9 replies to this topic

[RDM_Rep]

Hello, we are a food packaging manufacturer trying to obtain SQF certification. I am trying to write up a formal policy to satisfy 13.3.3 of Module 13 and I am looking for some help clarifying what is necessary for us in terms of protective clothing? Currently we only utilize hairnets and enforce a handwashing policy, would this be sufficient? I am seeing a lot of recommendations for jumpsuits and other alternatives, but I am wondering if this would be required for food packaging? 

[Evans X.]

Greetings RDM_rep,

 

If you don't use any form of protection then you risk physical/allergen cross-contamination being carried over to your client. Especially if you are producing eg cover films which are being placed in a packaging machine, you may find for example bread cramps rolled in it if your personnel wasn't thorough in cleaning its clothing after taking lunch. Not to mention other physical contaminants that can be carried over through clothes.

Maybe I wouldn't go as far as a full jumpsuit (depending on your product and how much involvement of the personel is required in the processes) but you should have some form of protective clothing that you will wear when entering/re-entering the production area.

If your production line is fully closed with limited to no contact, then you can be a little less strict, but you still need to set a few groundrules for overall personal hygiene when re-entering the production area.

[RDM_Rep]

Greetings RDM_rep,

 

If you don't use any form of protection then you risk physical/allergen cross-contamination being carried over to your client. Especially if you are producing eg cover films which are being placed in a packaging machine, you may find for example bread cramps rolled in it if your personnel wasn't thorough in cleaning its clothing after taking lunch. Not to mention other physical contaminants that can be carried over through clothes.

Maybe I wouldn't go as far as a full jumpsuit (depending on your product and how much involvement of the personel is required in the processes) but you should have some form of protective clothing that you will wear when entering/re-entering the production area.

If your production line is fully closed with limited to no contact, then you can be a little less strict, but you still need to set a few groundrules for overall personal hygiene when re-entering the production area.

 

Thank you for your response. Do you have any recommendations as to what to add to the required facemasks, hairnets, and handwashing? I am thinking perhaps disposable smocks or aprons would be good. To clarify, we do not work with any food on site, our work is entirely in plastic, and contact is relatively low. We supply food packaging and materials only. (I was asked to make this distinction clear by my employer). 

[Evans X.]

Since you mentioned that contact is realtively low I would not go for disposable protective clothing. My suggestion would be something like the simpler version of a doctor's white coat (the aprons -reusable ones- can work too, but I suggested the coats, cause they cover more body area). It's a one time buy, they are easy to clean (the material is not cloth exactly and it is liquid resistant), you can easily see when they are stained and best of all they are re-usable.

The only thing you should do for your management system afterwards would be to have a few instructions about taking them off near the exit of the production area when they take a break and wear them on again when they come back, as well as cleaning instructions like washing them seperately (if you don't wash them all together as a company) at a specific temperature and storing them in a plastic bag or some other clean material after that, so that it doesn't come in contact with anything else they have at home or carry with them when they get to work (dust, food etc). It's also something you can easily train your personnel and check if they abide by the instructions until it becomes a safety "habit".

In my experience with certified (ISO and FSSC) food packaging manufacturers, they never had a N/C raised for this practice by auditors, when following the above mentioned, but also I can't be 100% sure about your local SQF auditors. And of course this is on top of the hairnet/beardnet, facemask and handwashing!

Edited by Evans X., 12 March 2021 - 09:15 AM.

[epeabody]

Hello,

 

We are also a food packaging manufacturer in the USA, specializing in paperboard cartons (i.e. cereal boxes, etc). We have a full GMP program which includes hair nets, beard nets, no jewelry, no food or drink on the floor, closed toe shoes, no fake eyelashes, no nail polish or fake nails, no shirts with pockets, no pens on the floor that do not have a metal clip (so they are metal detectable), only use special blue band aids (contain metal strip), no facial piercings, hand washing, and no reporting to work if sick. We also require that any product that falls to the floor be discarded, the top and bottom sheets of each load must be discarded and we require all visitors to be trained and comly with all our GMPs. 

 

As for clothing, we allow our employees to wear their casual clothing items but require no loose fitting clothing, no hoodies with draw strings, no open sweaters, and no overly baggy pants. Our employees must wear tight fitting clothing and tuck in their shirts. 

 

we also require the use of gloves when coming into direct contact with the product. 

[RDM_Rep]

Since you mentioned that contact is realtively low I would not go for disposable protective clothing. My suggestion would be something like the simpler version of a doctor's white coat (the aprons -reusable ones- can work too, but I suggested the coats, cause they cover more body area). It's a one time buy, they are easy to clean (the material is not cloth exactly and it is liquid resistant), you can easily see when they are stained and best of all they are re-usable.

