Older thread, but we have the same issue as a Primus client who fresh packs citrus, the logic of hairnets is hard to comprehend.
So, the current GMPs suggest "where appropriate" that "effective" hairnets be worn (21CFR110.10). Here's the language:
"Wearing, where appropriate, in an effective manner, hair nets, headbands, caps, beard covers, or other effective hair restraints."
One of the underlying questions is whether the FDA would consider not wearing hairnets appropriate. My very limited experience would say that the local AG people you work with would likely agree with you, but the FDA would not (as they just don't have the experience with AG and produce). Also, sounds like you would fall under the Produce Safety rule, which doesn't specifically state anything about requiring them; just defers you back to the cGMPs.
IMO, there are a couple of ways to handle your Primus requirements:
All options: To get the points, you would have to: Make it policy, have stations close to doors and break areas, "make" your visitors wear them and "inspect" to make sure that they are available (check the box if you will), but from there you could
1.) Only ask employees to wear them on your audit day (I know several companies that take this approach).
2.) Ask packers to wear them, but only enforce the broader rule (everyone and their second cousin wearing them) on the day of the audit.
3.) Ask everyone to wear them, but only enforce "effective" on the audit day.
4.) Be critical and enforce it daily (it's an option).
5.) Blow it off and lose the points.
My issue with the last is that usually there are some items that you will always get busted on, which lowers the effective score that you can obtain. Losing points for things you can control can start to become costly. And some customers might get a little testy if you aren't wearing hairnets. We've been dinged for people not having hairnets over their ears and had other auditors ignore the fact that someone was only wearing a cap or wearing it in a manner that wasn't effective, so I think that at least some of the auditors themselves roll their eyes at this rule.
IMO, given that your stance on hairnets is that they are stupid, just ask your employees to wear them that day. You would have to check the box on the inspections, policy, etc., but that's not a big deal. In my case, our hairnet and hair sanitizers logs are the same form, so that someone can verify availability of both at the same time.
We've chosen to have people wear them, but I only really push on the issue right before the audit and that's to help them remember what effective is. And we elected to wear them, in part because we are close to some regional regulatory offices and so we get those folks coming through routinely. Without that, I think we would probably regress into a once a year locale as well.
Anyway, good luck...