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Setanta

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Posted 08 July 2019 - 02:30 PM

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.


Having also been bald (fundraiser at work) I wore a hairnet then, too. Simon, in my facility, you would have been wearing a beard net for several days at this point.

Arm hair is covered, so to speak by the fact we all have sleeves on our smocks. People are asked not to push them up.

We're making food here, hair may be trivial, but when found, the perception is huge.

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Setanta

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Posted 08 July 2019 - 02:31 PM

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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I get that, Auditors do not.

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The Food Scientist

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Posted 08 July 2019 - 03:10 PM

Unless its clean shaven that same day, they don't need to cover. That is my rule! 


Everything in food is science. The only subjective part is when you eat it. - Alton Brown.


CMHeywood

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Posted 10 July 2019 - 02:54 PM

I work for a company that makes food contact packaging.

 

Our poiicy:

Any hair below the corners of the mouth has to be covered by a beard net.

You must be clean shaven or you must wear a beard net (no exceptions for stubble).



Scampi

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Posted 10 July 2019 - 03:08 PM

The big issue here is not "what length of facial hair needs a beard net" but rather the overall perception of the facilities approach to food safety and the culture. IF you have a facility full of actual adults and zero tantrum pulling 5 year olds, then by all means, have some wiggle room in your policies. But since that's just not a reality in most places, policies cannot wiggle....................wear the cover or find somewhere else to work!

 

 

Now, off i go to talk with HR...................were starting edibles soon and they currently allow all sorts of jewelry in our production (non food) areas.............................so not at all looking forward to this, but if they want to succeed they need to come around to my way of doing things!  (i say with some caution of course............at least my boss is on board)


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larissaj

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Posted 10 July 2019 - 03:15 PM

The big issue here is not "what length of facial hair needs a beard net" but rather the overall perception of the facilities approach to food safety and the culture. IF you have a facility full of actual adults and zero tantrum pulling 5 year olds, then by all means, have some wiggle room in your policies. But since that's just not a reality in most places, policies cannot wiggle....................wear the cover or find somewhere else to work!

 

 

Now, off i go to talk with HR...................were starting edibles soon and they currently allow all sorts of jewelry in our production (non food) areas.............................so not at all looking forward to this, but if they want to succeed they need to come around to my way of doing things!  (i say with some caution of course............at least my boss is on board)

 

Just throw some earrings in the food at a company gathering and watch people freak out. Then state "this can happen to our customers, is that what you want?"

 

Kidding! But still, when I approach people in regards to any issues like GMPs, I always ask, do you want to eat something that has XYZ in it? If they try and be funny and say yes then a corrective action needs to take place but they usually say no. 



Scampi

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Posted 10 July 2019 - 03:21 PM

I only wish it were that simple............we are here talking full on spacers, false eyelashes, nails, polish...........the works!  And i have to convince folks that I don't care what part of the facility you're working in, we all need to play by the same rules.................I'm dealing with counter culture with current employer (cannabis) where up until cannabis production became legal in various places, no one gave a rats putout about safety!!!!!!!!


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larissaj

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Posted 10 July 2019 - 03:27 PM

I only wish it were that simple............where talking full on spacers, false eyelashes, nails, polish...........the works!  And i have to convince folks that I don't care what part of the facility you're working in, we all need to play by the same rules.................I'm dealing with counter culture with current employer (cannabis) where up until cannabis production became legal in various places, no one gave a rats putout about safety!!!!!!!!

 

I dont know about the industry for that but GMPs are what we use (Good Manufacturing Practices) and FDA has their standards that they want us to follow. Maybe having that as a back board for a fight can help.



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Posted 10 July 2019 - 05:43 PM

I work for a company that makes food contact packaging.

 

Our poiicy:

Any hair below the corners of the mouth has to be covered by a beard net.

You must be clean shaven or you must wear a beard net (no exceptions for stubble).

 

I'm curious: What justification/evidence  did you use to develop & support your policy? Are mustaches allowed?



CMHeywood

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Posted 11 July 2019 - 02:50 PM

Since we are a packaging manufacturer, we are relatively new to food safety.  I was not involved in the decision process for our beardnet policy so I can't tell you what justification or evidence was used.  I believe it was based on what a consultant had recommended to our food safety practitioner.



freshandsafe

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Posted 11 July 2019 - 06:18 PM

Yes, often hair is a quality issue that is treated like a food safety issue because customers demand that - no one likes to find a hair in their food.

