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#1 Pizza&Sandwich

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Posted 18 July 2013 - 05:38 PM

Does the code state that you cannot have bare hand contact with food? Where?

Does the code state that you must use gloves? Where?

 



#2 Setanta

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Posted 18 July 2013 - 06:39 PM

Which code are you looking under?

 

Setanta


-Setanta         

 

 

 


#3 Pizza&Sandwich

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Posted 18 July 2013 - 06:41 PM

Which code are you looking under?

 

 

Setanta

 

SQF 7.1, Modules 2 & 11



#4 esquef

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Posted 18 July 2013 - 07:54 PM

Gloved hands (one time use disposible gloves to be clear) for food contact is not a requirement of SQF (in Module 11) - or the FDA for that matter -with the exception of wounds that are suitably dressed. In this case glove wearing is a requirement. This is from 11.3.1 - Personnel Hygiene and Welfare.

 

The preferred way to prevent contamination of food is through proper hand washing policies, procedures, and adequate facilities. If gloves are worn be aware that any time the gloves are soiled or contaminated they must be properly disposed of and hands must be washed per standard hand washing policy/procedure before fresh gloves can be donned (this is in 11.3.2 - Hand Washing).

 

It's directly specified in 11.3.2 when hands must be washed:

 

- on entering food handling or processing area

- after each visit to a toilet

- after using a handkerchief

- after smoking, eating or drinking

- after handling wash down hoses, dropped product or contaminated material

 

 

Here's a good presentation on the subject (click on "Employee Health and Hygiene"):

 

http://www.cdph.ca.g...o Know Info.pdf


Edited by esquef, 18 July 2013 - 07:59 PM.


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#5 Pizza&Sandwich

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Posted 18 July 2013 - 07:58 PM

How can one justify that using bare hands is ok vs gloved hands?

 

Just had a consultant in and he is telling us that there's no way we can prove bare hands are not a risk.

 

 

Gloved hands (one tiome use disposible gloves to be clear) for food contact is not a requirement of SQF (in Module 11) -



#6 esquef

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Posted 18 July 2013 - 08:00 PM

What does your company make?



#7 Pizza&Sandwich

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Posted 18 July 2013 - 08:03 PM

What does your company make?

RTC pizzas, crusts, breadsticks & RTE sandwiches

 

Currently we have handwashing and hand sanitizer.



#8 esquef

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Posted 18 July 2013 - 08:27 PM

I don't know if your consultant was specifically for SQF implementation or not, but I can say with reasonable certainty that SQF doesn't require wearing of gloves for high risk processes. It does, however explicitely state in the Guidance Document and the actual code (11.3.2.3) that hands free operated taps as well as use of hand sanitizer is required. I work for a low risk processor; I'm assuming your proceesses (some of them anyway) are high risk, but my take on this from a SQF perspective is that so long as you have an adequate number of hand washing stations, and they meet the regulatory standards (warm water, liquid soap contained in a fixed container, clean paper towels for drying, a trash recepticle in which to place used paper towels, etc.), and have written policy and procedures for proper hand washing, and in addition have the same for your hand sanitizer, you should be SQF compliant IMO.

 

Now the FDA is a separate issue. I'm not up to speed on their policies on hand washing for RTE or other high risk activities, but I believe that glove use is a requirement in this case.  



#9 Charles.C

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Posted 18 July 2013 - 11:36 PM

Dear All,

 

I presume Lacey is based in the USA.

 

I didn’t check the standard but from content of above posts I assume that the scope of the 2 SQF modules referred excludes RTE products despite Lacey’s quoted items.

 

If otherwise ( and perhaps also depending on the unknown process / situation involved)  I suggest some urgent reading of the USA Food Code may be required.

 

It is surprising IMO that SQF would totally ignore such a document (if relevant) since legislatory requirements are usually  pre-eminent but  who knows ?

 

I also suggest Lacey consider acquiring a  consultant who is more probability-conscious. Or perhaps the comment followed an inspection ? :smile: .  

 

Just as an unrelated example, consider this one - 

 

http://www.fda.gov/F...e/ucm188201.htm

 

Rgds / Charles.C


Kind Regards,

 

Charles.C


#10 Pizza&Sandwich

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Posted 19 July 2013 - 02:32 PM

 

I also suggest Lacey consider acquiring a  consultant who is more probability-conscious. Or perhaps the comment followed an inspection ? :smile: .  

 

 

Perception. The consultant is stating that even if we do multiple swabs to validate that bare hand contact is acceptable due to our handwashing & sanitizing procedures, it would take only one person to mess up and we'd fail the audit.



