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Fit Bit - GMP Violation?


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#1 KrissyFSCM

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Posted 09 February 2016 - 02:23 PM

Hi all,

I am the Food Safety Manager for a Produce Wholesaler and Distributor.  Our current GMP policy says that we do not allow jewelry except for a plain wedding band or medical alert bracelet.  With the popularity of the "Fit Bit" would anyone consider allowing those?  The risk to our product from a fit bit is practically non-existent so I'm struggling to come up with a good reason why we shouldn't allow it - other than simply saying, "It's our policy."   My fear is that it will open the door to questions regarding other types of bracelets, watches or jewelry.  We are SQF Level 2 certified and the code only dictates requirements for areas of the facility where product is exposed or repacked so we have wiggle room in that area.  Again, my concern is that it will spark conversation about some of other jewelry requirements.  What do you guys think?  Do any of your companies allow fit bits or other jewelry? Insight is much appreciated!

 

Thank you,

 

 



#2 JPO

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Posted 09 February 2016 - 02:42 PM

"It's Our Policy" really should be good enough.

 

Also, I would caution against the plain wedding ring exception for safety reasons.

 

At my last place, we nearly had a ring avulsion injury due to a wedding band when a piece of equipment that was being lifted slipped.

 

Fortunately, the person still has his finger. 

 

It caused a near immediate change in policy.



#3 D.Fischer

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Posted 09 February 2016 - 02:46 PM

I believe when you make to exceptions, it opens the door for more controversy.  One policy across the board is easiest.   Additionally, you need to assess food safety risks of that item and monitoring compliance of employees moving through the areas where it would not be allowed (if applicable). I have actually worked with manufacturers that would not even allow wedding bands, based on risk and process.



#4 QAGB

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Posted 09 February 2016 - 02:54 PM

Hi all,

I am the Food Safety Manager for a Produce Wholesaler and Distributor.  Our current GMP policy says that we do not allow jewelry except for a plain wedding band or medical alert bracelet.  With the popularity of the "Fit Bit" would anyone consider allowing those?  The risk to our product from a fit bit is practically non-existent so I'm struggling to come up with a good reason why we shouldn't allow it - other than simply saying, "It's our policy."   My fear is that it will open the door to questions regarding other types of bracelets, watches or jewelry.  We are SQF Level 2 certified and the code only dictates requirements for areas of the facility where product is exposed or repacked so we have wiggle room in that area.  Again, my concern is that it will spark conversation about some of other jewelry requirements.  What do you guys think?  Do any of your companies allow fit bits or other jewelry? Insight is much appreciated!

 

Thank you,

 

 

Hi KrissyFSCM,

 

I agree with the people above. I understand the plain wedding band and medical alert exceptions. Outside of those, there shouldn't really be any exceptions to the rule. The Fit Bit looks a lot like a watch (from what I have seen), and I make sure that anyone on-site removes watches; so the Fit Bit would definitely be an item to be removed before entering the production area.

 

QAGB



#5 Chris @ Safefood 360°

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Posted 09 February 2016 - 06:00 PM

Hi KrissyFSCM, 

 

I wholeheartedly agree with JPO's comment above "'it is our policy' really should be good enough". 

 

You might want to cite the FDA's regulation for cGMP's (21CFR110). I recall a number of years ago making an exception for external body piercings within the production area. The piercings had to be covered by a band-aid (or other such covering) so that the object didn't become a foreign material concern. Then we had to track the issuance of the band-aid and of course this also led to questions from other employees "well if so-and-so is allowed to have their nose pierced and cover it with a band-aid, why can't I (fill in the blank)". 

 

With that in mind "wearable technology" is the new thing these days, and undoubtedly if an exception is made for a FitBit it won't be long until someone is walking around your production area wearing Google glasses. Do yourself a big favor and stick to your guns on this one. 

 

-Chris 



#6 Charles.C

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Posted 09 February 2016 - 08:37 PM

Hi All,

 

One caveat - nobody has mentioned the risk of legal actions, eg on religious grounds -

 

http://www.natlawrev...discrimination-

 

As far as general  "hand jewelry" is concerned, I noted one other potential barrier ( 21cfr 110 ) -

 

Removing all unsecured jewelry and other objects that might fall into food, equipment, or containers, and removing hand jewelry that cannot be adequately sanitized during periods in which food is manipulated by hand. If such hand jewelry cannot be removed, it may be covered by material which can be maintained in an intact, clean, and sanitary condition and which effectively protects against the contamination by these objects of the food, food-contact surfaces, or food-packaging materials.

 

As far as fit-bit (a watch ?) is specifically concerned, there is possibly an occupational  safety risk, eg distraction while handling equipment >> Policy ?


Kind Regards,

 

Charles.C


#7 QAGB

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Posted 09 February 2016 - 08:39 PM

Hi All,

 

One caveat - nobody has mentioned lthe risk of legal actions, eg on religious grounds -

 

http://www.natlawrev...discrimination-

 

As far as general  "hand jewelry" is concerned, I noted one other potential barrier ( 21cfr 110 ) -

 

 

As far as fit-bit (a watch ?) is specifically concerned, there is possibly an occupational  safety risk, eg distraction while handling equipment >> Policy ?

