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Jewelry in the Plant (Again)

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#1 qalearner

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Posted 02 June 2015 - 02:04 PM

Hi There, 

 

I know that this topic has been presented in these forums before but I need some help with clarification. We are following a provincial (Canadian) regulation when it comes to our further processing meat plant and the reg states: 

 

(5) No person who is engaged in the processing, packaging, labelling, handling or storing of a carcass, a part of a carcass or a meat product at a meat plant shall wear an object or use a substance that might fall into or otherwise contaminate the carcass, the part of the carcass or the meat product.  O. Reg. 31/05, s. 53 (5).

 

 Can we take this to let office workers and other management through the plant wearing their regular jewelry as they are not involved in the activities listed in the bullet? We have people who do not work on the floor coming inside to speak to the production workers, but they are never involved in anything to do with handling the meat products nor are they in the cooking room where raw product is exposed. 

 

 

Thoughts?



#2 gfdoucette07

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Posted 02 June 2015 - 02:16 PM

Are these "office people" coming into an area where any product or packaging is open to the enviroment or is it an area where all material is enclosed like a warehouse? For ease sake and uniformity in my personal opinion if anyone enters a non office or common area, all jewelry that is not allowed on the plant floor is not allowed.  Its easiest to enforce if there is a physical line they cannot pass with jewelry on or GMP precautions not enforced.  Help at all?

 

G



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#3 qalearner

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Posted 02 June 2015 - 02:23 PM

Yes that confirms my beliefs G. I want to make things easier for these "office people" but I think that a blanket ban is the best way and the way that I have always gone in the past. The difference here is that things have been this way for a long time and the plant floor is so small where we have non-production staff coming inside that I am looking for reasons why this practice can continue. In the area that we are having jewelry the product is rarely exposed, and only the open bags which are in line to be vacuum sealed. I think that I will discuss with our inspector when he comes around. 

 

I am just thinking that like so many other food safety issues if I can show that through a risk assessment that the occasional person coming in for a chat does not need to remove their jewelry. But that might be just a dream.



#4 MWidra

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Posted 02 June 2015 - 03:32 PM

Are these "office people" coming into an area where any product or packaging is open to the enviroment or is it an area where all material is enclosed like a warehouse? For ease sake and uniformity in my personal opinion if anyone enters a non office or common area, all jewelry that is not allowed on the plant floor is not allowed.  Its easiest to enforce if there is a physical line they cannot pass with jewelry on or GMP precautions not enforced.  Help at all?

 

G

I agree.  And these people should be washing their hands as well, because they are adding to the amount of possible pathogens in the area.  Do they have to put on hair nets?  If the plant is noisy, are they required to don hearing protection?  If they are submitting to these requirements, then what's one more?

 

They are entering a controlled area.  Do we think that the entire piece of jewelry will fall into the open bags without noticing?  Probably not.  But could something fall off the jewelry (like a small diamond chip or a clasp) which adds to the debris burden in the area and increases the chance of contamination?  Possibly.  And the chance of that happening is what a risk assessment has to determine.

 

What is the burden for having them take off jewelry before coming in?  What is the burden of searching through a production run to find the diamond that fell out?  Maybe presenting it that way will help.

 

Martha


"...everything can be taken from a man but one thing:  the last of the human freedoms--to choose one's attitude in any given set of circumstances, to choose one's own way."  Viktor E. Frankl

 

"Life's like a movie, write your own ending."  The Muppets


#5 Charles.C

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Posted 02 June 2015 - 05:36 PM

Yes that confirms my beliefs G. I want to make things easier for these "office people" but I think that a blanket ban is the best way and the way that I have always gone in the past. The difference here is that things have been this way for a long time and the plant floor is so small where we have non-production staff coming inside that I am looking for reasons why this practice can continue. In the area that we are having jewelry the product is rarely exposed, and only the open bags which are in line to be vacuum sealed. I think that I will discuss with our inspector when he comes around. 

 

I am just thinking that like so many other food safety issues if I can show that through a risk assessment that the occasional person coming in for a chat does not need to remove their jewelry. But that might be just a dream.

The textbook solution is that Top Management issues Policies.

 

You are not (supposed to be) the only man on the "Island".

 

This is where you find out if Top Management is really on board.

 

(I'm assuming that yr job is secure :smile: )


Kind Regards,

 

Charles.C


#6 qalearner

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Posted 02 June 2015 - 07:42 PM

I haven't taken top management to task yet for this one. I am figuring that I will get some push back, and wanted to know if there was any way around it. My gut tells me that no, there is not, and that this is going to be an issue for us. They have just started to worry about QA, hence the reason why I am here now.



#7 mgourley

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Posted 02 June 2015 - 10:17 PM

Thou shalt always follow all policies and procedures, regardless your position or status in the company.

 

Makes it easy to promulgate and easy to enforce.

 

Marshall



#8 MWidra

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Posted 03 June 2015 - 10:43 AM

Thou shalt always follow all policies and procedures, regardless your position or status in the company.

 

Makes it easy to promulgate and easy to enforce.

 

Marshall

A great policy.

