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SQF Audit GMP Question


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#1 staci mccarvey

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Posted 21 September 2017 - 06:31 PM

I have moved from a background of all very large food manufacturer's to a very small company with only 15 employees + temps when needed. I was brought in to help get the facility ready for SQF audit. I am running into having to justify the reasons for various policies, one of which is hair nets. It has always been required everywhere i have ever worked and I am being asked where the rules come from. Currently, employees are being allowed to use the SAME hairnet throughout the day, whether they are in production or not. I am very aware of the reasons why we have to wear hairnets but finding proof and reasons why they are required is more difficult. I am telling them that hairnets must be changed each time you leave the processing area, use the restroom or go to breaks. My boss is wanting to know where this comes from. being that I have always been a part of a larger picture, I am unsure where the justification came from. I am having the same issue with ball caps. Does anyone have any references, FDA, HACCP or other that refer to these as being justified rules?

 

Thanks,

 

Staci



#2 flori

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Posted 21 September 2017 - 07:06 PM



I have moved from a background of all very large food manufacturer's to a very small company with only 15 employees + temps when needed. I was brought in to help get the facility ready for SQF audit. I am running into having to justify the reasons for various policies, one of which is hair nets. It has always been required everywhere i have ever worked and I am being asked where the rules come from. Currently, employees are being allowed to use the SAME hairnet throughout the day, whether they are in production or not. I am very aware of the reasons why we have to wear hairnets but finding proof and reasons why they are required is more difficult. I am telling them that hairnets must be changed each time you leave the processing area, use the restroom or go to breaks. My boss is wanting to know where this comes from. being that I have always been a part of a larger picture, I am unsure where the justification came from. I am having the same issue with ball caps. Does anyone have any references, FDA, HACCP or other that refer to these as being justified rules?

Thanks,

Staci


Hi DlStacey,
Easy answer is: to avoid the transfer of infection, bacteria or germs to another person/object.
Hope it helps

Regards,
Florina




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#3 kgonzalez

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Posted 22 September 2017 - 02:06 AM

"The site shall undertake a risk analysis to ensure that the clothing and hair policy protects materials, food and food contact surfaces from unintentional microbiological or physical contamination" - 11.3.3.1 in SQF edition 8. Your risk analysis deems it necessary to change hairnets to protect from unintentional contamination.



#4 mruth84

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Posted 22 September 2017 - 01:34 PM

21 CFR 117 is another good reason



#5 John Moreton

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Posted 22 September 2017 - 01:49 PM

BRC Packaging

 

Its mostly on your own risk assessment.

 

6.5.6 In production and packing areas, hazard and risk analysis shall be used to determine the need for:
   • snoods for beards and moustaches
   • scalp hair coverings.

 

If you want to drown hi in data then have him read 

 

FDA 

 

https://www.accessda...h.cfm?fr=110.10    ( Section 6 )



#6 ntheobold84

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Posted 22 September 2017 - 02:32 PM

It is based on your own risk assessment.  My opinion about hair nets in food plants is that it's best to keep them on even outside of production because it keeps the hair up and limits the risk of hair falling onto clothes when going back into production.  This is in our GMP program, but again its based on your risk assessment.  



#7 Peaches

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Posted 22 September 2017 - 02:34 PM

With smaller companies, the bottom line is usually cost, meaning the more times you change the hairnets, the more you'll use, the more that will cost, and where is the benefit?(devils advocate with that question) I would go over the requirement for SQF and then complete the risk assessment.  Do you have a lot of allergens in your plant or are a RTE facility?  That could be a big red flag and help your case as far as changing hair nets more frequently.  Or if you have lower risk products, you might find you don't need to change as often as the big companies.

Ball caps can sometimes be more of a 'culture' thing and harder to get rid of.  I ran into this at one of the smaller companies I worked for - the employees (and owner) were ok with the hairnet as long as they could wear their baseball cap over it.  Once I tried to take away the baseball caps, it was like I asked them to cut off their left hands!  It all depends on what you're making and how your risk assessment looks.  If you're in a dusty environment (i.e. flour) then a baseball cap is a bad idea because of the possible transfer of particles and it's going to get dirty.  If you're in a cold, raw environment, they might be ok if they are company issued, replaced at a certain frequency, and included in the GMP inspections. 

Good luck!



#8 FurFarmandFork

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Posted 22 September 2017 - 03:42 PM

I would challenge you as well..like everyone else said its based on the risk you want to assume. But I would say that if you don't require employees to wash their face or shoes after entering/leaving the facility, how does a hairnet contribute to contamination?

 

Seems like overkill.


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#9 John Moreton

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Posted 22 September 2017 - 03:48 PM

I would challenge you as well..like everyone else said its based on the risk you want to assume. But I would say that if you don't require employees to wash their face or shoes after entering/leaving the facility, how does a hairnet contribute to contamination?

 

Seems like overkill.

 

Really ?. The risk would identify how to limit exposure and help mitigate contaminants. if your outside with your hair net on, in to an area with dust dirt insects blowing in the wind then to come back in to a food environment, it would seem you just increased exposure rather than limit.

 

A change of shoes to go out side is all so a must in our factory and a decontamination/tacky mat at the entrance of manufacturing. 

You cant allways eliminate the risk but you can take appropriate steps to reduce.






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