#11 esquef

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Posted 22 July 2013 - 03:36 PM

Charles,

 

Here's part of an FDA document (FDA Food Code 2009: Chapter 3 - Food) that muddies the water even more with its contradictions. Maybe this is the reason SQF doesn't get into too much detail on glove usage with respect to RTE foods:

 

Preventing Contamination by Employees

3-301.11 Preventing Contamination from Hands.

  1. (A) Food employees shall wash their hands as specified under § 2-301.12.
  2. (B) Except when washing fruits and vegetables as specified under § 3-302.15 or as specified in ¶ (D) of this section, food employees may not contact exposed, ready-to-eat food with their bare hands and shall use suitable utensils such as deli tissue, spatulas, tongs, single-use gloves, or dispensing equipment. P
  3. © Food employees shall minimize bare hand and arm contact with exposed food that is not in a ready-to-eat form. Pf
  4. (D) Food employees not serving a highly susceptible population may contact exposed, ready-to-eat food with their bare hands if:
    1. (1) The permit holder obtains prior approval from the regulatory authority;
    2. (2) Written procedures are maintained in the food establishment and made available to the regulatory authority upon request that include:
      1. (a) For each bare hand contact procedure, a listing of the specific ready-to-eat foods that are touched by bare hands,
      2. (b) Diagrams and other information showing that handwashing facilities, installed, located, equipped, and maintained as specified under §§ 5-203.11, 5-204.11, 5-205.11, 6-301.11, 6-301.12, and 6-301.14, are in an easily accessible location and in close proximity to the work station where the bare hand contact procedure is conducted;
    3. (3) A written employee health policy that details how the food establishment complies with §§ 2-201.11, 2-201.12, and 2-201.13 including:
    4. (a) Documentation that food employees and conditional employees acknowledge that they are informed to report information about their health and activities as they relate to gastrointestinal symptoms and diseases that are transmittable through food as specified under ¶ 2-201.11(A),
    5. (b) Documentation that food employees and conditional employees acknowledge their responsibilities as specified under ¶ 2-201.11(E) and (F), and
    6. © Documentation that the person in charge acknowledges the responsibilities as specified under ¶¶ 2-201.11(B), © and (D), and §§ 2-201.12 and 2-201.13;
    7. (a) The risks of contacting the specific ready-to-eat foods with bare hands,
    8. (b) Proper handwashing as specified under § 2-301.12,
    9. © When to wash their hands as specified under § 2-301.14,
    10. (d) Where to wash their hands as specified under § 2-301.15,
    11. (e) Proper fingernail maintenance as specified under § 2-302.11,
    12. (f) Prohibition of jewelry as specified under § 2-303.11, and
    13. (g) Good hygienic practices as specified under §§2-401.11 and 2-401.12;
    14. (4) Documentation that food employees acknowledge that they have received training in:
    15. (a) Double handwashing,
    16. (b) Nail brushes,
    17. © A hand antiseptic after handwashing as specified under § 2-301.16,
    18. (d) Incentive programs such as paid sick leave that assist or encourage food employees not to work when they are ill, or
    19. (e) Other control measures approved by the regulatory authority; and
    20. (5) Documentation that hands are washed before food preparation and as necessary to prevent cross contamination by food employees as specified under §§ 2-301.11, 2-301.12, 2-301.14, and 2-301.15 during all hours of operation when the specific ready-to-eat foods are prepared;
    21. (6) Documentation that food employees contacting ready-to-eat food with bare hands use two or more of the following control measures to provide additional safeguards to hazards associated with bare hand contact:
    22. (7) Documentation that corrective action is taken when Subparagraphs (D)(1) - (6) of this section are not followed.


#12 George @ Safefood 360°

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Posted 22 July 2013 - 05:59 PM

From experience, a major UK retail will require gloves and forearm covers to be used when handling high risk RTE products in addition to proper hand washing and sanitising procedures. IMO if high risk RTE go with gloves and hand washing.

 

George



#13 Charles.C

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Posted 24 July 2013 - 06:45 AM

Dear Lacey,

 

Does the code state that you cannot have bare hand contact with food? Where?

 

 

As far as SQF is concerned, I suggest that that module 11, para 11.3.1 is the initial defining requirement –

 

In many jurisdictions, personnel requirements in food plants are covered by food safety legislation.  Where this applies, the legislative requirements must underpin the requirements of 11.3.1.  This element  covers the basic personal hygiene requirement for working in a food manufacturing facility.

