BRC Packaging & Packaging Material V6 Draft

We are a packaging company making cartons for direct food contact:

Question regarding the new BRC Packaging Version 6 draft.

6.5.1 'Hair covering and beard snoods, where appropriate, shall be worn...'

What does 'where appropriate' mean?

If a beard exists then a snood shall be worn?

or

Hair covering and snoods shall be considered depending on risk?

At the moment we only require snoods for operators in contact with our product.

Other people in production with beards do not have to wear them.

We have considered making everyone wear them to remove this anomaly but decided against it (discussion for another time).

6.5.6 of Version 5 allows risk assessment to be used for hair covering and snoods.

Does anyone interpret Version 6 as changing this and to make it compulsory?

Appreciate your interpretation.

Per my interpretation:

where appropriate = Based on risk assessment.

Agree with FSQA and also in general if hair can go from head and face to packaging that would be where they need to be worn.

In a warehouse where everything is sealed up - no.

Thanks for the reply's. That was my interpretation and so it appears no change from issue 5, just re worded. (Passed half a day of my time thinking that one through!)