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bretterin

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Posted 09 January 2018 - 12:21 PM

I was issued a non-conformance by SQF as follows:

 

"There is no documented evidence that a risk analysis was completed to ensure that the clothing and hair policy protects materials, food, or food contact surfaces from unintentional microbiological or physical contamination." 

 

Our employees wear beard nets, hair nets, and smocks.  Can anyone help me with the risk assessment to show these food protection devices are adequate?



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CLEMENT GRIFFITHS

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Posted 09 January 2018 - 08:05 PM

Ouch! That is a tough one. I never audited in that fashion and I do not think its helpful. Your policy includes hair restraints and my job as an auditor is to determine if your policy is effectively implemented. Rather than formulating  a finding in the manner described I would take a sample from several processing areas so that I have observed lets say 10 employees and on that basis decide if hair is properly restrained and protecting materials , food and food contact surfaces. 

 

I should be able to state to you the objective evidence I found that would support a conclusion that your policy was not effective. 

 

If your policy was well implemented but I still found one person with a hairnet not properly adjusted I would off the record identify it as an opportunity. 

 

The risk assessment model would not work because typically you would use complaint history and the push back would be that a good complaint track records is not proof that an incident will not occur eventually its like food safety you can try to manage it but you cannot guarantee it.

 

By the way I am back in the private sector and I got an NCR ( BRC) this year because 3 people had a piece hair sticking out from their hairnet. My solution was to introduce a larger better hairnet design and to transition away from beard nets to a hairnet  for men that covers the hair, cheeks and beard.



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Posted 09 January 2018 - 09:40 PM

Did you ask the Auditor if you need a risk analysis for every darn thing you do to protect food and contact surfaces!?!

 

Some auditors just go way too far!


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Posted 10 January 2018 - 12:18 AM

Did you ask the Auditor if you need a risk analysis for every darn thing you do to protect food and contact surfaces!?!

 

Some auditors just go way too far!

 

As a corollary, which clause did the auditor quote so as to justify his criticism ?

 

Do you perform a daily "hygiene tour" which includes "Personnel" ?

 

If yes/satisfactory, a possibly "suitable" risk assessment approach is illustrated here -

 

http://www.ifsqn.com...ate/#entry56043


Kind Regards,

 

Charles.C


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FurFarmandFork

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Posted 10 January 2018 - 05:46 PM

Did you ask the Auditor if you need a risk analysis for every darn thing you do to protect food and contact surfaces!?!

 

Some auditors just go way too far!

I'm confused why everyone considers this surprising. This isn't a crazy finding, it's clearly identified in Module 11 and the associated guidance that you need a risk analysis for the level of protective clothing you choose to use.

 

11.3.3.1 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.

 

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.

 

11.3.3 Auditing Guidance

 

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;

 

 

 

 

Include in your policy on clothing or as an associated document an analysis/documentation of high/low risk areas and your determined level of protective clothing/hairnet usage for those areas necessary to keep your food protected. This could be as simple as your policy on what is worn wear, with an explanation of why. I do so with a map of the facility and the level of risk of contamination and required clothing and other GMP's.


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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bretterin

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Posted 10 January 2018 - 05:59 PM

Clement:  If your policy was well implemented but I still found one person with a hairnet not properly adjusted I would off the record identify it as an opportunity. 

 

Tim:  Thanks Clement, but our auditor told me that the "opportunity" score has been removed.  I basically used past history as support (no hair complaints, no listeria findings, no salmonella findings, etc.) and they accepted it as a legitimate risk analysis.

 

 



Mark G

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Posted 10 January 2018 - 08:15 PM

I'm confused why everyone considers this surprising. This isn't a crazy finding, it's clearly identified in Module 11 and the associated guidance that you need a risk analysis for the level of protective clothing you choose to use.

 

 

 

Include in your policy on clothing or as an associated document an analysis/documentation of high/low risk areas and your determined level of protective clothing/hairnet usage for those areas necessary to keep your food protected. This could be as simple as your policy on what is worn wear, with an explanation of why. I do so with a map of the facility and the level of risk of contamination and required clothing and other GMP's.

 

The requirement for the risk assessment in a new element in the SQF code Edition 8 so I can see where someone might miss that.



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tdunkley

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Posted 10 January 2018 - 08:21 PM

I'm confused why everyone considers this surprising. This isn't a crazy finding, it's clearly identified in Module 11 and the associated guidance that you need a risk analysis for the level of protective clothing you choose to use.

 

 

 

Include in your policy on clothing or as an associated document an analysis/documentation of high/low risk areas and your determined level of protective clothing/hairnet usage for those areas necessary to keep your food protected. This could be as simple as your policy on what is worn wear, with an explanation of why. I do so with a map of the facility and the level of risk of contamination and required clothing and other GMP's.