 

 

The potential legislative involvements in USA are very murky indeed. It particularly involves (a) product type, ie FDA/FSIS, (b) State/Federal options, © Others (?).

 

From yr previous post, I deduce you refer to a “non-retail food processing establishment (NRFPE)”  in US parlance.

 

Strictly speaking, I think the “Food Code” I previously mentioned (perhaps wrongly on a scope rethink) is limited to Foodservice/Retail facilities as defined therein although it’s basic content seems to have been widely borrowed / modified / re-used in various places.

 

The RTE items will presumably be the most legally sensitive as far as “bare hand contact (bhc)” is involved.

 

I wouldn’t know yr specific Federal involvement if any due to unknown detail (a) above ?.Who has jurisdiction over breadsticks :smile: ? FDA?

If a Federal requirement exists, it presumably takes precedence (?).** (added later, see PPS at bottom)

I could not see any general bhc rule for FDA or FSIS, (as [FDA] suggested by esquef) but maybe does exist somewhere, or perhaps only for certain products, like the ROP previously linked.

 

Regarding State options, here are 2 (bhc prohibited) examples which appear to be scope relevant, New York , Idaho respectively -

 

(A)

Food shall be prepared and served without bare hand contact unless the food will be heated to at least the minimum temperature required under §81.09. Convenient and suitable utensils, sanitary gloves, waxed paper or an equivalent barrier shall be provided and used to prepare or serve food to eliminate bare hand contact and prevent contamination.

 

Attached File  bh1 - NY, rules food preparation,food establishments.pdf   164.47KB   31 downloads

(l) pg16

 

(B) FOOD EMPLOYEES may not contact exposed, READY-TO-EAT FOOD with their bare hands and shall use suitable UTENSILS such as deli tissue, spatulas, tongs, SINGLE-USE gloves, or dispensing EQUIPMENT.

Attached File  bh2 - Idaho, Food Code.pdf   767.38KB   23 downloads

3-301.11 (pg45)

(But note, pgs xii,xiii,  the scope-related exceptions  001.03.d, 001.04.e, particularly the first one)

 

Does the code state that you cannot have bare hand contact with food? Where?

 

 

So SQF answer is “No/(Maybe/Maybe Not)”. General Federal rule for NRFPE unknown as above comments. State rules – Yes, based on above 2 examples only.

 

(One current reason for banning BHC seems particularly targeted on preventing spread of noroviruses.)

 

Does the code state that you must use gloves? Where?

 

 

Answer is SQF- No/(Maybe/Maybe Not). General Federal rule unknown as above comments. State rules -  No, based on above examples only.

 

Note that if one only considered Foodservice/Retail establishments,  the "State" answers to first question would change to Yes/No. For examples of each, can try these links for some rules and (4th link) context –

 

http://www.health.ny...afety/hands.htm

http://www.city-data...-S-USA-LLC.html

http://www.myflorida...mation/aop.html

 

The requirement to ban BHC  has/is(?) encountered commercial resistance, eg –

 http://www.oregonliv..._fight_new.html

 

 

Rgds / Charles.C

 

PS - I'm not in USA so I may have misinterpreted the hierarchy*. Corrections welcome :smile: .

(* see PPS below)

 

PPS – Based on the attachment bh3 below, an idea of relative jurisdiction rights is –

 

(1) Overview of Federal Food Safety Laws

In general, federal regulations apply to all foods that are sold in interstate commerce (meaning across state borders) or foreign commerce, and states have the power to regulate most foods that are only sold intrastate (see Section I: General Legal Setting for more information  on  the  general  breakdown  in  authority  between  federal  and  state  governments).

 

Implementation-wise, with  a number of specific exceptions, the U.S. Food & Drug Administration (FDA) has jurisdiction over processed foods,  seafood,  and  food  additives,  while  the  U.S.  Department  of  Agriculture  (USDA)  regulates  fresh produce, livestock, poultry, and eggs.

 

(2) Overview  of  State  Food  Safety  Laws

States  share  regulatory  authority  with  the  federal government in many areas, but states enjoy complete jurisdiction over farmers markets and other types of direct  farm  sales,  retail  sales,  restaurants,  and  many  types  of  small-scale  agricultural  production  and processing entities. In any given state, a variety of government agencies may  have collective responsibility for the safety of the retail and restaurant food supply.

Attached File  bh3 - good laws, good food, 2012.pdf   3.28MB   14 downloads

(eg pgs 89-91)

 

Additionally –

 

The Food and Drug Administration (FDA) creates the FDA Food Code, which recommends (but does not

require) food safety provisions for retail stores and restaurants. It is not mandatory but has been adopted in some form by most states. The federal government oversees food safety for products moving in interstate

commerce, as well as regulating poultry and meat processing, monitoring general food safety, and exercising its food recall authority.

