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.
184.108.40.206 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.