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Risk Assess to NOT wear hair nets - after wearing them for years?

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Posted 30 June 2020 - 07:28 AM

Morning everyone, 


A question that has been on the sites mind for around a year now. 


We wear hair nets. 


An egg packing site, low risk, enclosed product, no CCP's.


The site used to wear caps a few years before i started, but i reckon for about 4 years we've been wearing hair nets. 


The question that keeps coming up is, can we go back to wearing caps? 


I've been told that potentially yes we can as long as we have a solid risk assessment, however i find it hard to see that an auditor would accept this, as we have obviously risk assessed at some point to say we need to wear hair nets.


How easy is it to go back on this?


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Posted 30 June 2020 - 08:01 AM

Any particular certification standard involved?
BRC seems to be somewhat flexible on this, subject to the requirement noted in the IG that "headwear such as mob hats or hairnets must ensure that head hair is completely covered to minimise potential contamination".

The IG also states that the requirement to wear full company-issued protective clothing "would not be absolute" for fully enclosed/low risk etc, (See IG section on 7.4.1).  

I don't think it's at all unreasonable to revise a risk assessment from time to time, and thus one may reasonably reach a different conclusion in some cases. Can you locate a copy of the previous risk assessment to better understand the basis for the original decision?


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Posted 30 June 2020 - 09:55 AM

Not Primus by any chance ?


The Issue for them has occurred several times due their rigorousness.


Product ??


Same kind of query in a parallel thread for a different reason - supplier of hairnets has no stock so what to do ?

Kind Regards,




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Posted 30 June 2020 - 12:01 PM

So I'm guessing you're saying the egg shell protects the product?  


Ask yourself, would a consumer complain if there was a hair inside the egg box?  If "yes", just wear mob caps or nets and be done with it...

Cathy Gladwin

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Posted 30 June 2020 - 12:24 PM

Risk assessment is generally a great idea however, as with any standard, there are clauses that are a definite requirement. I'm a BRCGS Lead Auditor and I've had to raise this NC for a packing operation on a field rig where they were wearing caps. The guys harvesting had no rules to worry about and the guys on the field rig had to fully comply with the standard. They were all wearing caps but which did not fully enclose all hair. They'd been doing so for many years but due diligence... I had to raise the NC. I encouraged them to appeal the NC but it was upheld by the certification body. Where there's implied wriggle room in the clause and you want to apply common sense, I say go for it with a risk assessment but otherwise just go with the clause. I personally worry that hair nets aren't even recyclable and the numbers we go through in the food industry must be staggering.



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Posted 30 June 2020 - 02:10 PM

I'd take a strand of hair on on my egg anyday vs. a spot or two of chicken poop.

Kind regards,
Glenn Oster

Goodstart Coastal Enterprises, PMA | Business Development & SQF Development, Implementation & Certification Consultant - 772.646.4115



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