BRC clause 7.4.2: Sewn-on buttons on pants?
We are having our first BRC audit next month. One topic that is up for debate internally is the interpretation of BRC clause 7.4.2 where it says "Protective clothing shall be available that is of suitable design to prevent contamination of the product (as a minimum containing no external pockets above the waist or sewn-on buttons)."
Is this saying that pants cannot have sewn-on buttons or is it just talking about buttons above the waist? We are a low risk facility and currently, everyone wears Kauki pants with one sewn-on button in the front. We have looked into finding pants with other forms of buttons or snaps/eye and hooks such as jeans but we cannot get them in everyone's size. It just doesn't seem to be a viable option. Do we have any reason to be concerned that this could be any issue? What do other food companies do?
The clause 7.4.2 where it says "Protective clothing shall be available that is of suitable design to prevent contamination of the product (as a minimum containing no external pockets above the waist or sewn-on buttons)." is looking at the risk of foreign material "button" falling into your product. Is it possible for a uniform pant button to fall into the product if it were to become dislodged? Are all work tables/conveyor belts above waist high level? You can do a simple risk assessment to negate anything an auditor may say about this clause as long as you do your due diligence.
The clause 7.4.2 where it says "Protective clothing shall be available that is of suitable design to prevent contamination of the product (as a minimum containing no external pockets above the waist or sewn-on buttons)." is looking at the risk of foreign material "button" falling into your product. Is it possible for a uniform pant button to fall into the product if it were to become dislodged? Are all work tables/conveyor belts above waist high level? You can do a simple risk assessment to negate anything an auditor may say about this clause as long as you do your due diligence.
This is one of those difficult issues. I get why we don't want buttons or snaps or clips or....well you get the idea. But we also don't want to see naked butts, or droopy drawers to be a safety hazard either.
I agree do your due diligence but this is one of those places where a modicum of common sense goes a long way and we need more auditors who have a bit of it.
We are BRC Certified and have sewn on pants buttons. Not that our auditor was going around lifting up the guys shirts to look at their waist lines.
Another way we remedy this is that operators in open-processing areas where there is a higher risk of "button" contamination where aprons. But I agree with the other folks on the thread - do your due diligence and an auditor typically won't pick at the subject.
Hi Mitch,
It is clearly a non-compliance with the requirements of the BRC Standard. Most of the protective clothing I see have press studs, though those can be a hazard themselves. The question of how much the auditor will make of it will be based on the risk of the button ending up in the product.
Questions that spring to mind:
Are employees handling open product?
How often are buttons lost?
Are they colored and distinguishable from the product?
Has a button every end up in the product?
Regards,
Tony
Use long coats that cover the tops of the trousers?
In the companies I work for they all use the long coats which cover external clothing from neck to knee and I have never been asked the question regarding the closure of their trousers.
this is a good question. Our plant does not allow buttons above the waist. However, any bling on pants is forbidden.
this is a good question. Our plant does not allow buttons above the waist. However, any bling on pants is forbidden.
The point is re-emphasized here:
BRC GLOBAL STANDARD FOOD SAFETY ISSUE 7 INTERPRETATION GUIDELINE
7.4.2 Interpretation Availability and design of protective clothing
The company needs to consider the design of protective clothing and ensure that it is suitable for the production processes. As a minimum:
• The clothing must not include external pockets above the waist (e.g. no pockets in coats) and must not have sewn-on buttons.
Regards,
Tony