 

Has anyone ever found a beard hair in a home cooked meal? Please don't tell me.

 

 

Policy wise it's easy to write but tough to enforce the length. I like the "pinch" idea.

 

Used to work for a place that had a "neat and trim" requirement for beards justified by the difference between beard and head hair.

 

Also places where beard nets were an absolute requirement.

 

Enforcement is one thing.

 

Behavior is another.

 

Challenge is you will have clean shaven people who's facial hair grows from day to day. Difficult to enforce and it does not match with their habits to not wear beard net for 2 days after shaving, but then yes for the next 2 days until they shave again.

 

Habits and human nature are one of the rarely discussed parts of these programs.

 

Eagerly watching for a practical solution,

 

 

-Josh Heinrichs

 

 

 

 

 

 

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...


- Joshua Heinrichs

 

 

 


larissaj

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Posted 11 July 2019 - 06:24 PM

I am seeing a lot of gray, it should be black and white. Facial hair = beard net. Leaves no room for arguments. Making excuses allows for anyone to come up with a reason to not wear one. 



freshandsafe

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Posted 11 July 2019 - 06:59 PM

I'm very curious Larissa, how do you implement this for very fine facial hair that is not immediately visible (many women)?

 

-Josh Heinrichs

 

 

 

 

I am seeing a lot of gray, it should be black and white. Facial hair = beard net. Leaves no room for arguments. Making excuses allows for anyone to come up with a reason to not wear one. 


- Joshua Heinrichs

 

 

 


The Food Scientist

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Posted 11 July 2019 - 07:02 PM

I'm very curious Larissa, how do you implement this for very fine facial hair that is not immediately visible (many women)?

 

-Josh Heinrichs

 

 

 

I believe if its not visible, then there's really no beard or facial hair.  At least to me and my rules.


Everything in food is science. The only subjective part is when you eat it. - Alton Brown.


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larissaj

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Posted 11 July 2019 - 07:04 PM

Exactly The Food Scientist. There is hair all over the body, we arent in a full on bubble, but any growth of a mustache or beard means a beard net. 



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CMHeywood

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Posted 11 July 2019 - 07:29 PM

Larissa:  facial hair = beardnet

 

Does this include eyebrows, nose hair, etc.?



larissaj

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Posted 11 July 2019 - 07:36 PM

Not in my plant, do you do it for yours??????????

 

I state "any beard or mustache must be covered by a beard net"

 

How you write your policy is on you, however if we are talking about "what constitutes a beard" any type of growth needs a beard net.



The Food Scientist

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Posted 11 July 2019 - 07:38 PM

Larissa:  facial hair = beardnet

 

Does this include eyebrows, nose hair, etc.?

 

fa·cial hair
noun
 
  1. a growth of hair on a man's chin, cheeks, or upper lip.
    "men with lots of facial hair"

Everything in food is science. The only subjective part is when you eat it. - Alton Brown.


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CMHeywood

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Posted 11 July 2019 - 08:19 PM

Larissa:  OK, you win!

 

I do know from personal experience that nose hair and eyebrow hair do fall out but rarely.

 

So is this about a definition or is it about keeping all hair out of your products?

 

My point is:  how strict do you need to be?  Clean rooms (e.g., electronics) may require almost total body coverage.  You can buy full face snoods (https://www.uline.co...wE&gclsrc=aw.ds).

 

The plant where I work is SQF certified.  We produce food contact packaging.  None of our SQF auditors has stated that we need to cover mustaches.



CMHeywood

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Posted 11 July 2019 - 08:21 PM

Former discussion on beardnets:  

https://www.ifsqn.co...aches-required/



freshandsafe

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Posted 11 July 2019 - 08:24 PM

CMHeywood,

 

Ultimately it's risk management, not risk elimination.

 

That's why an auditor is supposed to be more than a robot and able to exercise professional judgement.

 

Significantly less risk of eyebrows and eyelashes vs. beard and mustache.

 

We went full beard netting for any hair due to Costco's requirements.

 

-Josh Heinrichs

 

 

Larissa:  OK, you win!

 

I do know from personal experience that nose hair and eyebrow hair do fall out but rarely.

 

So is this about a definition or is it about keeping all hair out of your products?

