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#1 nbobrowicz

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Posted 02 July 2019 - 05:10 PM

We are a printer of (low risk) food packaging material. Hairnets and beardcovers have been in place for several years and no auditor has ever questioned this. However, personnel have recently begun questioning inconsistency in the use of beard covers. We do not require mustaches to be covered (mainly because the SQF requirement does not specify it), however some people feel that a small 'soul patch' or tightly trimmed beard does not require a cover. Others have argued they may miss a few days shaving and get a stubble that is not considered a beard. This is now being challenged.

Does anyone have any guidance regarding acceptable beard length in a low risk, non-food handling

environment?



#2 Ruthie1

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Posted 02 July 2019 - 05:34 PM

My rule is, if you can pinch it, it has to be covered. 



#3 paulam1

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Posted 02 July 2019 - 05:35 PM

I would perform a risk assessment.  If you can validate the issue is of hair being low risk, that is the idea behind the data you need. 

 

I really do not believe this is the case, from a manufacturer point of view if I bring your product in to my facility and package it and find hair, that is a foreign material.  I would then be requesting a corrective action from you as a customer.  

 

This is a very basic GMP in our facility, and we have went to full coverage burkas to prevent the concern of any head or facial hair from being exhibited.  In some cases some individuals wear 2. Also we encourage changing upon need (ie. when torn, ripped or generally a individual feels the need. 

 

 

Being on the supplier verification side of things though, I would keep this in mind, if you are supplying a food contact material, you should be maintaining the same standards as the company producing that food, to prevent any contaminate from occurring in the finished goods...This is a part of the supplier verification process.  I can see why customers would question this. 

 

Once again my opinion only.



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#4 zanorias

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Posted 02 July 2019 - 06:05 PM

We are a printer of (low risk) food packaging material. Hairnets and beardcovers have been in place for several years and no auditor has ever questioned this. However, personnel have recently begun questioning inconsistency in the use of beard covers. We do not require mustaches to be covered (mainly because the SQF requirement does not specify it), however some people feel that a small 'soul patch' or tightly trimmed beard does not require a cover. Others have argued they may miss a few days shaving and get a stubble that is not considered a beard. This is now being challenged.

Does anyone have any guidance regarding acceptable beard length in a low risk, non-food handling

environment?

 

^ I think that is the key word here. As with many things, as soon as there is some inconsistency or different rules for different people there will be challenging and non-conformance. 

Not familiar with SQF but IIRC the BRC I.G goes as far to say "excessive stubble". Fair to say "excessive" is somewhat open to interpretation, but I too have heard the "if you can touch/pinch it" a snood is required. Whether it's a small "soul patch" or a beard that would make Gandalf envious, there potential to contaminate food/packaging remains. What does the SQF guide say on the matter?

 

Once the standard for snood  requirement has been established, it will need to be enforced thoroughly and be consistent across all staff. Hopefully after some time the challenge will fade and the standard accepted, otherwise I'd proceed the non-compliance to HR/management.

 

On a side note, I'm surprised SQF does not require a moustache to be covered  :huh:



#5 nbobrowicz

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Posted 02 July 2019 - 06:15 PM

SQF module 13 requirement for food packaging really gives no guidance as to how to determine to food safety risk for facial hair. We have never had a complaint for hair of any kind (or any other foreign matter) in the 10 years that I have been here.

If anyone has suggestions on where to start a risk analysis for this, I'm all ears...

13.3.3.1 Clothing

The site shall undertake a risk analysis to ensure that the clothing and hair policy protects food contact packaging from unintentional contamination.

 

 



#6 SQFconsultant

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Posted 03 July 2019 - 04:48 AM

Got stubble, cover it.


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#7 pHruit

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Posted 04 July 2019 - 12:10 PM

Got stubble, cover it.

^This is the simplest and most consistent approach IMO.

If I don't shave for a day then I wear a snood, and that's the rule that I set for everyone else on site - no equivocation or philosophical discussion about the length at which stubble becomes a beard.



#8 Setanta

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Posted 04 July 2019 - 02:13 PM

^ I think that is the key word here. As with many things, as soon as there is some inconsistency or different rules for different people there will be challenging and non-conformance. 
Not familiar with SQF but IIRC the BRC I.G goes as far to say "excessive stubble". Fair to say "excessive" is somewhat open to interpretation, but I too have heard the "if you can touch/pinch it" a snood is required. Whether it's a small "soul patch" or a beard that would make Gandalf envious, there potential to contaminate food/packaging remains. What does the SQF guide say on the matter?
 
Once the standard for snood  requirement has been established, it will need to be enforced thoroughly and be consistent across all staff. Hopefully after some time the challenge will fade and the standard accepted, otherwise I'd proceed the non-compliance to HR/management.
 
On a side note, I'm surprised SQF does not require a moustache to be covered  :huh:


Costco does require it even when using SQF as a standard.
Got facial hair? Cover it! If length is a question, I use Ruthie's rule. Do you want me to try and pull it?

