and processes).

Bottom line I am looking for work around that accomplishes two things: 1) Keep the financial cost minimal. 2) Avoid having management wear uniforms or smocks who are on the floor frequently, but not handling product.

Hi there,

The problem is that auditor will see this as double standards.

Is it not possible to have a 'pool' of protective clothing for upper management thus reducing the number needed to be purchased?

To justify what you are looking to do I would document and implement a policy that only personnel wearing protective clothing are permitted on production lines and to handle products. Upper management understand this policy and adhere to it (allowing them to handle products if they put gloves on does not prevent hazards such as foreign bodies from clothing).

When you carry out a risk assessment the policy greatly reduces the risks and will support your case for allowing upper management to visit the plant whilst only wearing hair protection.

Regards,

Tony