The only thing you should do for your management system afterwards would be to have a few instructions about taking them off near the exit of the production area when they take a break and wear them on again when they come back, as well as cleaning instructions like washing them seperately (if you don't wash them all together as a company) at a specific temperature and storing them in a plastic bag or some other clean material after that, so that it doesn't come in contact with anything else they have at home or carry with them when they get to work (dust, food etc). It's also something you can easily train your personnel and check if they abide by the instructions until it becomes a safety "habit".

In my experience with certified (ISO and FSSC) food packaging manufacturers, they never had a N/C raised for this practice by auditors, when following the above mentioned, but also I can't be 100% sure about your local SQF auditors. And of course this is on top of the hairnet/beardnet, facemask and handwashing!

 

Thank you so much for your input, this is incredibly helpful!

 

Hello,

 

We are also a food packaging manufacturer in the USA, specializing in paperboard cartons (i.e. cereal boxes, etc). We have a full GMP program which includes hair nets, beard nets, no jewelry, no food or drink on the floor, closed toe shoes, no fake eyelashes, no nail polish or fake nails, no shirts with pockets, no pens on the floor that do not have a metal clip (so they are metal detectable), only use special blue band aids (contain metal strip), no facial piercings, hand washing, and no reporting to work if sick. We also require that any product that falls to the floor be discarded, the top and bottom sheets of each load must be discarded and we require all visitors to be trained and comly with all our GMPs. 

 

As for clothing, we allow our employees to wear their casual clothing items but require no loose fitting clothing, no hoodies with draw strings, no open sweaters, and no overly baggy pants. Our employees must wear tight fitting clothing and tuck in their shirts. 

 

we also require the use of gloves when coming into direct contact with the product. 

 

Our policy is essentially the same as what you mentioned, in your experience, can you advise if it has it been sufficient to obtain SQF certification? I can already feel the pushback if I try to suggest white coats (though it does sound solid!). 

[queenb]

We are a label manufacturer operating under SQF and our policy also specifies hair nets, beard nets, no jewelry, no food or drink on the floor, closed toe shoes, no fake eyelashes, no nail polish or fake nails, no facial piercings, and no reporting to work if sick.  Our initial pre-operational sanitization includes hairnets, beard nets or balaclava, hand washing, rubber gloves and a disposable smock (these are knee length) when working on the production line of food contact labels. All these pre-operational sanitizations are monitored and recorded by another employee.

[Hoosiersmoker]

Food Contact paperboard packaging manufacturer here too. Hair nets, beard snoods, nails, eyelashes, no piercing, illness policy etc... We supply 6 t-shirts to all employees on their first day. They must wear a company issued shirt every day. We allow a plain, solid colored sweatshirt in cooler weather if they have not received one from the company. No restrictions on pants as all operations occur below the waist or are in totally enclosed machines. Has been looked at by auditors for several years with no issues. Allergen control reduces the risk of any potential contamination.

[RDM_Rep]

Thank you all for the responses. Per the recommendation of a consultant, we have moved forward with disposable plastic aprons in addition to the hairnets we had already required. The problem I'm now encountering is how this applied to visitors - for example, does our pest control guy need to wear the apron as well? Do the office employees need to as well if they need to go into production for whatever reason?
 

The idea behind the apron is in case employees pick up material (large rolls/boxes) we can avoid any contamination from any food particles that might be on their clothes. My thinking is a risk assessment would be sufficient to avoid this requirement for anyone not working in production/making actual contact with product as our policies will also prohibit visitors/office employees from doing so. At the same time, for the sake of consistency, I think it makes sense to require anyone that enters production to wear the apron. Any thoughts? 

[TaraMcKinzie]

I would define in your SOP that anyone that enters production follow the same procedures, for uniformity as well as I have dealt with some front office staff that would bend the rules if they could get away with it so I made it the same rules for everyone so I didn't have to hear "but so and so doesn't wear that" and so forth.  Just be clear in the SOP what your expectations are and train train train.

 

Thank you all for the responses. Per the recommendation of a consultant, we have moved forward with disposable plastic aprons in addition to the hairnets we had already required. The problem I'm now encountering is how this applied to visitors - for example, does our pest control guy need to wear the apron as well? Do the office employees need to as well if they need to go into production for whatever reason?
 

The idea behind the apron is in case employees pick up material (large rolls/boxes) we can avoid any contamination from any food particles that might be on their clothes. My thinking is a risk assessment would be sufficient to avoid this requirement for anyone not working in production/making actual contact with product as our policies will also prohibit visitors/office employees from doing so. At the same time, for the sake of consistency, I think it makes sense to require anyone that enters production to wear the apron. Any thoughts?