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#9 Simon

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Posted 04 July 2019 - 02:28 PM

I just want to be contrary for a minute if I may. :eekout:

 

Facial stubble doesn’t come out easily like an eyebrow or eyelash does and you don’t have dandruff on you face like you do on your head.  If I‘m right about those two things (correct me if I’m not) then what’s the risk of stubble, for example facial hair at a length less than you can pinch?

 

Human beings who are not food safety savvy still do their own commonsense risk assessments and quite rightly get disenchanted when being asked to do something that is pointless and perhaps uncomfortable.  You could say well if you don’t want to wear a beard net then have a shave, but my same point applies.

 

To encourage a positive food safety culture I think we should focus on the important things and the ‘real risks’ rather than risk bringing the whole system into disrepute because of arbitrary rules that do not add to our food safety performance.

 

In my humble opinion.

 

Simon


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#10 pHruit

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Posted 04 July 2019 - 02:39 PM

Simon, I quite agree with your humble opinion on this in principle in terms of the actual risk of stubble contamination.

My own approach is driven by pragmatism and simplicity, as it's easier to have a definitive rule that errs towards caution than it is to have an endless series of debates about the point at which stubble becomes a beard. I've come across "two day rule" and similar approaches, but for some people two days still looks pretty much freshly shaved, and for others it really is tending towards being a light beard at that point, so you then get "person x has stubble/beard that's ...mm longer than mine, so I don't need to wear a snood".

And whilst the layperson may think that "long enough to pinch" is fairly unambiguous as a concept, you've all worked in food factories with people who don't want to wear a beard snood, so you probably know this isn't necessarily the case ;)

Maybe there is a gap in the market for an app that sites can run on their CCTV systems that uses the camera feed to assess beard length? :ejut:



#11 Simon

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Posted 04 July 2019 - 02:52 PM

I understand all you say pHruit. :smile:

 

We need to take out the subjectivity and if we can make a practical tool that can replicate the "long enough to pinch" concept that would be great.  Nobody likes being pinched.  For starters lets say "long enough to pinch" was 2m, then a device that can grab or measure >2mm surely would be a winner.


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#12 Setanta

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Posted 04 July 2019 - 03:24 PM

I just want to be contrary for a minute if I may. :eekout:
 
Facial stubble doesn’t come out easily like an eyebrow or eyelash does and you don’t have dandruff on you face like you do on your head.  If I‘m right about those two things (correct me if I’m not) then what’s the risk of stubble, for example facial hair at a length less than you can pinch?
 
Human beings who are not food safety savvy still do their own commonsense risk assessments and quite rightly get disenchanted when being asked to do something that is pointless and perhaps uncomfortable.  You could say well if you don’t want to wear a beard net then have a shave, but my same point applies.
 
To encourage a positive food safety culture I think we should focus on the important things and the ‘real risks’ rather than risk bringing the whole system into disrepute because of arbitrary rules that do not add to our food safety performance.
 
In my humble opinion.
 
Simon


I am replying with a grin, but that is hard to convey.

Having removed eyebrow and facial hair from near the chin with tweezers,(my favorite thing to admit-BTW), I can tell you they ARE the pretty much the same. Eyebrows are no less sensitive than chins and repetition doesn't make it easier. But no one is asking beard wearers to pluck, are they? Shaving can be an irritant, but here are cures for that. There isn't a cure for a customer finding hair in their food.

Also, a face CAN generate dandruff and skin flakes just like your head. I know gentlemen who need to brush it off the fronts of their shirts more often than their shoulders. Stuff happens. Many people shave under their armpits, but most food facilities require sleeved shirts instead of sleeveless to prevent that hair from straying...

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#13 Setanta

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Posted 04 July 2019 - 03:27 PM

I understand all you say pHruit. :smile:
 
We need to take out the subjectivity and if we can make a practical tool that can replicate the "long enough to pinch" concept that would be great.  Nobody likes being pinched.  For starters lets say "long enough to pinch" was 2m, then a device that can grab or measure >2mm surely would be a winner.


Again, for me, the grasping of facial hair is done with humor. Most people know that if you can feel it, it is also visible and should be covered/removed.

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#14 larissaj

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Posted 04 July 2019 - 03:41 PM

Ive gone with this idea, if you can see it, you cover it no matter if it is a beard or mustache. No gray area, very black and white. You have facial hair? It gets covered, dont like it? then shave. Simple. 



#15 mgourley

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Posted 04 July 2019 - 03:44 PM

What about arm hair?

Certainly for some men that's more of an issue than a days growth of beard?

We use "two days growth" as a standard... which of course is not a standard at all.

If you have noticeable "stubble" you wear a snood. Period.

 

I find that works well for people who are too lazy to shave and for those that have the full beard thing going on.

 

In the grand scheme of things, "what constitutes a beard" is way down the list of food safety priorities.

 

Marshall


Edited by mgourley, 04 July 2019 - 03:45 PM.


