SQF 11.3.4, Watches, Jewelry and Personal Effects Removal for Visitors
SQF version 8 states that employees cannot wear watches and jewelry where product is exposed. (implying that those in the warehouse could wear jewelry)
But then a couple lines down in reference to visitors, it does not grant this, it simply states visitor cannot wear jewelry. (does not specify "around exposed product", making it a more definitive statement)
So I ask a visitor to remove all their jewelry just so they can walk into the warehouse and see employees with jewelry? What is everyone's understanding of these two items?
How do you address implementation of this in your facility?
11.3.4 Jewelry and Personal Effects 11.3.4.1 Jewelry and other loose objects shall not be worn or taken into a food handling or processing operation or any area where food is exposed. The wearing of plain bands with no stones and prescribed medical alert bracelets can be permitted, however the site will need to consider their customer requirements and the applicable food legislation.
11.3.5.2 All visitors shall be required to remove jewelry and other loose objects
PD
Our employees and visitors are prohibited from wearing jewelry in the entire operation portion of the facility. We want a level playing field and reduced complexity. If someone shows up with a specific medical need for a device or alert jewelry we will perform a risk analysis and make a business decision.
I agree with Watanka, that is the easiest way - don't allow warehouse employees to wear jewelry. While SQF can be interpreted that way - you ultimately have to be in compliance with federal law. Not sure which industry you're in but in regards to the food manufacturing and the FDA - they don't allow it. 117.10(b)(4)
It's a very simple thing to avoid any confusion whatsoever. You have GMPs for Employees (and that means all employees, including management and owners), Contractors and Visitors - basically everybody follow the same rules, period.
Everybody.
This way, everybody wears hairnets, this way everybody can't wear a watch, a ring, a bracelet, etc.
I absolutely loved the uniforms at this one facility I inspected one day - if the person had a medical issue, allergen issue etc they had a window pocket sewn onto the pants section and it displayed a medical card -- so no more medical alert bracelets nor chains etc that could easily fall out of shirts, etc .
The uniform idea is really good. Hope you don't mind if a "borrow" it. All my best ideas I borrowed form someone else which is why I love this forum.
Thanks!
I agree with Watanka, that is the easiest way - don't allow warehouse employees to wear jewelry. While SQF can be interpreted that way - you ultimately have to be in compliance with federal law. Not sure which industry you're in but in regards to the food manufacturing and the FDA - they don't allow it. 117.10(b)(4)
Open to interpretation...states "unsecured jewelry" and "other objects that might fall into food, equipment, or containers". To me, it isn't so black and white. Surely a watch is "secured" to one's wrist.
(4) Removing all unsecured jewelry and other objects that might fall into food, equipment, or containers, and removing hand jewelry that cannot be adequately sanitized during periods in which food is manipulated by hand. If such hand jewelry cannot be removed, it may be covered by material which can be maintained in an intact, clean, and sanitary condition and which effectively protects against the contamination by these objects of the food, food-contact surfaces, or food-packaging materials.
If you can make a blanket policy that's great! Much easier to implement and enforce. Unfortunately, not all facilities and/or businesses allow this due to various reasons.
Unfortunately, I've inherited a facility's policy that is quite confusing. For one, they state "micro sensitive", "GMP", and "Food Production" as three separate areas with differing GMP requirements. Additionally, my boss doesn't really help to alleviate confusion because he waffles back and forth on what should be enforced. I really have to corner him to make a "concrete, specific" decision on things.
As others have said...if you can make it a blanket policy and enforce with everyone...employees, visitors, contractors. Just make sure if your company CEO or owner is walking through they must follow policy as well. I've been in several facilities where I've ingrained GMP's so much so the employees have gone up to the CEO or owner and asked them to follow specific GMP's. In every instance, the CEO or owner was appreciative of that employee confronting them about the GMP policy.
I find the most difficult bunch be the contractors. Usually maintenance departments are pretty bad, and when they bring in their contractors they are doubly bad about following GMP's.
I agree with GMO.
I have seen the results of a complicated message on these matters, it is such an uphill battle it keeps bringing me back to one thought...
What is the benefit of the allowance? What do I get for allowing people to where a watch? Nothing. Those same people will throw me under the bus the first chance they get. What I have seen happen again and again is that every time you make an allowance across broadly enforced GMPs it comes back to complicate your life. First it's a watch, until they start coming in with apple watches that play videos and music.
At times, I am forced to point toward a safety issue to support my GMP decisions. You can always point out the danger of watches in relevance to machine operation.
This doesn't seem to be a grey area to me. It states "Jewelry and other loose objects shall not be worn or taken into a food handling or processing operation or any area where food is exposed." Notice the OR any area where food is exposed. It also states "shall not be worn or taken". Also it doesn't differentiate between employees or visitors, which means everyone, every time, NO jewelry. I think it even implies shipping, receiving, warehouse etc. if you consider them part of a "food processing operation" (in the broader sense) which, arguably, they are. We have banned all jewelry from our production areas and we define a production area in our plant as any area that is not designated as offices or the break area. This also removes the grey area of "what is a production area" and includes all employees being under the rule. Just how I see the statements and how we do it here.
in addition to banning jewelry for everyone as several people have stated above, we do have a clause that states "religious relics can be worn at managements discretion." however no one has yet to ask to wear their crucifix or anything else so it hasn't been an issue.
Open to interpretation...states "unsecured jewelry" and "other objects that might fall into food, equipment, or containers". To me, it isn't so black and white. Surely a watch is "secured" to one's wrist.
(4) Removing all unsecured jewelry and other objects that might fall into food, equipment, or containers, and removing hand jewelry that cannot be adequately sanitized during periods in which food is manipulated by hand. If such hand jewelry cannot be removed, it may be covered by material which can be maintained in an intact, clean, and sanitary condition and which effectively protects against the contamination by these objects of the food, food-contact surfaces, or food-packaging materials.
This is my thinking exactly! The only kind of jewelry I would truly consider unsecured is the type of earings where they just kind of hook in and there's no back to them. I have one lady who has a metal nose ring in place that she's never removed and we have a metal detector, so I'm having trouble seeing what the issue is. Conversely, I'd love to know what the FDA considered "secured jewelry." We have our 4th SQF audit coming up and I'd like to have answers before then.