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#1 charbear

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Posted 29 November 2017 - 04:05 PM

Hi we are currently seeking SQF level 2 certification as a food contact packaging company. Our consulting firm is pushing us to enforce uniforms or lab coats at the least. They are saying that street clothes are a cross contamination issue and we won't be certified unless that changes. Any thoughts? Opinions? Proof to the contrary? Any info would be appreciated. It gets very hot in here during the summer.



#2 ctzinck

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Posted 29 November 2017 - 05:16 PM

we are also a food contact packaging company, we do not wear uniforms or smocks, we wear street clothes, however we do keep some shirts and pants in various sizes on hand in case someones clothes become contaminated or in some way pose a risk to product.



#3 ctzinck

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Posted 29 November 2017 - 06:08 PM

we are also a food contact packaging company, we do not wear uniforms or smocks, we wear street clothes, however we do keep some shirts and pants in various sizes on hand in case someones clothes become contaminated or in some way pose a risk to product.

and we are SQF lvl 2



#4 charbear

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Posted 29 November 2017 - 06:33 PM

And the auditor didn't have an issue with it? Do you have a risk analysis that enables the employees to wear street clothes?



#5 ctzinck

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Posted 29 November 2017 - 06:37 PM

we have been sqf certified for 4 years and it has never come up, not by consultants or auditors

 

we recently had consultant in to upgrade our system to version 8 and he did include a risk assessment for clothing. but i have no idea how to attach it here.



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#6 FurFarmandFork

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Posted 29 November 2017 - 07:21 PM

SQF 3 bottled water producer here with no uniforms. You consulting company is going a little crazy unless it is reasonably expected that your employees will be contacting food contact materials with their clothing in the course of their work (e.g. if they have to hug rolls of film to move it or something).

 

Relevant code:

13.3.3 Clothing

13.3.3.1 The site shall undertake a risk analysis to ensure that the clothing and hair policy protects food contact packaging from unintentional contamination.

13.3.3.2 Clothing worn by staff engaged in handling food contact packaging shall be maintained, stored, laundered and worn so as not to present a contamination risk to products.

 13.3.3.3 Clothing and shoes shall be clean at the commencement of each shift and maintained in a serviceable condition, and changed where they present a product contamination risk.

13.3.3.4 Gloves used when contacting finished packaging material shall be clean and maintained and replaced when needed

 

 

 

The current guidance for the food module (module 11) gives additional insight into what the expectations are for your risk analysis.

 

What does it mean? Uniforms, including footwear, and hair coverings that are provided to employees in food manufacturing sites are primarily for the protection of materials, work-in-progress (WIP), finished product and foodcontact surfaces; however, buttons, snaps, pockets and the like can pose risk if the clothing item is not properly vetted, and head, face and body hair pose both potential biological and physical hazards that must be analyzed. Clothing must therefore be designed to prevent contamination and maintained in a clean and serviceable condition. A risk analysis will identify which items are appropriate for the personnel, product and process. What do I have to do? Employees and visitors must wear clean clothing, footwear, and hair covering, if identified as a risk, while in the processing area. The site must conduct a risk analysis to identify clothing needs and the risk posed by the clothing choices. Employees and visitors with excessively soiled clothing are not to handle products or packaging materials. Employees working in high risk areas must not wear processing uniforms off site. Employees engaged in low risk processes can wear uniforms off site provided they are properly cleaned at the beginning of their work operation. Clothing includes outer garments such as work clothes, overalls, boots, shoe coverings, head coverings, hair nets, smocks, frocks, beard snoods and coats. When required, gloves and aprons shall be kept in an intact and sanitary condition when used. When not in use, gloves and aprons shall be stored in a designated area (e.g., such as a rack or in sealed containers within lockers), not on products, packaging or equipment. Disposable gloves shall be removed before each break, changed upon re-entry into the processing area and when damaged. Employees must comply with hand washing practices even when gloves are used. Any disposable clothing must be changed between breaks, upon entry into processing areas and when damaged. This includes aprons, frocks, smocks, boots, gloves, etc. When clothing is to be reused, it must be properly cleaned and stored on racks or hangers. It cannot be stored on boxes, product or packaging materials. Hairnets and beard snoods are to be worn by employees working on the packing or processing line or who work around exposed product.

 

Company choices for clothing, including uniforms, gloves, hairnets, snoods and footwear shall be based on a risk analysis and reviewed at the initial desk audit. Clothing worn by staff, contractors and visitors (where appropriate) shall be reviewed at each site audit through observation and interview. Evidence may include: • A risk analysis has been conducted to determine clothing needs and choices; • Company policies on clothing including uniforms, gloves, hairnets, snoods and footwear are in place and are appropriate for the type of operation; • Company clothing policies are implemented by all staff; • Clothing provided to staff is appropriate and properly maintained; • Clothing worn by staff is clean; • Clothing worn by staff in high risk areas is not worn off-site; • There is clean or temporary clothing available for staff in high risk areas; • Items such as hair nets, snoods and disposable gloves are available at accessible locations; • Clothing designations (e.g., color coding) for high risk/low risk areas are fully implemented; • Clothing requirements for contractors and visitors are followed: • Staff clothing is clean at the start of each shift; • Staff clothing is changed when excessively soiled; • Disposable gloves and hairnets are correctly disposed of;• Non-disposable gloves and/or aprons are properly cleaned between uses.

