Need Guidance on New Uniform Policy

We are a fairly small operation, about 120 employees working 3 shifts.  We recently lost about 30% of our business, which led to a reduction of staff and a review of all expenses to cut anything possible.  We were paying around $6000.00 per month for uniforms that were laundered and delivered by an outside vendor which was a huge expense.  Cleaning towels, wet and dry mop heads, first-aide and paper supplies were also included in this amount, but the uniforms were the bulk of it.   We conducted a risk assessment and made the decision to discontinue providing the uniforms.  I have attached our new policy.  We are BRC certified so I tried to include all of the items from the standard.  Advice, guidance and opinions needed as to whether we can get away with this! 

In the standard it is stated that you can do internal washing of uniform as long as you can validate the process and demonstrate that your process of washing is effective in removing the soil from garments.  

Practically though it is almost impossible to implement.

Kind regards

Humaid Khan

MD Halal International Services

Sorry, forgot attachment!

In the standard it is stated that you can do internal washing of uniform as long as you can validate the process and demonstrate that your process of washing is effective in removing the soil from garments.  

 

Practically though it is almost impossible to implement.

 

Kind regards

Humaid Khan

MD Halal International Services

I was also under the impression that as long as you can risk assess uniforms vs. not wearing uniforms, that this could be justified under GFSI. If the company is low-risk, and has enclosed (or mostly-enclosed) processes, the employees may not need to wear uniforms. They could also think about having employees wear disposable smocks in the more critical locations.

Hi Miss Tammy,

Thks for attachment.

I ony studied the "laundering"/ clause 7.4.3 aspects.

A few comments - 

I cannot recall the product/process, ie as to why it’s low risk ? – sorry.

It was unclear to me as to the proposed location of washing/cleaning etc – I guess at home ?  If so, line 10 comment below wud appear somewhat critical.

IMO the following items (lines) in para 7.4.3 are not yet fully responded to within yr document -

Line 2 - defined criteria / validated

Line 4 – adequate segregation

Line 5 – effective cleaning

Line 8 – cleaned ….bags

*** Line 10 - Washing ….. shall  (ONLY?) be acceptable where the protective clothing is to protect the employee from the products handled

I think you may need >= 1  “Procedure / SOP” 

PS - i moved topic to BRC Food, hopefully it is Food

Where I was working until very recently, we all washed our own PPE overalls.  the BRC auditor really didnt like this and Iwas only just able to argue us out of a non conformance for this, based on us being such a low risk product.  The rules have tightened up though in BRC 7 and its very clear that if the PPE is to protect the PRODUCT, then you can't clean your own.  If its only to protect the worker, then you can clean it yourself.

However, one thing concerns me, you say you are not going to provide uniforms. Is this because you dont feel they are needed?  which would be fine from a BRC point of view if its not to protect the product... or are you expecting your workers to buy their own.  We've been doing a lot of ethical work at the moment and it could be considered worker exploitation to make them pay for items they need for work (it specifically mentioned PPE)

Where I was working until very recently, we all washed our own PPE overalls.  the BRC auditor really didnt like this and Iwas only just able to argue us out of a non conformance for this, based on us being such a low risk product.  The rules have tightened up though in BRC 7 and its very clear that if the PPE is to protect the PRODUCT, then you can't clean your own.  If its only to protect the worker, then you can clean it yourself.

 

However, one thing concerns me, you say you are not going to provide uniforms. Is this because you dont feel they are needed?  which would be fine from a BRC point of view if its not to protect the product... or are you expecting your workers to buy their own.  We've been doing a lot of ethical work at the moment and it could be considered worker exploitation to make them pay for items they need for work (it specifically mentioned PPE)

We're BRC Certified Issue 7, and we wear uniforms (and we plan to continue doing so).

However in response to the questions and comments, yes I do see in the manual where it is frowned upon to wash your own uniforms or PPE (I personally wouldn't consider doing that at all). On the other hand, I do not see where it says in the manual that you can't buy disposable PPE (like Tyvek overalls or smocks), and risk assess frequencies of changing them.

According to the manual, "the company is required to determine the procedures for application and use of protective clothing, based on risk assessment. The risk assessment must consider foreign-body, microbiological and allergen risks as appropriate."

Also according to the manual, "the requirement to wear full company-issued protective clothing would not be an absolute requirement where all of the following criteria apply:

1. All products are fully enclosed.

2. The product would, if it were not fully enclosed, be classed as a low-risk product.

3. The area is separate from areas containing open product.

4. Staff do not need to pass through open product areas to access the area."

As a result, wouldn't it be acceptable to have disposable overalls or smocks (considering these company-issued protective clothing), hairnets, beard nets, and the typical GMP policies including no shorts, clothing with buttons or frays (or other types of material that can easily fall into product), and then risk assess the frequency of changing the PPE?

QAGB

Hi Miss Tammy,

Any Comments from S.Carolina ?? :smile:

We're BRC Certified Issue 7, and we wear uniforms (and we plan to continue doing so).

 

However in response to the questions and comments, yes I do see in the manual where it is frowned upon to wash your own uniforms or PPE (I personally wouldn't consider doing that at all). On the other hand, I do not see where it says in the manual that you can't buy disposable PPE (like Tyvek overalls or smocks), and risk assess frequencies of changing them.