States can create their own meat and poultry processing inspection regime, but it must be at least as stringent as the federal regime.

 

As far as the “no bare hand contact” aspect is concerned,  I could not see any general legal requirements for this for “non-retail”, food processors within FDA / USDA published regulations for raw or RTE foods. The previously mentioned ROP link is one specific example / exception,  there are probably others.

It is however possible to find various recommendations for processors to implement  a  no bhc environment, eg –

 

(a)

We recommend that all persons who will enter an area where RF-RTE foods are processed or exposed thoroughly wash their hands before doing so. We also recommend that employees use suitable utensils (such as spatulas or tongs), or wear gloves, when touching exposed RF-RTE foods, food-contact surfaces, and packaging materials, and not touch exposed RF-RTE foods, food-contact surfaces, and packaging with bare hands.

 

(RF=raw frozen)

http://www.fda.gov/F...P/ucm073110.htm

 

(b)

Workers working with raw and cooked product wear clean gloves, clean outer garments, and waterproof aprons. Waterproof aprons are cleaned and sanitized twice each day, at the midday break and at the end of the shift.

 

Attached File  bh4 - seafood alliance haccp training manual,ed5,2011.pdf   2.17MB   19 downloads


Edited by Charles.C, 25 July 2013 - 06:08 PM.
added PPS

Kind Regards,

 

Charles.C


#14 imadoughguy

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Posted 26 July 2013 - 05:40 PM

Bakery operator here.  We make RTE Donuts, Cookies, Muffins etc... We require gloves for anyone that touches the product after Bake or Fry. AND we have a very aggressive hand washing program, policy, training etc...

 

Why wouldn't you require your employees to wear gloves when handling RTE food? Cost? Hassle?

Check out the FDA Recalls lately?

 

Where does Listeria, E.coli, Salmonella etc... on our food come from? I say peoples hands are a major contributor to these Food Safety issues. 

 

My 2 cents, like Nike says "Just Do It". :-)

 

Phil



#15 Charles.C

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Posted 27 July 2013 - 01:41 AM

Dear imadoughguy,

 

Yr decision is fine with me. But the interesting part is whether if you, for example, were convinced (and willing to validate) that yr employees had microbiologically pristine hands, would your not wearing gloves  worry anybody in officialdom, eg whomsoever licenses you to process (?)  Or yr customers ? or BRC / SQF ?. As far as I could see, for USA, you would legally be in the clear.

 

Rgds / Charles.C


Kind Regards,

 

Charles.C


#16 imadoughguy

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Posted 27 July 2013 - 03:08 AM

It probably depends on the state or even county ordinances. We are in FLorida and fall under Food Service statutes for RTE food.

From the Florida Department of Regulations

Are food service employees required to wear gloves all the time when handling food?

Gloves are not required when handling food, but the Food Code prohibits employees from contacting exposed, ready-to-eat food with their bare hands. Employees may use utensils such as deli tissue, spatulas, tongs, dispensing equipment, or single-use gloves to handle ready-to-eat food.

However, there is a provision in the Florida Administrative Code that allows an establishment to develop a written Alternative Operating Procedure (AOP) that describes the additional food safety and sanitation steps that will be used in order for employees to have direct bare hand contact with ready-to-eat food. For further information about AOP's, contact the Customer Contact Center at 850.487.1395.


References:
F.A.C., Rule 61C-1.001
Food Code, Section 3-301.11 (B)
Alternative Operating Procedure (AOP) forms
View Handwashing and Good Hygienic Practices

We would be cited by the state auditor if we were observed not wearing gloves (or other protective measure) while handling RTE food. Unless we had an approved AOP that is.

Phil



#17 Charles.C

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Posted 27 July 2013 - 06:34 AM

Dear imadoughguy,

 

Thks for the comments. Interesting system of classification. :smile:

 

Do all processors which ultimately produce a retail-ready product have the option to be "foodservice" category? Maybe depends on the business/location as you mention.

 

Actually, the Florida FoodService rules were (randomly) linked in my previous post and well match yr info.  I previously noticed the States have freedom of choice as to which version of Food Code they prefer (!?). Florida apparently 2001. Although not so different to the latest version (2009?) on a quick look.

