38 replies to this topic

[Scampi]

Perhaps the confusion is that we are looking at this the wrong way................is SQF asking that the PPE is suitable to not contaminate the product (i.e. NON latex gloves or aprons made of food contact approved plastic vs non)?????

 

Instead of; Does the PPE do the job it's been chosen for?

[dsafforld]

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?

dID YOU EVER FIND A DOCUMENT?

[jeff.mil]

We had a non-conformance by SQF for 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. 
 
What i am doing is that i made up a Quarterly check using a template like below.  Would you think this would work?

Edited by jeff.mil, 08 January 2019 - 09:45 PM.

[tina Block]

 

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. 

 

Are you able to show me how you did it? please help! thank you. My email add xxxxxx Thanks.

[tina Block]

We had a non-conformance by SQF for 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. 
 
What i am doing is that i made up a Quarterly check using a template like below.  Would you think this would work?

I don't see the template. Please share. 

[tina Block]

 

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) 

what does NLR mean?

 

[SausageGuy]

 

what does NLR mean?

 

 

 

Tina, hopefully this isn't too late of an answer for you, but NLR in that context means Not Low Risk (I believe!).

[kenzml]

 

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. 

 

 

 

HI gerthe, 

 

So glad to hear the auditor was impressed with this! Reading the thread, it is apparent the auditors are being stringent with this section of the code.

 

Would you be willing to share an example of one of your "what if" scenerios? We too have implemented HACCP and all our GMP's which cover specific attire requirements but it seems they are wanting more....

[Angus86]

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...

I'd love to see a copy of this matrix to prepare myself 

[Anwer Khattak]

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...

 

Can you please share the matrix, would love to see it.

 

Regards,

M. Anwer Khattak

Edited by Anwer Khattak, 04 May 2021 - 08:54 AM.

[Cheza0021]

Everyone is correct on "How To"' but can someone post an actual document?

[PQAManager]

Mine was simple and accepted by 2 SQF auditors.  I have attached it.

Attached Files

•  2023 Clothing Risk Assessment.docx   14.21KB   40 downloads

[Cheza0021]

Template (SQF 11.3.3) Clothing_Hair Risk Assessment.xlsx]

Attached Files

•  Template (SQF 11.3.3) Clothing_Hair Risk Assessment.xlsx   456.69KB   35 downloads

[Cheza0021]

Template SQF REF: 11.3.3 

Attached Files

•  Template (SQF 11.3.3) Clothing_Hair Risk Assessment.xlsx   456.69KB   15 downloads