Costco "No Bare Hands" Policy

Good Day Folks,

Costco has a "No Bare Hands" policy for RTE products unless an exception has been granted by Costco Food Safety. 

I plan on contacting Costco Food Safety team to see what it requires, but I wanted to see if anyone has applied for the exception on this policy.

If you have, what did it take? What do I need, to be granted the exception?

TIA

itreatpets: You did not mention much about your process, however why would you want a exception to this. If the product is RTE you would want to handle it accordingly, which would include gloves for example. That's the reasoning for the product. 

I'm curious about this as well. We make bread, so bare hand contact is necessary when handling the dough. 

We used gloves during dough handling for a brief period, but stopped due to glove fragments being found in the finished product. If/When we apply to Costco, I would plan on showing them this documentation. Would this along with the hazard analysis and a policy on glove use prior to the bread being baked be enough?

I have heard that it's very difficult to make a case that Costco finds acceptable. 

P.S. sorry to piggyback onto your question, TIA :) 

Is the Costco requirement for raw dough too? It sounded like it was only for RTE product...

We fall into the low-risk RTE category...We sell RTE bread. Their policy states it's required for all RTE products of all risk levels.

Does their policy mean no bare hands contact at any point during production, or just after the product is considered RTE (i.e. after the kill step of baking)? 

Ok thanks for explaining the product. 

I do not know. I would just asked them the scope of the policy. If it's for dough too, than that could impact your process a little bit. 

It seems more likely though its only for when your product becomes RTE. 

Just ask them to clarify.. 

I would think so (or hope so), as well. I'll reach out and report back just in case anyone else here has the same question.

I think it's on a ready to eat product i.e. After your kill step.if you consider baking to be your kill step and  we don't expect anyone to eat dough..

.

I am guessing a risk assessment is in order and the list of controls you have to ensure the risk to RTE is minimal.their approach can be if you do bare hand contact in one area and gloves in another ..what "zoning"do you have .Are you doing bare hand contact where all employees are looking..?how do you communicate this to other employees?

Zoning will be key to your argument-if you have the zoning concept-I don't see them refusing your exemption.

itreatpets: You did not mention much about your process, however why would you want a exception to this. If the product is RTE you would want to handle it accordingly, which would include gloves for example. That's the reasoning for the product. 

We produce 100% natural pet treats, Freeze Dried meats and more. The reason we have a hard time working with gloves is it becomes a safety hazard in SOME process areas, but we do use gloves in many areas of our RTE production. So the exception would only apply to a few tasks where the safety risk is high.

In the past, we tried gloves and the outcome wasn't good. One person had a glove caught on a piece of machinery, no injury but it could have been worse if the person wasn't familiar with the machine. Second is a glove melted when working with the heat shrink tunnel (I think the gloves used in this situation was not the proper type for the job). Lastly, we use touch as a sensory check for some of our products to ensure there are no sharp splinters starting to form that could harm an animal.

Dear All,

So what does the Policy actually state ?? is it claimedto align with one of BRC, SQF etc ?

(1) Not much doubt presumably that the finished product is terminologically RTE.

(2) But it all depends on how the minefield of High/Low Risk Product and  Production Zones are defined by Costco together with the respective associated specific requirements.

As per their Glossaries the GFSI-recognised Standards, eg BRC/SQF, seem to have variable viewpoints on (2).

A good illustration is the BRC document on their interpretation of "High Risk/High Care" which is  variously posted on this Forum. Most other Standards seem extremely shy to offer specific examples.

Costco GMP Audit Policy is:

Gloves are to be latex free and powder free, they are maintained intact, clean and in good condition. Gloves must be used where there is direct hand contact with ready-to-eat products. “No Bare Hands” policy in place unless exception has been granted by Costco Food Safety. Procedures for the proper handling and usage of gloves have been developed, implemented, and verified where required. Non-disposable rubber gloves must be washed and sanitized frequently, after breaks, and/or after handling potential contaminates.

