16 replies to this topic

[carine]

hi all,

 

i intend to replace hand glove to hand sanitiser, is there anything i need to take consideration before i start to implement this??

[Charles.C]

Dear Carine,

 

Yes, You need to -

(a) Validate yr decision.

(b) Consider who, or what, you have to justify yr decision to ?

 

Not necessarily in above order.

 

Rgds / Charles.C

 

hi all,

 

i intend to replace hand glove to hand sanitiser, is there anything i need to take consideration before i start to implement this??

[carine]

any idea how to validate my desiccion? it is conduct swab test by using hand sanitiser?/

[Charles.C]

simplest option. Look for a standard reference like usa food code which offers yr new idea as an option. works for validation if you follow similar procedure.

 

Rgds / Charles.c

 

any idea how to validate my desiccion? it is conduct swab test by using hand sanitiser?/

[Setanta]

State why you want to do this, why you think it is justified to make the change and how the changes you want to make will give you the same or better results.

 

Best Regards,

S.

[Antores]

Hello,

First, I’m under the assumption that the use of sanitizer (or gloves) is AFTER hand washing. Hand washing cannot be replaced and you will find it hard to justify it.

With that said, the additional use of gloves or sanitizer is a company decision, mostly based on jut risk assessment. Sometimes, the use of sanitizer can be justified just because is simpler to manage than gloves. Gloves give a false sensation on cleanliness, and you may find employees working with dirty gloves just because they feel their hands are clean. That itself can make the use of sanitizers a better option.  Some considerations are:

• Justify: Normally, just explaining in your risk assessment the reason why for that decision should be enough.  I don’t think validation would be necessary, but it might,  depending of your operation and risk.
• TRAIN: One of the mayor risks of using sanitizers is that employees believe that this is instead of hand washing. Be sure you train your employees and monitor so they keep washing their hands always before using sanitizer.
• Selection: Since the sanitizer will contact the food, be sure it is food-safe; preferable FDA or NSF approved. (e.g. no fragrance). If you have a GFSi program more likely you would need to approve the product (and Supplier), so for me an NSF certification is the easier way.
• Dispenser Type: Consider using manual/automatic dispensers. They both have advantages and disadvantages.  The obvious advantage of automatic dispenser is that employees do not have to touch the dispenser, so the risk of cross-contamination is reduced, BUT, it can make the process slower, if you have many employees who want to sanitize at a time since there is a few delay between pumps..  This can be frustrating if you have 100+ employees all trying to sanitize hands at the same time after a luch break… And finally, they use batteries, so there is something else to track… sometimes they ran out of batteries and nobody says anything, or the batteries may leak and be a source of chemical contamination.. for this reason is good add the automatic dispensers in a pre-operation check list.
• Location and Amount: Again, if you have 100 employees using sanitizer at the same time, you need to have enough dispenser to sped up the process, otherwise employees will be discouraged to wait in line to do it, and the manager won’t be happy  when he realizes how much time this add up in a week or month.  And also location, is a MUST on all hand washing stations, sometimes is good outside the bathroom, just to supervisors can see the practice.  Although some schemes ask for “additional sanitizer stations”, I don’t like to put sanitizers in places where there are o hand washing stations, because is an invitation to use them without washing their hands.
• Other considerations: Consider preventative actions (policies) for nails (short), nail polish (not allowed), and cuts (report and cover). These are more important when gloves are not used, so you may still need to have a use glove usage policy for especial circumstances, such as when somebody have a minor cut and is using a bandaid…

Hope that helps.

[Charles.C]

Dear Antores,

 

With that said, the additional use of gloves or sanitizer is a company decision, mostly based on jut risk assessment.

 

Dear Antores,

 

With all due respect i disagree.

 

IMEX, use of gloves, and particularly for RTE foods, is more often a legislation-driven issue assuming that Public Health Control systems exist at the specific location / process involved.

 

Unfortunately there is no relevant data provided on such aspects in the OP.

 

Rgds / Charles.C

[Tony-C]

hi all,

 

i intend to replace hand glove to hand sanitiser, is there anything i need to take consideration before i start to implement this??

 

Hi Carine,

 

Can you confirm what products you are working with?

 

This decision is also related to how well you train your staff and if they wash their hands properly. Your validation should be on finished product results as well as swabs.

 

Regards,

 

Tony

[Antores]

Dear Antores,

 

Dear Antores,

 

With all due respect i disagree.