 

According to the manual, "the company is required to determine the procedures for application and use of protective clothing, based on risk assessment. The risk assessment must consider foreign-body, microbiological and allergen risks as appropriate."

 

Also according to the manual, "the requirement to wear full company-issued protective clothing would not be an absolute requirement where all of the following criteria apply:

 

1. All products are fully enclosed.

2. The product would, if it were not fully enclosed, be classed as a low-risk product.

3. The area is separate from areas containing open product.

4. Staff do not need to pass through open product areas to access the area."

 

As a result, wouldn't it be acceptable to have disposable overalls or smocks (considering these company-issued protective clothing), hairnets, beard nets, and the typical GMP policies including no shorts, clothing with buttons or frays (or other types of material that can easily fall into product), and then risk assess the frequency of changing the PPE?

 

QAGB

Yes, your points 1-4 can be summed up as the PPE is not used to protect the product.. because it doesnt need protecting under these circumstances.  Therefore there is no reason why you couldn't wear disposable PPE. I'd guess you already use disposable gloves and hairnets anyway.  So as long as your risk assessment says its ok then I can't seen an issue there. However... if youre going to use disposable overalls, is there not a danger that it could end up being as expensive as having more permanent overalls and washing them?

Yes, your points 1-4 can be summed up as the PPE is not used to protect the product.. because it doesnt need protecting under these circumstances.  Therefore there is no reason why you couldn't wear disposable PPE. I'd guess you already use disposable gloves and hairnets anyway.  So as long as your risk assessment says its ok then I can't seen an issue there. However... if youre going to use disposable overalls, is there not a danger that it could end up being as expensive as having more permanent overalls and washing them?

Hi Kehlan,

Yes, disposable overalls could get very expensive. It really just depends on the process. If it's a mostly enclosed or totally enclosed process where people aren't handling the product much, frequency of PPE changes would be less (and not as costly). It would also depend on the size of the company too. There could also be something in place where the level of PPE worn depends on where the person is in the process. For example, anyone working directly with open product must wear overalls, downstream of that where a person comes in contact with the product at times, they would wear smocks. Downstream of that, a person that very seldom comes in contact with product or not at all could wear aprons. Yes, we already use the hair protection, I was just trying to make sure all of the typical PPE items were addressed.

I would still suggest to anyone (enclosed or not) that uniforms/PPE provided and washed by laundering services are the best option. There is no gray area when the uniform company provides and washes the clothes. There is a lot of gray area when companies try to wash the PPE themselves, or choose not to  use uniforms at all. That's one less non-conformance to worry about, in my opinion.

QAGB

Why not buy a washing machine, should be enough to wash the cloths once or twice a week considering the low risk.

I would still suggest to anyone (enclosed or not) that uniforms/PPE provided and washed by laundering services are the best option. There is no gray area when the uniform company provides and washes the clothes. There is a lot of gray area when companies try to wash the PPE themselves, or choose not to  use uniforms at all. That's one less non-conformance to worry about, in my opinion.

 

Agreed.  As I said, we got away with it last year (BRC 6) but ONLY after an argument with the auditor.  The wording in 7 is much less ambiguous and harder to argue.

Why not buy a washing machine, should be enough to wash the cloths once or twice a week considering the low risk.

Hi Tuuttu,

Buying the washing machine and doing the cleaning onsite means the process has to be validated and verified. So I would assume there would be some sort of process of sending clothes to a lab for micro testing or performing micro testing in house for washed items. Then there would need to be ATP swabbing done or some other verification on a set frequency to ensure that the washing is continuously effective.

QAGB

Hi Tuuttu,

 

Buying the washing machine and doing the cleaning onsite means the process has to be validated and verified. So I would assume there would be some sort of process of sending clothes to a lab for micro testing or performing micro testing in house for washed items. Then there would need to be ATP swabbing done or some other verification on a set frequency to ensure that the washing is continuously effective.

 

QAGB

Well we are talking about a low risk process any kind on washing on site should be better then having people wash their uniforms at home.

Put a sticker on the uniforms once a month to register the temperature. If your uniforms can handle it, then go for +80C and you should be fine. If thats not the case then use whatever temperature the uniforms can handle, use whatever information you can get hold off to prove that this is enough, perhaps contact an offsite service and ask what they do or whoever is selling the machines, uniforms etc.

Keep things inhouse.

A heartfelt "thanks" for all of your guidance, advice, opinions, etc.  Unfortunately, the issue has been decided by the people that pay the bills, so no uniforms.  I fully expect a non-conformity, and when it happens we will have to reinstate the smocks as a corrective action.  Hopefully business will be better by then :)  We have done very well on all of our prior audits, so this shouldn't cause us to completely fail.  Our audit is not until May, and a lot can change in that time so we shall see!  I will keep you posted on our results.  Thanks again to all!

A heartfelt "thanks" for all of your guidance, advice, opinions, etc.  Unfortunately, the issue has been decided by the people that pay the bills, so no uniforms.  I fully expect a non-conformity, and when it happens we will have to reinstate the smocks as a corrective action.  Hopefully business will be better by then :)  We have done very well on all of our prior audits, so this shouldn't cause us to completely fail.  Our audit is not until May, and a lot can change in that time so we shall see!  I will keep you posted on our results.  Thanks again to all!

Hi Miss tammy,

You might consider responding to Post 5 as per the original OP which, from memory(?), was the attempted "validation" of yr now confirmed procedure ?