I had an issue brought up to me about the use of hair ties, hairbands, and bobby pins by our HR person, who says an employee is arguing over being written up for using such an item while wearing a hairnet to cover it ("It can't fall into a bottle if it's under my hairnet" situation).
So I wanted to pick your brains...in item 126.96.36.199 of the SQF code (Module 13), it states "Jewelry and other loose objects shall not be worn or taken into a product handling area or any area where packaging is exposed."
I also checked regulation, and Title 21 (Chapter I,Subchapter B, Part 110,Subpart A, §110.10 (4)) states "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."
Would you classify hair accessories under "other loose objects" or "other objects that might fall into food?" Our HR person is looking for something exact that "wouldn't get us dinged" on the next audit if we were to allow people to use hairbands or bobby pins to hold their hair back. I think she's looking for a black-and-white answer from regulation requirements, instead of a "this is not allowed according to the company's cGMP" answer to give this employee. I already pointed out what SQF and the FDA say about it above, but it's "too open to interpretation" for her.
So I need some help.