Please advise: During a recent PrimusGFS audit for a dry onion packinghouse, a nonconformance was issued because the employees don't wear hair restraints (2.20.04.) The risk is low (no "processing" [cutting] of the onions is occurring and the mesh bags have the potential to let other contaminants into contact with the onions.) I know we're ascribing to PrimusGFS guidelines but the FDA's Produce Safety Rule doesn't require hairnets to be worn. Bottom line is that management would like to decline doing a corrective action for this. How do I approach this on the paperwork that I must submit back to our auditing body? Is it appropriate to state: "Due to the low risk of exposing the product to a biological, chemical, or physical contaminant via employee's hair, there is no hair restraint policy in place at our facility."
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