 

Perhaps it would also be helpful for the standard to explicitly require a "documented" risk assessment, where auditors will in practice require this...? I see no mention of a "documented" risk assessment in the above quoted standard, although the need for one does seem to be implied. Agree this could be handled simply as suggested.



Charles.C

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Posted 11 January 2018 - 12:17 AM

It looks as though SQF are becoming attracted to the BRC concept that everything must be risk analysed/assessed/evaluated/risk managed. Disturbing.

 

IMO a risk analysis for this thread is trivial - 

 

(1) Every GFSI-recognised  FS System demands  HACCP.

 

(2) HACCP demands a hazard analysis (= risk analysis).

 

(2) Codex HACCP demands  that GMP (GHP whatever) is implemented as a precursor to doing a hazard analysis.

 

(3) GMP demands the items listed in the SQF requirement be satisfactorily accommodated.

 

The validation/verification for red is simply a routine daily inspection which IMEX every factory implements as part of their FS System.

 

QED


Kind Regards,

 

Charles.C


Charles.C

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Posted 11 January 2018 - 12:47 AM

addendum

 

Nonetheless if you would like a "Risk" Procedure to justify what is in my opinion self-evident, this impressive example offers an elegantly simple matrix illustration of how to do it -

 

Attached File  Safefood360, risk assessed cleaning program.ppt   1.56MB   1081 downloads

(particularly see slides 43 - 46)


Kind Regards,

 

Charles.C


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CLEMENT GRIFFITHS

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Posted 12 January 2018 - 03:48 PM

Well we certainly got a useful discussion out of this thread.  I conclude that I could live with the risk assessment concept and yes "opportunity for improvement" is not a grade its a  discussion the auditor could have off the record  and the auditor has to be careful that it does not fall into " soft auditing". If auditing is going to add value one needs to identify solid non conformance's that will drive continual improvement rather than generating "fluff". That being said however its not my call as to if a hairnet being slightly exposed is "fluff" I just want to encourage and support better auditing and encourage sites to improve their processes.



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Charles.C

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Posted 12 January 2018 - 08:24 PM

Repeating the SQF8 Code -

 

11.3.3      Clothing

11.3.3.1    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.

 

 

Seems to me this is equivalent to asking for a risk-based Validation of the Policy prior to its implementation.

I suspect (despite the SQF8 Guidance quote below) that wheels are quietly, subtlely, reversing the Policy change in ver.7.2 that Hygiene PRPs do not require Validation.

 

 

2.5.1        Validation and Effectiveness (Mandatory)
2.5.1.1  The  methods,  responsibility  and  criteria  for  ensuring  the  effectiveness  of  all  applicable  elements of  the SQF Program shall be documented and implemented.  The methods applied shall ensure that:
i.        Good Manufacturing Practices are confirmed to ensure they achieve the required result;  
ii.        Critical food safety limits are validated, and re-validated annually;
iii.        Changes to the processes or procedures are assessed to ensure controls are still effective; and  
iv.        All applicable elements of the SQF Program are implemented and effective.  
2.5.1.2  Records of all validation activities shall be maintained.

 


Kind Regards,

 

Charles.C


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Louie S.

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Posted 05 September 2018 - 07:59 PM

I stumbled upon this thread and I really enjoyed reading all the insights.  Thank you all!!

 

But now...

 

I have to question why I chose this career.   :eek_yello:  :doh:  :lol2:



Scampi

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Posted 06 September 2018 - 01:59 PM

Louise S, that's something we've all thought!!!!!!!!!

 

We are all part lawyer, part scientist and part peacekeeper...........it's a much more demanding job than people realize!!!

 

 

I would also like to note to the above discussion (which I've also just read) that the risk analysis is to be reviewed AT THE INITIAL DESK AUDIT and subsequent audits verified by onsite observations.

 

My biggest peice of advice, is know the code and the regulations that apply to you better than the auditor does!


Please stop referring to me as Sir/sirs


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Sarah72

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Posted 15 October 2018 - 06:43 PM

Hello! I recently got a non conformity for not having the documented risk assessment. Does anyone know of a resource or database for all of the risks which would need to be taken into account?

 

I know how to conduct a hazard analysis, however for our HACCP plan I relied heavily on the CFIA's Reference Database for Hazard Identification in determining which hazards were applicable/needed to be assessed to make sure I covered everything (particularly for the specific microbiological risks to be taken into account).

 

I am new to this forum, and any help would be greatly appreciated!



Scampi

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Posted 15 October 2018 - 07:30 PM

This is such c**p that auditors are asking for this nonsense regardless of what the code says.

 

Sorry for the rant..........this is a ridiculous addition to V8 and not a good use of anyones time

We do not use gloves (hand packaging into glass jars) so I just have a blurb that says the risk of using them (broken gloves, broken jars etc) is higher than not using them. Auditor this year did not ask for this

 

The RDHI is a great tool but does not cover this silly RA. I would also urge you to use the FSEP manual as your HACCP plan builder

 

11.3.3.1 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.
 
