Production Personnel Wearing Finger Nail Polish and Gloves

Hello, I am the QA Manager of a Dietary Supplement manufacturing co and I am wondering if there is any issue with production personnel wearing finger nail polish, not fake nails, as long as intact gloves are worn during the processes?  I am not seeing anything in SQF stating this is prohibited.

Yes, that is fine.

I would create a risk assessment to support this decision in an audit.   :smile:

It's in our GMP's Procedure that they can have fingernail polish as long as they wear gloves.  What I want to know is if anyone is having a problem getting gloves?  We only can let our employees that come in contact with raw product and ingredients wear gloves because of the shortage.  Employees that touch bagged product are not wearing gloves. I had to tell my employees no nail polish until gloves are readily available again and not 70cents a pair.  What can I do? A risk assessment, or update covid policy and procedure? or both?

Hello, I am the QA Manager of a Dietary Supplement manufacturing co and I am wondering if there is any issue with production personnel wearing finger nail polish, not fake nails, as long as intact gloves are worn during the processes?  I am not seeing anything in SQF stating this is prohibited.

Hi Sarah,

It may relate to where you are.

Googling demonstrates a variety of opinions with degree of tolerance  perhaps linked to food occupation but IMO majority for manufacturing negative. eg Canada -

 

• All persons wash and sanitize their hands upon entering food handling areas, before starting work, after handling contaminated materials (e.g. picking objects off the floor, handling garbage, cleaning chemicals or raw incoming materials), after breaks, after using toilet facilities or after blowing their nose and whenever there is a risk of contamination of the products. Fingernails are kept clean without nail polish.
• Disposable gloves are changed whenever contamination is a possibility.

 

https://inspection.c...14870197?chap=9

 

Nonetheless, for retail USA, food code has -
 

(B) Unless wearing intact gloves in good repair, a FOOD EMPLOYEE may not wear fingernail polish or artificial fingernails when working with exposed FOOD.

(one can predict where arguments may arise in above statement)

Can browse this SQF packaging thread  -

https://www.ifsqn.co...ant/#entry88204

The simplest solution (ie minimize argumentation) is presumably to ban it, eg -

All food handlers must be trained to wash their hands thoroughly. Hand-washing should take about 30 seconds of continuous lathering and should include fingertips, nail beds and forearms. Anyone handling food must keep their fingernails short and clean as long nails collect bits of food and bacteria.

You and your staff must not wear nail varnish.

False nails of any sort are not allowed.

Any wounds, scratches or grazes must be covered with a clean, brightly coloured (blue) waterproof dressing.

https://www.bromley....260991/13/756/d

At the companies I have worked at nail polish is never tolerated. Gloves tear easily and I do not want the risk of (chipped) nailpolish sticking through a ripped glove.
If there is a temp worker who shows up with minor infractions (nail polish, fake lashes, piercings) I will allow them in the low care packaging facility if they use thick gloves to cover the hands (and band aids over the piercings). But day two they should be completely complient.

We currently ban nail polish use in our facility, though hands are always gloved, polish (especially when worn or chipped) is notorious for bacterial harborage.

I am glad to see others pop in saying that they ban nail polish as well.  I was feeling a bit like Negative Nelly.  I don't like polish in food facilities.  In this situation, it is too easy for this to become a slippery slope.  Nail polish, fake nails, jewelry...where does it stop?

Gloves tear. 

Nail polish chips. 

People don't always remove gloves over garbage receptacles.

It is much easier to not allow nail polish at all than to find wiggle room for potential contamination to occur.   

Just to chime in, we do ban nail polish for workers in production here in our GMP's. It was a decision made prior to me coming on board, and it's one I don't think they actually reviewed the risk for. 

However, it's been a non-issue, as all of our production/maint staff have been of the male gender who do not paint their nails.

This is a nuisance for me because we have nail polish banned and about 60% of our workforce is female.  They wear glove to cover any nail polish which is against our GMP's and I HATE, HATE, HATE glove use because it leads to so many other bad habits....poor handwashing, torn gloves and pieces, gloves not handled properly.  Aside from asking employees to remove their gloves to check I don't know what we can do.

Ryan, I had a similar issue with fitbits/watches here. People would notice when I was going to walk through and they'd either take them off real fast and toss them in a pocket, or they'd have a sweat band on their wrist. I recruited the individual responsible for HR here at the plant to walk through once a month and do a focused GMP inspection on the actual employee/temps. She asks them to pull aside long shirts sleeves or pull aside their wrist bands to show wrists, drop hoodies or ear coverings for earbuds, and show their necks for chains.

I was always kind of sensitive around this one because HR laws are kind of touchy, so I had HR do it for me.

I dealt with employees wearing fingernail polish and finally had to do a risk assessment. I would rather us have it banned but gave up on it. It is allowed now. The only reason I do allow it is because I work in a cold environment (average room is 40 F) so employees wear reusable cloth gloves then the disposable gloves. The risk then becomes low because anything chipping will be caught by the cloth glove. Fake nails not allowed.

Thank Tim. I'll consider this and see if that's an option for us.  We are a very "pro people" company to a fault honestly.  It makes it difficult for us to enforce and police the operational and quality/food safety policies we need to.  It really has led to our current environment where there's a lack of continued enforcement of policy and old / bad habits seem to recur over and over again.  Aye...anyhow.  Appreciate the suggestion.

Ryan, I had a similar issue with fitbits/watches here. People would notice when I was going to walk through and they'd either take them off real fast and toss them in a pocket, or they'd have a sweat band on their wrist. I recruited the individual responsible for HR here at the plant to walk through once a month and do a focused GMP inspection on the actual employee/temps. She asks them to pull aside long shirts sleeves or pull aside their wrist bands to show wrists, drop hoodies or ear coverings for earbuds, and show their necks for chains.

I was always kind of sensitive around this one because HR laws are kind of touchy, so I had HR do it for me.

Hello,

Is anyone able to send me risk assessment template. My management wants to have nail paint and fake nail. They don't want to lose employees. 

Thank you, 

If wearing the gloves then no issue. But why to use nail polish at all. They are coming to work in a food factory not in a fashion industry. Isn't it?

I agree, but they want to allow nail polish and fake nails. 

I agree, but they want to allow nail polish and fake nails. 

If you're an SQF facility (assuming because you're asking in the SQF subforum), these employees cannot perform any task handling exposed food per SQF.  Code 11.4.1.2 states: ii. The wearing of false fingernails, false eyelashes, eyelash extensions, long nails, or fingernail polish is not permitted when handling exposed food.

Federal law applies here for anyone handling the food or even the packaging.  CFR 21 Chap 1B Subpart A 110.10 states:

(b) Cleanliness. All persons working in direct contact with food, food-contact surfaces, and food-packaging materials shall conform to hygienic practices while on duty to the extent necessary to protect against contamination of food. The methods for maintaining cleanliness include, but are not limited to:

(9) Taking any other necessary precautions to protect against contamination of food, food-contact surfaces, or food-packaging materials with microorganisms or foreign substances including, but not limited to, perspiration, hair, cosmetics, tobacco, chemicals, and medicines applied to the skin.

First, I would ask your management team to provide you an detailed plan to deal with customer complaints of finding nail polish and nails in their product.

I know I refuse to drink Kool-aid ever again, after finding a finger nail in the powdered juice mix almost 20 years ago. Not worth the risk of brand trust being lost with customers.