5 replies to this topic

[purple_bridget]

Hello, I am looking for advice! 

 

We pack both organic and conventional fruits. When the line moves to packing an organic product, its rinsed with water and the operatives put plastic oversleeves over the arms of their overalls. They wear the same overalls all day, just put on the white plastic oversleeves whenever they are packing organic. We don't pack organic at start of shift, as the order patterns are such that we can go too/from organic production throughout the day.

The white plastic oversleeves in my opinion are nothing more than a foreign body risk. I can't see what they are protecting the organic product from, given we're not processing the fruit at all, the overall isn't in direct contact with it, all the staff are doing is picking fruit out of a box and passing it down a line to be counted into a net or flow wrap ready for retail sale. 

I was just wondering if any members have successfully removed different clothing/plastic overcovers for organic, based on the low risk? How have you justified it? Do you have a risk assessment that I could 'borrow'? Or maybe there is someone on here who has a more detailed understanding of the organic standards than myself, who can tell me exactly what we need to do. I have looked at the soil association standard (as we are in the UK) and I am none the wiser as to their requirements on PPE!! 

 

Many thanks in advance for your help!! 

[Scampi]

The sleeves are to prevent any chemicals that may be on the clothing from contaminating the organic fruits..............organic regulations are quite restrictive and I'm surprised your going back and forth throughout the day..........how are you segregating???  Our organic auditor would never allow that to happen

 

The easiest way to address this is run organic first!  Always......then you never have a risk of cross contamination

 

 

Which organic standard are you following please?

[pHruit]

Which certification body are you with?
I don't think our organic body has ever asked about clothing changes!

Starting the day with organic is generally advisable where possible, as it helps demonstrate very clear segregation.  

Who do you need to "justify" the discontinuation of the sleeves to? If you're Soil Association certified and they haven't set a requirement then it wouldn't seem to be a problem?

The latest version of the standard, rev 17.7 November 2018, makes no reference to PPE and neither do the previous versions that I've got here (going back to early 2009 without having to dig further back in the archive), but then these have never been very focussed on safety or processing in the normal sense that we think about it.

The biggest concern I could readily see them having would be whether the clothing could transfer unapproved chemicals - if they are producing a non-organic product first, is there any potential for contact with e.g. cleaning/washing chemicals (even at low concentrations) that could be absorbed and then transfer onto organic product, if the plastic covers aren't used?
A basic risk assessment should be able to support this point for you, particularly if you can combine with a scheduling control to ensure organic is always run first.
 

[ilonar]

Hello Bridget,

 

My company is also packing fresh fruit and vegetables, the only difference is that we are located in the Netherlands, and audited by other certification body, but in the end having to comply with the same EU legislation. What we normally do is try to start the activities in the morning with organic production on several lines. In case after packing conventional products we need to work with organic products, we clean the production lines-equipment and check and record if the lines are clean before starting with the new production activity. Our employees are required to wash hands when changing from conventional to organic (we don't use gloves). In the requirements that we've received from our  certification body, actually the only one in the country, there is nothing abut the use of PPE, they are only asking for separation in time and space between organic and conventional production and that the cleaning and check of cleaning have to be recorded.

 

From the experience of previous audits (we are BRC/IFS Food certified), I can tell you that if you use those sleeves in production, you will have to record how many sleeves you gave to the employees, if you got all back and if they are still intact. Otherwise the missing parts might be in your product. We had a similar non-conformity a few years ago with used gloves that were  laying everywhere in the changing area when our personnel went home, and that is why we decided to stop using gloves instead of counting 200-300 gloves/day.

 

But don't you need to use a cleaning agent to clean the tables between products? Was your cleaning procedure approved like this?

[Charles.C]

Hello Bridget,

 

My company is also packing fresh fruit and vegetables, the only difference is that we are located in the Netherlands, and audited by other certification body, but in the end having to comply with the same EU legislation. What we normally do is try to start the activities in the morning with organic production on several lines. In case after packing conventional products we need to work with organic products, we clean the production lines-equipment and check and record if the lines are clean before starting with the new production activity. Our employees are required to wash hands when changing from conventional to organic (we don't use gloves). In the requirements that we've received from our  certification body, actually the only one in the country, there is nothing abut the use of PPE, they are only asking for separation in time and space between organic and conventional production and that the cleaning and check of cleaning have to be recorded.

 

From the experience of previous audits (we are BRC/IFS Food certified), I can tell you that if you use those sleeves in production, you will have to record how many sleeves you gave to the employees, if you got all back and if they are still intact. Otherwise the missing parts might be in your product. We had a similar non-conformity a few years ago with used gloves that were  laying everywhere in the changing area when our personnel went home, and that is why we decided to stop using gloves instead of counting 200-300 gloves/day.

 

But don't you need to use a cleaning agent to clean the tables between products? Was your cleaning procedure approved like this?

 

Hi Ilonar,

 

Thks for input.

 

Of course, not using gloves might expose you to some additional investigative queries from auditors ?.

[ilonar]

Hello Charles,

 

We haven't had any problems until now with not using gloves. We stopped using them in 2012, with exception of cleaning and covering a plaster. As we are (re)packing fresh fruit and vegetables and are low risk according to BRC standard, it was accepted by all auditors. We have the requirement of hand washing after breaks, toilet visit and we do random swabbing of hands to check the efficacy of handwashig (IFS requirement).