I would write a short bullet style blur........
Hair restraints....hair carries staph=hair nets/beard nets from a reputable source made for that purpose
Street clothes could come in contact with food=company issued smock or apron from a reputable source made for that purpose
Gloves--in Canada we are generally less likely to use them (unless high risk/meat/dairy/cheese) so that one is up to you but if you're going to use them make sure they are from a reputable source made for that purpose
 
Voila, you're done

Please stop referring to me as Sir/sirs


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Posted 15 October 2018 - 09:06 PM

 

This is such c**p that auditors are asking for this nonsense regardless of what the code says.

 

 

I have a matrix with all of the unnecessary (well, what I felt was unnecessary) risk assessments that auditors requested from our site year after year. Added the clothing/hair net risk assessment to it recently. :) They all have basically the same form and the same conclusions...



Sarah72

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Posted 24 October 2018 - 01:43 PM

Thank you for your help! I did this, and also did ATP swabs on all of our protective clothing (uniforms, gloves, sleeves/aprons, hairnets/beard nets, etc..), to show that these items do not pose a risk to our products.



phannon

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Posted 31 October 2018 - 04:24 PM

As a corollary, which clause did the auditor quote so as to justify his criticism ?

 

Do you perform a daily "hygiene tour" which includes "Personnel" ?

 

If yes/satisfactory, a possibly "suitable" risk assessment approach is illustrated here -

 

http://www.ifsqn.com...ate/#entry56043

 

I have a matrix with all of the unnecessary (well, what I felt was unnecessary) risk assessments that auditors requested from our site year after year. Added the clothing/hair net risk assessment to it recently. :) They all have basically the same form and the same conclusions...

We just got hit with this on our audit yesterday.  Auditor requested risk assessment on clothing, hairnets and beard nets.  Could you share your risk assessment template with me?



Charles.C

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Posted 31 October 2018 - 07:23 PM

We just got hit with this on our audit yesterday.  Auditor requested risk assessment on clothing, hairnets and beard nets.  Could you share your risk assessment template with me?

 

Hi phannon,

 

I assume this is SQF8.

 

If (partially) directed towards myself, I suggest to see Post 10.


Kind Regards,

 

Charles.C


CLEMENT GRIFFITHS

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Posted 31 October 2018 - 07:39 PM

Basically, we would create a table typically in Excel and use the following titles :

  • Food Safety Attribute  ( Clothing, Beard nets, Hairnets, etc)
  • Concern / Threat   ( Concerned that there is the potential for product contamination traceable to unhygienic workwear or the failure to wear or improperly wear hairnets or beard nets )
  • Probability ( 1= remote 2= possible, could happen, 3= has occurred  
  • Severity ( 1= complaint ,2 = lost sales 3= Lost account ( customer)
  • Risk Score ( probability X Severity)
  • Risk Level ( Risk Score < 3 = Low risk , >3 NLR)
  • Control Measure ( If risk Level = <3, "NA", specify control measure
  • Monitoring / Verification  ( state how and how often) 


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Posted 31 October 2018 - 09:54 PM

One could perhaps simply base it on the Production Zone risk level, eg low risk, high risk, high care, enclosed using the freely available BRC self-help tree.

 

Then define the same outfits to be (mostly) used everywhere but with applied colours/segregation as appropriate. :smile:


Kind Regards,

 

Charles.C


jgerthe

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Posted 01 November 2018 - 03:52 PM

I also had a bit of a "wtf" moment when I came across this in preparing for our SQF audit last month. I was able to come up with a risk assessment based on my interpretations of what I thought they wanted.

 

So basically, even though we have GMP's that state that certain articles of clothing are not allowed on the production floor, that jewelry is not allowed, improper footwear, and that hair nets/beard nets are utilized by all employees, you still have to address the fact that 1) people will disobey the rules even though they know they are supposed to be following the GMPs and 2) these contaminants could still possibly make their way to the floor. I came up with various different scenarios of "what if this happened to allow this to make it's way to the floor". Then I did a probability/severity assessment for each one to determine the significance, then documented the actions we are taking to minimize the risk. It does seem redundant as all of this is documented in our GMP SOP, but not only did it address employees who are trained on this (several times), but it also takes into consideration the visitors who come into the facility and other incidents that we have come across. 

 

We have 3 facilities and as of right now, 1 has been audited. This was shown when asked for it, and the auditor said it looked good. He will not be the same auditor that will be doing the other two facilities. But like someone else said, it's hard knowing exactly what the auditor is looking for as they are inconsistent and what is good for one will probably be lacking to another. 



miseenplace

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Posted 19 November 2018 - 01:38 PM

Got a minor on this one too. I followed the code and have evidence but auditor wants something more documented. Feeling lost  :uhm:



MrHillman

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Posted 19 November 2018 - 03:03 PM

Make sure workers do not eat personnel items while wearing protective clothing. Allergens could be passed on.






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