My understanding is Costco audits aligns with SQF.  I do not remember nor have I looked for it yet..."no bare hands policy" in SQF. I will read the BRC document about the interpretation of "High risk/High care".

Maybe there's a better guidance document for Costco that I haven't received or read yet. Planning on contacting Costco Food Safety dept to get more clarification today.

The document I have (last updated May 1st 2018) states:

Costco  has a "No Bare Hands" policy- i.e. gloves must be used where there is direct hand contact with ready-to-eat products (all risk level). The facility must have a written procedure for the proper handling and usage of gloves and must include verification documentation. Reusable rubber gloves must be washed and sanitized frequently, after breaks, and/or after handling potential contaminants. If fabric gloves are used when hands are are in contact with food, they need to be covered with an outer non latex, powder free disposable glove. All other types of gloves are to be latex free and powder free. They should always be clean and in good condition.

Where it can be demonstrated, through scientifically sound validation studies, that the wearing of gloves is impractical or less hygienic than bare hands, Costco may grant an exception to the glove requirement.. There are rarely issued, and are only granted when the product, processes, risk-level, and validation evidence support this. 

Here is the most recent doc I could find

https://webapps.traq...rvlet?filename=Costco_Food_Safety_Expectations.pdf

It does specifically mention the bare hands item

We supply costco and this has never come up nor have we had an on site audit however

Thanks, Scampi. It seems like Costco updates that document at least once every two months...just something to note for everyone actively working towards a Costco audit. 

Interesting that you haven't had an on site audit...how long have you been supplying Costco?

4 years, they are the reason we became SQF .............but we are a seasonal supplier and are not in stores all the time and not all stores...............so it may stand to reason that their requirements depend heavily on those items?.?.?..

I would also like to add from my experience, this gloves always business appears to be a USA type standard........the only chain restaurant I've ever seen gloves worn is a large sandwich chain....just saying

Also, it seems to me Costco doesn't understand 'magic gloves" syndrome at all

Here is the most recent doc I could find

 

https://webapps.traq...rvlet?filename=Costco_Food_Safety_Expectations.pdf

 

It does specifically mention the bare hands item

 

We supply costco and this has never come up nor have we had an on site audit however

The link is giving me an "under maintenance" statement. Strangely it's headed by NSF.

here is the pdf

addendum

After accesssing document by an alternative method, the content looks similar to Post 12

IMO Paragraph can only be described as typically "ambiguous".

Only Nostradamus knows the answer.

Charles,

Looks like half of the link is broken, if you copy paste everything (include the Costco_Food_Safety_Expectations.pfd into it), it should work!

Charles,

 

Looks like half of the link is broken, if you copy paste everything (include the Costco_Food_Safety_Expectations.pfd into it), it should work!

Actually not. I think it's a forum aberration due the truncating. It happens. Using the full original url does work, as you say.

@Scampi

Thanks for the file.

I love getting perspective from those of you who aren't in the US...so interesting (although not that surprising  :lol2:)

4 years, they are the reason we became SQF .............but we are a seasonal supplier and are not in stores all the time and not all stores...............so it may stand to reason that their requirements depend heavily on those items?.?.?..

 

 

I would also like to add from my experience, this gloves always business appears to be a USA type standard........the only chain restaurant I've ever seen gloves worn is a large sandwich chain....just saying

 

Also, it seems to me Costco doesn't understand 'magic gloves" syndrome at all

We produce shelf stable product in jars. We emailed our Costco rep and they gave us an exemption on this. We just show the email to our auditor and it has been accepted for over 4 years. The reasoning was we only handle the product after it is completely sealed in jars. This may not apply to your products. I would recommend emailing your Costco contact and asking if it is possible.

Hello TIA,

why don’t you demonstrate with micro modelling, such as PMP or com base, that the bare hands handling of raw dough is not significative going to increase the count on S aureus (that could potentially be in the hands)?

Leila