 

As mentioned, the intriguing difference is between the above rules and those for other “pure” processors who are Federally controlled by FDA / USDA. Maybe for the second case, the large scope width / variable  product history(s) has prevented the imposition of general requirements for items like no bare hand contact / gloves. I suppose it might even be based on risk-assessment,  somewhere ? :smile:

 

One wonders as to the processor "category" of the OP ????

 

Rgds / Charles.C


Kind Regards,

 

Charles.C


#18 Pizza&Sandwich

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Posted 21 October 2013 - 07:02 PM

 

One wonders as to the processor "category" of the OP ????

 

Rgds / Charles.C

 

 

The RTE products are basically retail-ready products sold to food service. Other products are NRTE sold to food service for final preparation prior to retail sale.

 

Requiring everyone to wear gloves is costly in many ways: cost of gloves, cost in production (learning curve to doing everything with gloves), cost in training/retraining, etc. We are already struggling to meet production goals without throwing in a curveball with adding gloves to the mix.



#19 Hareesh

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Posted 24 October 2013 - 09:07 AM

Bare hands are always better if you can train the staff and ensure that they follow proper hand washing procedures. Wearing gloves gives a false sense of security. We are not using gloves in the sandwich section and till today all hand swabs have given negative results only.


With Best Regards

Harish


#20 Charles.C

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Posted 24 October 2013 - 10:14 AM

Bare hands are always better if you can train the staff and ensure that they follow proper hand washing procedures. Wearing gloves gives a false sense of security. We are not using gloves in the sandwich section and till today all hand swabs have given negative results only.

Dear Hari,

 

Interesting.

 

May I enquire as to the regulatory requirements in the Indian Food Code for handling  RTE products ?

 

Rgds / Charles.C


Kind Regards,

 

Charles.C


#21 cazyncymru

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Posted 24 October 2013 - 01:09 PM

Perception. The consultant is stating that even if we do multiple swabs to validate that bare hand contact is acceptable due to our handwashing & sanitizing procedures, it would take only one person to mess up and we'd fail the audit.

 

 

So , gloves don't get dirty?????????

 

And what about bits of blue gloves in food...they don't last forever!


Edited by cazyncymru, 24 October 2013 - 01:10 PM.


#22 Pizza&Sandwich

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Posted 24 October 2013 - 01:22 PM

So , gloves don't get dirty?????????

 

And what about bits of blue gloves in food...they don't last forever!

 

I do not deny any of the points: gloves get dirty, gloves deteriorate with use, gloves give a false sense of security...

It's all perception: Would you rather buy deli meat from a person using gloves, tongs, tissue, etc. OR from someone handling the deli meat with their hands.

 

Sad that SQF would rather us use dirty gloves to pass an audit...



#23 Setanta

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Posted 24 October 2013 - 01:45 PM

We change our gloves frequently; after each trip outside of our production room and whenever damaged. We also wash the gloves frequently and sanitize between washings. I don't get the impression that SQF prefers dirty gloves.

As to the question of how I'd rather buy deli meat? Like a lot of things, there is no one clear cut answer. It depends on the condition of the gloves, general cleanliness of the person in question and the cleanliness of the deli.


-Setanta         

 

 

 


#24 Pizza&Sandwich

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Posted 12 November 2013 - 03:39 PM

Bare hands are always better if you can train the staff and ensure that they follow proper hand washing procedures. Wearing gloves gives a false sense of security. We are not using gloves in the sandwich section and till today all hand swabs have given negative results only.

 

Hareesh~ are you SQF certified? How did you justify not wearing gloves? Hand swabs for pathogens or TPC/APC?



#25 Mr. Incognito

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Posted 12 November 2013 - 04:38 PM

I like to agree with the general statement that Hareesh has brought up.

 

One problem I have with gloves is the preception some operators have that if they are wearing gloves, no matter what they've done with them on, the product is safe because they aren't touching it with their hands.

 

I would like to think my examples are extreme but I saw these with my own eyes or heard of them from trusted sources:

 

Operator opening a drain during a floor flush then filling product contact packaging directly after it.

Operator in the bathroom taking care of "stand up" business with gloves on.

 

I'd go into more but the fact is some people seem to think that everything is better when they are wearing their gloves.  No matter how much training you give them they just don't get it.

 

That's why I typically advocate against gloves and for a strict hand washing regiment. Honestly I see gloves as just another thing to try to train and drill into people's heads.  There is no difference between dirty gloves and dirty hands.  I would rather have my operators wash their hands more often than to have to think about switching gloves.

 

But that's just me.


____________________________________________________________________________________________________

Mr. Incognito


:tardis:

Mr. Incognito is a cool frood who can travel the width and breadth of the galaxy and still know where his towel is.




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