8 replies to this topic

[Fred73]

We pack an ingredient with a very low aw here and the current gmp rules in the production area state long sleeve t-shirts, hair cover, beard nets, etc. but now with the summer arriving the production area turn really warm, and employees complaint about wearing long sleeve shirts, so I am thinking if it is worth to reevaluate the risk involve during the production since there are only 1 or 2 instances were the product could become open to the environment , otherwise a big sack is open only over a machine and at the other end a bagger machine fill the bags and sealed, then it is only handling of packaging material. Does anyone got the same issue, does anyone has evaluate what is the best fabric for shirts in a production area like this? thanks.

[Charles.C]

We pack an ingredient with a very low aw here and the current gmp rules in the production area state long sleeve t-shirts, hair cover, beard nets, etc. but now with the summer arriving the production area turn really warm, and employees complaint about wearing long sleeve shirts, so I am thinking if it is worth to reevaluate the risk involve during the production since there are only 1 or 2 instances were the product could become open to the environment , otherwise a big sack is open only over a machine and at the other end a bagger machine fill the bags and sealed, then it is only handling of packaging material. Does anyone got the same issue, does anyone has evaluate what is the best fabric for shirts in a production area like this? thanks.

^^^^^^red

 

Based on previous analogous threads and perhaps depending on the product(??) almost anything has been known, including short sleeve t-shirts (didn't know a long one existed).

[TimG]

Good morning Fred. Like Charles mentioned, there have been some very similar threads on this and the results are extremely varied. Knowing what an auditor will look for, some steps I would take if I were you:

• Document a risk analysis and include feedback from your HACCP team (be sure to get feedback from your safety manager, there could be safety implications to this rule)
• If a decision is made to allow short sleeve shirts, RE-TRAIN your team and document this. (This doesn't have to be a complete re-training, obviously. But conveying to the team what rule has changed, why, and what it means for them)
• Make sure you update any GMP or other docs where the old rule needs to be removed or changed (be sure new versions are created and your DMS system is updated accordingly)

Off hand I think that about covers it. Of course your FS system might have different guidelines in addition to these that you need to follow for changes to GMP rules, but these are going to be some things an auditor will check for.

Edited by TimG, 08 June 2020 - 01:47 PM.

[Padfoot]

We are currently in the process of deciding whether we will allow employees to use shorts or capri pants in the production floor... we currently cover all clothing with smocks up to the knees. 

 

TimG I have a current hazard analysis on smocks should i just add a section on that same hazard analysis on under garments? 

[SQFconsultant]

You'd need to do a risk analysis to determine if the what if's are super low or nil.

 

I'd first however be looking at my ventilation system - because an Auditor might take the short sleave shirts, but may focus on the underlying issue first and foremost.

[TimG]

We are currently in the process of deciding whether we will allow employees to use shorts or capri pants in the production floor... we currently cover all clothing with smocks up to the knees. 

 

TimG I have a current hazard analysis on smocks should i just add a section on that same hazard analysis on under garments? 

As long as you reference the new date where you did the newer hazard analysis. You can either do that in a revision description at the end if it's controlled in DMS, simply reference it in the body of the analysis focusing on undergarments, or add it in as a dated addendum. It really depends on how your smock hazard analysis is laid out.

The thing you're trying to make sure is you document the most recent analysis date, while still keeping track of the previous hazard analysis date. This lets the auditor follow up on making sure proper training/communication and accountability was observed. For example, they could question Joe on the floor and he could say "well we didn't used to be able to wear shorts, but startin last July they let us" and you want to be able to back that up.

[Padfoot]

As long as you reference the new date where you did the newer hazard analysis. You can either do that in a revision description at the end if it's controlled in DMS, simply reference it in the body of the analysis focusing on undergarments, or add it in as a dated addendum. It really depends on how your smock hazard analysis is laid out.

The thing you're trying to make sure is you document the most recent analysis date, while still keeping track of the previous hazard analysis date. This lets the auditor follow up on making sure proper training/communication and accountability was observed. For example, they could question Joe on the floor and he could say "well we didn't used to be able to wear shorts, but startin last July they let us" and you want to be able to back that up.

That makes sense! thank you 

[kfromNE]

For fabrics - I googled breathable fabrics for summer and this is what I found. You can recommend staff to wear these type.

 

https://www.rei.com/...athable-fabrics

[Juribe]

If I were in your position I would likely change my focus from the employees sleeves to the ventilation system of the facility. If there is ample ventilation the employees should not be overheating.