Is 'snus' food?

Dear members,

This time we received during our BRC-audit a non-conformity because the auditor noticed that one of the staff was using what we in Sweden call for “snus”, snuff/tobacco that one puts under the upper lip and will stay there a while. The auditor claimed that snus is equated with food or tobacco and thus is not allowed according 4.8.6 and 4.8.7.

Is there, under the Swedish forum members, someone who also has experienced this?

Would you allow “snus” throughout the whole facility, accept for certain zones?

Thank you for input.

Olaf (snusfritt)

No snus.

Snuff is regulated as food according to the Swedish Food Act 2006:804

§ 3 The Act applies to all stages of production, processing and distribution of food. In the Act the following are treated as food
1. water from the point at which it is taken into a waterworks to the point of compliance as defined in Article 6 in Council Directive 98/83/EC of 3 November 1998 on the quality of water intended for human consumption, as amended by Regulation (EC) No 1882/2003 of the European Parliament and of the Council, and
2. snuff and chewing tobacco.

Whether that's the same thing as snus I'm not 100% sure - I actually had to google what 'snus' is  :rolleyes:

Looking at BRC clauses and I.G for both 4.8.6 and 4.8.7 I can see why the auditor referenced both - I can see an argument for both and neither. 4.8.7 (focuses on food) does mention in the I.G that it includes chewing gum), perhaps the closest resemblance of snuff? If you have a smoking area that is also a permitted eating area I guess this would be ideal to define the designated "snuf area" to ensure it isn't a risk to food production/storage.

I would agree with this being a non-conformity. Agreed that this should only be used in designated smoking areas.

The use of such a tobacco product / derivative presents a potential biological and chemical introduction hazard. I wouldn't even approach it from the food aspect because you don't ingest it (intentionally). I think more importantly, a by-product of using the snus is extra saliva production and, more importantly, the need to dispose of said saliva. I assume your GMPs prohibit spitting in production areas? I don't think you can do one without the other. All indications point toward no snus except areas you allow spitting / smoking.

I have the unfortunate experience of dealing with personnel in our facility using chewing tobacco and snuff.  As a former California resident I didn't have this problem.  But...apparently, it is quite common in the South.  Yay....

Our policy restricts it to designated smoking areas only, but in practice...it is quite different.  I've tried to enforce it and even to get more help from my boss (QA Director), but his response is "I cannot control other departments".  So...I just do what I can.  Good times!

Good luck enforcing it on your end.  Hopefully, you have the backing of upper management.

You may argue  whether or not snus is food.  However, you don't want to swallow it.

If you don't swallow it, you have to eventually spit it out.

Therefore it is an item that could cause contamination and should not be allowed in areas where you have contamination controls.