 

*sigh* But easier said than done.  I've tried (and mostly failed) to get VPs to wear safety glasses and presidents to wear hearing protection.  And that's for something that the company can get fined thousands of dollars for.

 

Human nature is for people in power to resist following rules themselves, but imposing them on others.  Especially if they are used to being the rule-makers.

 

Human nature has not changed in thousands of years, and I see no great evolutionary trends on the horizon.

 

Just keep plugging away at it.  I always use the lever of setting a good example, and it helps for a time.

 

Martha


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"Life's like a movie, write your own ending."  The Muppets


#9 CarrieK

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Posted 09 June 2015 - 11:47 AM

I agree that anyone going through the plant (especially in areas of exposed product or where product is being packaged) should adhere to the policies and programs. Anything could contaminate your product and you never know when an 'accident' may happen. We make all visitors to the plant adhere to the rules of the plant, including office personnel (so because of that, office people stay in the office!!) :-)



#10 Ekivlen

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Posted 09 June 2015 - 12:49 PM

If you can't eliminate the act of rule-breaking while office staff enter the production area, eliminate the office staff entering the production area.

Invest in an intercom system that they can page the necessary staff, e-mail, put up a white board, take care of these things on breaks. Just a few ideas.



#11 Simon

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Posted 09 June 2015 - 02:09 PM

If you have rules for an area then in my opinion everyone who enters that area should follow the rules regardless of risk.

 

If you come at it form risk assessment POV you can easily make special dispensations for this and that to be relaxed for certain individuals.  However, I prefer a system that is easy to manage and supports a food safety and quality culture that we are all in in together!

 

How hard is it for an office dude or a senior manager to put on the gear once a week...five minutes every blue moon.

 

Regards,

Simon


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#12 MWidra

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Posted 09 June 2015 - 02:29 PM

If you have rules for an area then in my opinion everyone who enters that area should follow the rules regardless of risk.

 

If you come at it form risk assessment POV you can easily make special dispensations for this and that to be relaxed for certain individuals.  However, I prefer a system that is easy to manage and supports a food safety and quality culture that we are all in in together!

 

How hard is it for an office dude or a senior manager to put on the gear once a week...five minutes every blue moon.

 

Regards,

Simon

Agreed.  But you would think that asking them to put on gear for that short time is tantamount to asking them to fly to that blue moon, on gossamer wings!

 

Martha


"...everything can be taken from a man but one thing:  the last of the human freedoms--to choose one's attitude in any given set of circumstances, to choose one's own way."  Viktor E. Frankl

 

"Life's like a movie, write your own ending."  The Muppets


#13 Simon

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Posted 09 June 2015 - 03:25 PM

Agreed.  But you would think that asking them to put on gear for that short time is tantamount to asking them to fly to that blue moon, on gossamer wings!

 

Martha

 

:lol:  I know..easier said than done.

 

In reality probably easier to do a risk assessment or say "yes boss".


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#14 Ahmad.raza

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Posted 09 June 2015 - 03:29 PM

Hi qaleaner
Dont get urself worry, its just those worker or management personnel who is in direct contact with the processing activities, regular personnel and workers work in other areas does not come under this scope of statments,
So, easy way doing this to put pictorial presentations.



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#15 qalearner

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Posted 15 June 2015 - 02:29 PM

Thanks everyone, 

 

I have decided that a one size fits all in regards to the plant hygiene is where we need to go. I will be setting up training for everyone in the plant and the adjoining offices so that we can get everyone on the same page. I know that this will not solve the issue at hand, but at least if I can get people to sign off on training I can start enforcing a set of rules that applies to everyone.



#16 lkosler

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Posted 15 June 2015 - 02:48 PM

All valid points.

 

Remind them that a recall is an expensive endeavor.  Let them know how much it will cost them and they will all be taking off the jewelry.



#17 Charles.C

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Posted 15 June 2015 - 03:31 PM

Hi qalearner,

 

I deduce that Top Management is not yet on Board.

 

If not, that is likely to be yr biggest headache IMO.


Kind Regards,

 

Charles.C


#18 qalearner

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Posted 15 June 2015 - 05:56 PM

Hi qalearner,

 

I deduce that Top Management is not yet on Board.

 

If not, that is likely to be yr biggest headache IMO.

 

Yup! Thankfully I have some buy in, but as always things have to change from the top down. Also, our plant has windows where customers can see in, and the threat of a customer being turned off is sometimes bigger than food safety.



#19 Umeda

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Posted 15 June 2015 - 07:11 PM

Management support is hard to get, I agree, but a good risk assessment can make a big difference.  Put together a quick presentation on how exactly jewelry on the floor can be a big pain.  These are business people, and the last thing they want is to lose money because some random office person's jewelry piece fell in a package or on the equipment.  Where are the potential risks?  What are the negative results?  Get into details.  

 

I know for a lot of QA managers this is a big hassle and there is no time for that, but if you want it bad enough, any person can be persuaded.  

 

In all the plants I've been to, there is no question asked, beyond a certain point, I am asked to take off all jewelry, put on a hair net, wash my hands, etc.  Even the 'office people' who take me in, stop to perform all these safety tasks before stepping beyond this line.







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