#16 Simon

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Posted 05 July 2019 - 05:54 AM

I think this (photo) is perfectly safe and acceptable. Seriously an "if you can't stand the heat get out of the kitchen and unless clean shaven you wear a net" approach is clear and easy, but it isn't necessary. If it was shouldn't everyone wear an all over body suit and goggles. I would see a difference between someone preparing pre packed sandwiches and a fork lift truck driver in a warehouse.

They don't wear them in supermarkets and food service outlets.

I'm ok with stubble on men...and women.

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#17 zanorias

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Posted 05 July 2019 - 06:47 AM

Morning Simon :lol:

 

Some interesting and contrasting points made, but hopefully enough for the OP to make their own conclusion on what an acceptable beard length for their facility would be.

 

Once that is established there's then the question of enforcement and compliance. Personally, I am in favour of allowing in-excessive stubble, and whilst some ambiguity therefore exists, ultimately the TM has enforced the policy and all staff are expected to comply. Reasonable questioning of anything is welcome and staff have asked me previously if they require a snood on a certain day which is fine, but deliberate non-compliance is not tolerated. This has been the way for years and is accepted, part of the culture now I guess, and new guys joining the team will enter the factory and see half the people in there already wearing snoods. I think the problem arises when you have inconsistency between staff or requirements.

 

Though admittedly in this case I don't think it helps matters of consistency if an operative with light stubble is required to cover it whilst their colleague with no stubble but has a bushy moustache doesn't have to cover that. I've not had a moustache myself but I can't imagine the below-nose hairs are less probe to falling than chin hairs? :huh:  



#18 Simon

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Posted 05 July 2019 - 07:34 AM

Morning.

 

I like your policy, maybe a photo visual standard/SOP of what stubble is acceptable would be in order. 

 

I agree if required to be worn I think it should cover beard and moustache.

 

I think my tablets are kicking in. :lol:

 

Happy Friday!

 

Simon


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#19 pHruit

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Posted 05 July 2019 - 08:58 AM

Nobody likes being pinched.

There are corners of the internet where you will find people who beg to differ on this, Simon. Or at least that's what a friend told me :ejut:

 

It is amazing in general how emotive the beard snood subject can be - I'm guessing from the number of posts that we've all had plenty of challenges in this area. I've worked in a proper clean room with the full suit, mask etc, and yes it's weird at first but you get used to it very quickly really, so I do wonder: why do people hate the beard snood so much?



#20 larissaj

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Posted 05 July 2019 - 01:16 PM

I was told by a few men that the cover is uncomfortable, my response was always, because you dont have to cover your facial hair outside of work. Ive had men tell me that it always falls down, my response was that they had to tie it to make it fit, in which they would state the first response. All in all, it sucks to wear them but its what needs to happen.



#21 Simon

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Posted 05 July 2019 - 05:12 PM

There are corners of the internet where you will find people who beg to differ on this, Simon. Or at least that's what a friend told me :ejut:

It is amazing in general how emotive the beard snood subject can be - I'm guessing from the number of posts that we've all had plenty of challenges in this area. I've worked in a proper clean room with the full suit, mask etc, and yes it's weird at first but you get used to it very quickly really, so I do wonder: why do people hate the beard snood so much?

Friend :ahem:

It is definitely a spikey issue.

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#22 Jeffrey Ort

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Posted 05 July 2019 - 05:39 PM

Clean shaven = no  need

Otherwise cover both beard and moustache.

 

I had many tell me excuses why its not covering, or its fallen, then I grew a beard to make the point that is can be worn correctly and it does stays in place.



#23 Ryan M.

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Posted 06 July 2019 - 05:30 AM

Conduct risk assessment, write / revise policy, and most important of all...enforce it equitably.  You need to have all management / leadership onboard with enforcing the policy.

 

In my facility the newest challenge is shaved heads.  Our policy is hair net regardless if head if shaved or not.  If we start allowing exceptions it really opens a can of worms.  Our enforcement is not consistent as it is..we don't need any further ambiguity.



#24 zanorias

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Posted 06 July 2019 - 08:42 AM

In my facility the newest challenge is shaved heads.  Our policy is hair net regardless if head if shaved or not.  If we start allowing exceptions it really opens a can of worms.  Our enforcement is not consistent as it is..we don't need any further ambiguity.

 

I was wondering when the question of hairnets on shaved heads would arise  :biggrin:  Agree 100%, allowing one exception would be the start of something unwelcome.



#25 nbobrowicz

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Posted 08 July 2019 - 01:22 PM

Thanks to all for your input. I struggled from the start with the facial hair issue (hairnets seem straightforward as everyone wears one regardless). While I understand the 'yuck' factor, I personally consider it a low risk in our industry since there seem to be many other sources of potential hair contamination (arms, eyelashes, brows). However, I still have not found any source of objective evidence to support (or dispute) the level of risk (to packaging material) other than my opinion. Maybe I'm just weak on objectively assessing risk...






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