13.3.4 Jewelry and Personal Effects
Hello!
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 13.3.4.1 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. :uhm:
So I need some help.
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. Ithink
Oooh. I would not! It would become an issue with me if the TM's are wearing scarves or bands that are exposed beneath the hairnet, especially with designs or accents that may become loose. Additionally, if boby pins are decorated with accents that create holes in the hairnets, thus yielding them ineffective, those would not be allowed. IMO, the hairnet does prevent hair, and hair accessories, from falling out and onto food or product contact surfaces.
I have long very thick hair. If I don't secure it with a hair tie/hair band, a single hairnet would not hold it, and I've even had my hair slip out of two hairnets (my hair is also very fine textured!) when not secured.There are poor individuals, like myself, who would not be allowed on the floor without 3+ hairnets.
Christina,
In the plants I have worked at the bobby pins were a no, but I believe they used the ties yet. Also a lot of head bands and bandannas under the hairnet. Not definitive but just what I have done.
G
This is what we do at my facility and we have never been "dinged" by an auditor for it:
- No curlers or bobby pins.
- Barrettes (at least 2 inches long with no beads) are allowed.
- Undecorated tiebacks/hair bands are allowed.
- Scarves/bandannas, so long as they are worn neatly beneath the hairnet, are allowed.
In my experience, the no bobby pin rule is fairly universal in the industry. Bobby pins create holes in hairnets and have the potential to fall out. Regardless of the myriad tricks that I know exist for keeping bobby pins in place, I would advise the ban, because you cannot guarantee that such precautions will be taken every time.
Thank you for your ideas, everyone! I've got a few notes down and I'll be talking to my boss about editing our GMP documents to reflect the changes in policy.
Then HR and I will have a discussion about what's allowed and what isn't. :spoton:
Here is what I have on mine:
No spangles, beaded or glass decorations on clothing is allowed. Furs/Pom poms are not allowed. Sleeveless tops without an outer garment is also not allowed.
Hair accessories (clips, pins, rubber bands and etc.) cannot be worn, except for plain cloth, elastic type scrunchie, to be covered by hairnet.
False eyelashes or eyelash extensions are not permitted.
The only jewelry allowed within the production and storage areas are plain (stone free) wedding bands or Medic-alert bracelets. Watches, any form of ear ring/stud, nose/lip or eyebrow studs, necklaces etc. are not allowed.
Supervisors/Managers are the only personnel that are allowed to wear a watch or use a cell phone, if it is required to perform a food safety related task
I added the false eyelashes and eyelash extensions recently because they have become very popular, I'm being pro-active. I've seen eyelash extensions come off as well as false eyelashes.