 


Austin Bouck
Owner/Consultant at Fur, Farm, and Fork.
Consulting for companies needing effective, lean food safety systems and solutions.

Subscribe to the blog at furfarmandfork.com for food safety research, insights, and analysis.

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#7 charbear

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Posted 30 November 2017 - 12:45 PM

We are module 13 but I have to expect the guidance would be similar. Our process does involve a lot of touching and clothing can be in contact with some products. Could you post an example of your risk analysis?



#8 ctzinck

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Posted 30 November 2017 - 01:04 PM

SQF RISK ASSESSMENT ANALYSIS

 

 

Potential Hazard:

Microbiological and Physical Hazards

Cause:

Clothing / Hair Policy

Severity (Consequence):

D

Likelihood (Frequency):

4

Total Score:

21

 

 

FOOD SAFETY RISK ANALYSIS MATRIX

Severity (Consequences)

Likelihood (Frequency)

1. Fatality

A. Common occurrence

2. Serious Illness

B. Known to occur

3. Product recall

C. Could occur (published)

4. Customer Complaint

D. Not expected to occur

5. Insignificant

E. Practically Impossible

 

FOOD SAFETY RISK ASSESSMENT TABLE

LIKELIHOOD→

A

B

C

D

E

SEVERITY↓

 

1

1

2

4

7

11

2

3

5

8

12

16

3

6

9

13

17

20

4

10

14

18

21

23

5

15

19

22

24

25

 

Corrective Actions taken to eliminate or reduce hazards scoring 1-10 (or 11-15) or justification for no action taken on scores 11-25

 

The facility has a documented GMP Program which includes the requirement for all employees to wear a hair net and beard snood (if applicable).  Hair nets are required to be worn to cover the ears to help ensure to capture all the loose hair. 

The facility had not received customer complaints in the last two years for packaging materials containing any foreign material resulting from poor GMP compliance.

 

 

 

 

 

 

 

Assessment Date: 10/26/17

 

 

 

 

Signature:____________________



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#9 ctzinck

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Posted 30 November 2017 - 01:04 PM

 

SQF RISK ASSESSMENT ANALYSIS

 

 

Potential Hazard:

Microbiological and Physical Hazards

Cause:

Clothing / Hair Policy

Severity (Consequence):

D

Likelihood (Frequency):

4

Total Score:

21

 

 

FOOD SAFETY RISK ANALYSIS MATRIX

Severity (Consequences)

Likelihood (Frequency)

1. Fatality

A. Common occurrence

2. Serious Illness

B. Known to occur

3. Product recall

C. Could occur (published)

4. Customer Complaint

D. Not expected to occur

5. Insignificant

E. Practically Impossible

 

FOOD SAFETY RISK ASSESSMENT TABLE

LIKELIHOOD→

A

B

C

D

E

SEVERITY↓

 

1

1

2

4

7

11

2

3

5

8

12

16

3

6

9

13

17

20

4

10

14

18

21

23

5

15

19

22

24

25

 

Corrective Actions taken to eliminate or reduce hazards scoring 1-10 (or 11-15) or justification for no action taken on scores 11-25

 

The facility has a documented GMP Program which includes the requirement for all employees to wear a hair net and beard snood (if applicable).  Hair nets are required to be worn to cover the ears to help ensure to capture all the loose hair. 

The facility had not received customer complaints in the last two years for packaging materials containing any foreign material resulting from poor GMP compliance.

 

 

 

 

 

 

 

Assessment Date: 10/26/17

 

 

 

 

Signature:____________________

 

it didnt copy and paste very well, sorry



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#10 FurFarmandFork

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Posted 30 November 2017 - 03:42 PM

I haven't been asked for one specifically related to clothing, our food safety plan (formerly haccp plan) covers contamination by personnel and discusses how our operation does not necessitate employees to contact exposed products with their bodies other than hands, and those are limited.

 

Remember as well that "uniforms" is a broad category. If it makes sense it can be short sleeve or long sleeve smocks, lab coats, or even minimalist aprons that cover the lower body if employees have to lean over places etc. ctzinck's template above will work well if you want to explicitly call out clothing and do a more formal assessment, or you could slip it into an SOP.


Austin Bouck
Owner/Consultant at Fur, Farm, and Fork.
Consulting for companies needing effective, lean food safety systems and solutions.

Subscribe to the blog at furfarmandfork.com for food safety research, insights, and analysis.




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