8 replies to this topic

[techmgr_uk]

I just want to make sure I'm not going mad here.  I am preparing a low risk manufacturing business for their first BRC audit and rewriting the changing procedure and personal hygiene policy to reflect the increase in standards.

 

The site has toilets which open out into the changing area (i.e. not directly into production) and there is currently no guidance on how to use the toilets in relation to changing (or using the changing room handwash sink prior to re-entry).  As a business with strong environmental credentials I do not want to use more of the disposable mob caps than is necessary (without compromising food safety of course) so in my mind keeping hair nets on whilst using the toilet feels like the right thing to do.  The rest of the protective clothing would be removed.  Am I mad?

 

Just to add - the lunch room is NOT near the toilets and so staff are free to go to the toilet when they wish, not just during breaks.

[zanorias]

7.4.1 The company shall document and communicate to all employees (including agency and temporary

personnel), contractors or visitors the rules regarding the wearing of protective clothing in specified work

areas (e.g. production areas, storage areas etc.). This shall also include policies relating to the wearing of

protective clothing away from the production environment (e.g. removal before entering toilets, and use of

canteen and smoking areas).

 

From Interpretation Guide:

 

Documented protective clothing policy

The company is required to determine the procedures for application and use of protective clothing based

on a risk assessment. The risk assessment must consider foreign-body, microbiological and allergen risks

as appropriate, as well as general good-practice principles. It must document:

• removal of protective clothing before entering toilets

 

Wearing any kind of PPE inside a toilet is a hygiene & contamination no no for me.

 

Perhaps others will have found a way to risk assess and justify it...

Would the staff be re-entering an open product area?

 

I like the strong environmental credentials, but this can't be used to justify compromising food safety to an auditor. You mention staff are free to go to the toilet when they wish - perhaps a control of this could help to reduce washing/disposal of PPE.

[pHruit]

I certainly wouldn't want to try to defend it to a BRC auditor, even with a strong risk assessment in place.

Too easy to construct a scenario of e.g.: Visit toilet, touch unclean surface (or body part), touch hairnet, wash hands, re-enter production, touch hairnet, re-contaminate hands.

I think there will be more of these environmental vs. food safety type questions as businesses look in more detail at where gains can be made. And it doesn't hurt that many of them could also provide cost savings

[techmgr_uk]

BRC doesn't say that you have to remove PPE in toilets - it says that you must have policies for doing so.

 

I'll have a think on this over the weekend.

[zanorias]

However the policy and RA it is based on would have to be acceptable to the auditor. IMHO this is what you would struggle with, primarily for the contamination route pHruit describes. CCTV cannot verify employee activity in the toilet room, so you'd have to verify cleanliness of the hairnets before entering production - not something I imagine is feasible or practical.

[Charles.C]

Strictly speaking, Post 4 looks semantically "accurate", ie BRC8 has "kicked the can".

 

This topic has been debated on several occasions here, notably within the PPE genre. Not only are hairnets of interest, eg Boots ?

 

Generally,  the removal or not of hairnets before entering toilets seems to be contentious, eg this SQF thread -

 

https://www.ifsqn.co...stroom-allowed/

 

Implicit/Explicit/Evasive Literature references exist for either option, eg, from a couple of  UK Manufacturers and an Australian one -

 

Workwear should be removed by production staff before entering the toilets or canteen unless risk assessment concludes otherwise.

 

Coats/jackets must be removed before entering toilets, canteen and rest areas (including any designated smoking area)

 

Protective clothing including aprons, coats, jackets, and gloves (excluding hairnets) must be removed before entering toilets, canteen, smoking areas, and offices (outside production areas)

 

 

Reminiscent of the hazard ascribed to toilet doorknobs ?

 

The situation is probably more clear cut where > Low Risk production is involved but separate Toilets ?

[Leila Burin]

Hello, beyond what BRC says or not, pls use common sense, it is not hygienic and that´s all it matters....

I don´t think it will be a very costly measure, or “not environmentally friendly”, food safety first…

Best regards,

Leila

[Charles.C]

Hello, beyond what BRC says or not, pls use common sense, it is not hygienic and that´s all it matters....

I don´t think it will be a very costly measure, or “not environmentally friendly”, food safety first…

Best regards,

Leila

 

Hi Leila,

 

Slightly OT

 

Ahh!  the Common Sense Card

 

I quite liked this although it's a bit laborious -

 

https://www.quora.co...ed_qid=19249329

[zanorias]

Not in relation to OP, but I've been in the industry a relatively short time myself though I get the impression that neither "hygiene" nor "common sense" are commonly at the top of the consideration list, usually when management/production has an idea on how to save money/time.