 

My point is:  how strict do you need to be?  Clean rooms (e.g., electronics) may require almost total body coverage.  You can buy full face snoods (https://www.uline.co...wE&gclsrc=aw.ds).

 

The plant where I work is SQF certified.  We produce food contact packaging.  None of our SQF auditors has stated that we need to cover mustaches.


- Joshua Heinrichs

 

 

 


The Food Scientist

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Posted 11 July 2019 - 08:26 PM

Larissa:  OK, you win!

 

I do know from personal experience that nose hair and eyebrow hair do fall out but rarely.

 

So is this about a definition or is it about keeping all hair out of your products?

 

My point is:  how strict do you need to be?  Clean rooms (e.g., electronics) may require almost total body coverage.  You can buy full face snoods (https://www.uline.co...wE&gclsrc=aw.ds).

 

The plant where I work is SQF certified.  We produce food contact packaging.  None of our SQF auditors has stated that we need to cover mustaches.

 

Every company is different. what you do is different than what we, than what everyone on the forum does. GMPs are not strict to one rule only in SQF, or any other scheme or regulatory standard. It depends on what you do (your product risk), your results of risk assessment. None of your auditors stated you should cover mustaches simply because they did not see a risk. You can do whatever you want to as long as what you are doing is protecting the safety of your food. 


Edited by The Food Scientist, 11 July 2019 - 08:31 PM.

Everything in food is science. The only subjective part is when you eat it. - Alton Brown.


CMHeywood

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Posted 11 July 2019 - 08:43 PM

Food Scientist:  I really don't disagree with you.

 

However, I work for a company that makes food contact packaging.  We often have customers stating that our policies should be the same as theirs:  no short sleeve shirts, no shorts, cover all facial hair (beard, mustache).

 

We all need to realize that we are the type of people that like to be correct.  However, this sometimes leads us to think that our opinions, interpretations and experiences that represent the only really true statement that matches reality in all situations.

 

FreshandSafe:  I agree with you that it is about risk management and not total risk elimination (which is almost impossible).  So the issue really is - what does your risk analyis show and what level of control is necessary?  I was just trying to show how crazy we can get if we start thinking "no hair contamination whatsoever"!

 

So I find that the most helpful discussions are:  here's what we do (control program) and why we do it (risk analysis, regulations, food safety standards, etc.).



The Food Scientist

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Posted 11 July 2019 - 08:45 PM

Food Scientist:  I really don't disagree with you.

 

However, I work for a company that makes food contact packaging.  We often have customers stating that our policies should be the same as theirs:  no short sleeve shirts, no shorts, cover all facial hair (beard, mustache).

 

We all need to realize that we are the type of people that like to be correct.  However, this sometimes leads us to think that our opinions, interpretations and experiences that represent the only really true statement that matches reality in all situations.

 

FreshandSafe:  I agree with you that it is about risk management and not total risk elimination (which is almost impossible).  So the issue really is - what does your risk analyis show and what level of control is necessary?  I was just trying to show how crazy we can get if we start thinking "no hair contamination whatsoever"!

 

So I find that the most helpful discussions are:  here's what we do (control program) and why we do it (risk analysis, regulations, food safety standards, etc.).

 

If your customers required that then that's a different story! 


Edited by The Food Scientist, 11 July 2019 - 08:45 PM.

Everything in food is science. The only subjective part is when you eat it. - Alton Brown.


CMHeywood

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Posted 11 July 2019 - 08:55 PM

Food Scientist:  yes it would be a different story but sometimes it is a political issue of determining how to respond to a customer request that may not be necessary, may not be required, or may not be acceptable.

 

For example, we have a customer that produces dairy items.  They are asking us if we comply with European CPMP pharmaceutical packaging.  So we need to find out why they are asking about this and then decide how to respond.  We don't automatically start spending lots of money to have a 3rd party lab do pharmaceutical packaging testing.

 

Another example is customers asking or implying that we must have a certain percentage of minority workers.  The plant where I work is located in East Central Wisconsin.  Our minority population is very low so the percentage of minority workers is below any national average.  So do we start hiring people primarily based on their minority status?  Some people would say yes because of affirmative action.  Some would say no.

 

Just for grins:

Rule #1   There are no hard and fast rules.

Rule #2   There might be exceptions to Rule #1.





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