 

Hi Charles,

 

I've heard that there are companies that won't allow religious jewelry to be worn. We do allow that here, and if we noted a hazard, we would have to make sure that PPE could properly cover the hazard.

 

QAGB



#8 Chris @ Safefood 360°

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Posted 09 February 2016 - 09:05 PM

Hi Charles, 

 

Thank you for bringing that up. For those who religiously exercise and are devoted to a life of dieting, I suppose it could be argued that a "FitBit" is actually a religious article!  :sleazy:

 

Hi All,

 

One caveat - nobody has mentioned the risk of legal actions, eg on religious grounds -

 

http://www.natlawrev...discrimination-

 

As far as general  "hand jewelry" is concerned, I noted one other potential barrier ( 21cfr 110 ) -

 

 

As far as fit-bit (a watch ?) is specifically concerned, there is possibly an occupational  safety risk, eg distraction while handling equipment >> Policy ?

 

Not to take this off the topic of the OP's intent, but there was a great conversation on this subject in this thread: http://www.ifsqn.com...y-and-clothing/

 

-Chris 



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#9 tsmith7858

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Posted 09 February 2016 - 09:11 PM

Agree with the "its our policy" should be enough but people want an explanation for why a policy is in place.  So why do we tell people they can't wear jewelry, watches, etc.

  1. Lack of control for sanitation of the watch, jewelry, FITBIT could be a reason
  2. Safety risks/injury
  3. Damage to piece could cause foreign material to end up in product

I am sure there are others.  Most policies are not in place "just because" and there is always a reason behind it.



#10 Charles.C

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Posted 09 February 2016 - 10:09 PM

Agree with the "its our policy" should be enough but people want an explanation for why a policy is in place.  So why do we tell people they can't wear jewelry, watches, etc.

  1. Lack of control for sanitation of the watch, jewelry, FITBIT could be a reason
  2. Safety risks/injury
  3. Damage to piece could cause foreign material to end up in product

I am sure there are others.  Most policies are not in place "just because" and there is always a reason behind it.

 

I agree but it's not too difficult to find Policy inconsistencies (pragmatisms?), eg -

BRC Food - jewellery shall not be worn, with the exception of a plain wedding ring or wedding wristband
BRC Packaging - jewellery shall not be worn on exposed parts of the body, with the exception of a plain wedding ring or wedding wristband and sleeper earrings (continuous loop).

 

UK Buyer -

10.12
Jewellery must not be worn, with the exception of a single plain band ring (i.e. one piece with no stone settings or intricate design). Cufflinks and tie pins must be considered as jewellery.
10.13
Additional jewellery may be permitted if it is worn for medical or religious reasons.
In these circumstances a risk assessment must be completed and the permitted jewellery must be strictly controlled.

10.13.1

Permitted medical or religious jewellery is not exposed or pose any food safety risk.


Kind Regards,

 

Charles.C


#11 dsafforld

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Posted 10 February 2016 - 01:27 PM

I have the same policy at our facility. My suggestion is that you stick to your policy and not allow the fit bit. Allowing the fit bit to be worn would only open a can of worms and subject your policy to be challenged going forward. In the past I had an employee ask if electronic cigarettes could be smoked inside of facility (food manufacturing facility). Although we had a no-tobacco/ no cigarette  policy, he maintained the E-cigarettes were not real. We stuck to our policy and did not allow the E-cigarette.

 

 

Regards

 

 

Donnell 



#12 Jus'me

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Posted 10 February 2016 - 03:12 PM

I agree w/ the majority here.  It would fall under the jewelry policy and shouldn't be an exception.  At our facility bracelets, (excluding emergency alert) and watches have to be removed prior to entering our Production area.  A fit bit woudl fall under this same category and would have to be removed. 



#13 Anika

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Posted 10 February 2016 - 03:20 PM

wow. Fitbit a jewelry?

 

Never thought about it that way and we have a in office competition going on every week :oops2:



#14 AB Perkin

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Posted 11 February 2016 - 02:14 AM

Take a good look at the Fitbit. You will find that it has numerous crevices that can harbor bacteria. Anything that can harbor bacteria and cannot be cleaned effectively should not be permitted in the production area.
Keep in mind that the purpose of wearing this is to record your excersize. Exercise generally results in sweat, and sweat harbors and nurtures bacteria.
The answer has to be no.



#15 Simon

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Posted 11 February 2016 - 07:08 AM

No, no, no. Fit Bit = :banned:


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#16 Christine Poirier

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Posted 11 February 2016 - 01:32 PM

Hi,

Fitbit is part our our wellness business program.

Employees need to keep their device below their hips so you make sure to not integrate food safety risk.



#17 KrissyFSCM

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Posted 22 February 2016 - 05:22 PM

Thank you all for the great feedback!



#18 djammur

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Posted 22 February 2016 - 08:53 PM

We said NO to fit bit bracelets.  The popular band is notorius for falling off.  The potential for falling off into the product is pretty high. Have them keep it in their pockets






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