 

IMEX, use of gloves, and particularly for RTE foods, is more often a legislation-driven issue assuming that Public Health Control systems exist at the specific location / process involved.

 

Unfortunately there is no relevant data provided on such aspects in the OP.

 

Rgds / Charles.C

Hello Charles.

 

I see your point.  I guess that is one consideration that I missed, and that Carine must take in to account when replacing gloves with sanitizers: Local legislation, 3rd party requirements and customer requirements, and many others such as local culture.

 

The fact is that, unless there is a local legislation mandating the use of glove for the specific product/operation, the decision of using sanitizers vs. gloves should be based on risk assessment of that operation, and for what Carine posted, we know nothing about it… we don’t even know where on “Earth” is that operation…   I guess I was a little bias on that, as there is no regulation where I live (USA) that mandates the use of gloves for food facilities, at least not that I know, but good point.

[Charles.C]

Dear Antores,

 

I guess I was a little bias on that, as there is no regulation where I live (USA) that mandates the use of gloves for food facilities, at least not that I know.

 

 

Regarding mandatory glove usage in USA, I (mostly) agree with you after just having tried to assess  this for another thread in respect to retail / non-retail food handling / processing establishments and RTE / non-RTE food products.

Based on experience, I am reasonably certain that other locations will differ.

Many USA State regulations for  retail / foodservice  establishments follow the "no bare hand contact" rule (w/wo exceptions) as suggested in the US Food Code for RTE/Retail items. The required method of achievement is similarly optional in various ways, including gloves. I suspect gloves are ultimately a common choice, or similar routes, eg plastic bags over the hand. However acceptance of the “no bare hand contact” rule  is by no means ubiquitous in USA (see link below).

 

Can see more detail for my yes/no attempts referred above here, especially the PPS -

http://www.ifsqn.com...ge-2#entry63305

(free BUMP )

 

Actually the use of hand sanitizers is also mentioned in some of the US regulations but, not surprisingly, involves various other "approvals",  particularly if RTE again + no gloves.

 

Rgds / Charles.C

[Antores]

Well Charles, All I have left to say is this... I'm wearing gloves in my profile picture!!.... that should make you happy...  :)

[carine]

hi all, our product already filled up by machines into plastic bag and  worker use hand  to tie  the product up by using raffia string. Is this not consider direct contact with the product rite, as worker only touched upper part of plastic bag.  

[CaliforniaFS]

hi all, our product already filled up by machines into plastic bag and  worker use hand  to tie  the product up by using raffia string. Is this not consider direct contact with the product rite, as worker only touched upper part of plastic bag.  

I don't know what commodity you are referring to, but I've worked with bagging machines and have seen in many occasions hand (with gloves on) contact with product. For example, count- Packed 3 count avocado in bags, if 4 ended up in a bag, we would have to remove a piece, Quality- Packed oranges, if a bad piece made it through it needs to be taken out, Weight- adding or removing product to make weight requirements. 

That's here in the USA. 

[carine]

Any idea how often shall worker re-apply hand sanitiser to ensure effectiveness?    

[Tony-C]

Any idea how often shall worker re-apply hand sanitiser to ensure effectiveness?    

 

Hi Carine,

 

After events in which are likely to contaminate their hands (they will need to wash hands first if visibly dirty) plus I would stipulate hourly and then monitor hand hygiene to assess this frequency is adequate or can be reduced.

 

Regards,

 

Tony

[Tony-C]

hi all, our product already filled up by machines into plastic bag and  worker use hand  to tie  the product up by using raffia string. Is this not consider direct contact with the product rite, as worker only touched upper part of plastic bag.  

 

Hi Carine,

 

True but in these situations I have seen operators touching the nozzle and/or poking fingers in the bag so it is good practice to implement good hand hygiene even if you believe they are not in contact with the product or product surfaces.

 

Regards,

 

Tony

[Mr. Incognito]

The bag is food contact packaging and as such contamination of the outside of the bag could lead to a contamination of the product especially if the bag isn't tied properly.

 

I am not a supporter of gloves however, after seeing how some people work with them on.  In my opinion they provide a false sense of food safety no matter how many times you tell people that gloves must be treated like hands.

 

A good GMP program with personnel washing their hands properly should be fine, depending on legislation of course.  Sanitizer is good too as it helps to kill bacteria that is left over on the washed hands.