Personal Hygiene and Welfare: Long Pants?

Hi all, I recently moved as an SQF practitioner from food manufacturing to food packaging and have a question about clothing and personal effects (section 13.3.3). This section states:

 

 

The site shall have a clothing and hair policy that protects raw and packaging materials, work-in-progress, food sector packaging, and product contact surfaces from unintentional contamination.

Clothing worn by staff engaged in handling food sector packaging shall be maintained, stored, laundered, and worn so as not to present a contamination risk to products.

Clothing worn by staff engaged in manufacturing and warehouse processes shall be made from materials that will not contaminate raw and packaging materials, workin-progress, and food sector packaging. Clothing and shoes shall be clean at the commencement of each shift, maintained in a serviceable condition, and changed where they present a product contamination risk.

When protective clothing (e.g. frocks, smocks, aprons, boots, gloves, face shields, etc.) is used, hooks racks, cabinets, or other forms of off the floor storage shall be provided for temporary storage when staff leave the manufacturing area and shall be provided in close proximity or adjacent to the personnel access doors and handwashing stations. All clothing stored on-site shall be maintained and stored so as not to present a contamination risk to raw or packaging materials, work-in-progress, and food sector packaging.

Gloves used when handling food sector packaging material shall be clean and replaced when needed.

Jewelry and other loose objects shall not be worn or taken into any area where raw and packaging materials, work-in-progress, or food sector packaging is exposed. Wearing plain bands with no stones and medical alert bracelets that cannot be removed can be permitted; however, the site will need to consider their customer requirements and the applicable food legislation.

All exceptions shall meet regulatory and customer requirements and shall be subject to a risk assessment and evidence of ongoing risk management.

 

We are a paperboard manufacturer and the previous Quality Director had a requirement of long pants being worn. Supposedly, back in the day, the employees wore shorts and when the company became SQF this was updated but I'm failing to see where this is called out in the code, specifically. Any insight on this would be greatly appreciated! 

Hello Lulu,

The general consensus with SQF is that when the code doesn't specifically require something (for example in the code you listed Jewelry shall not...) that the risk be evaluated. If I were in your shoes I would:

• attempt to find a risk assessment that was done by the previous Quality Director which triggered his change to long pants
• If you find it, are the risks listed still valid? 
• If you don't find it, perform your own risk analysis (RA) and involve other members of your food safety team. Try to get as much scientific data as possible to support any decision you might be making.
  • I typically try to get everyone on the HACCP team involved, but I don't think that's a requirement. What you want to do is get several different sets of eyes/viewpoints on the risks to make sure you are covering your bases
• Document the risk analysis findings
• If RA consensus is that you SHOULD change anything, implement change (don't forget training if needed)

It is not specific, not intended to be - the code is guidelines only.

You woul want to do a risk analysis to determine if you could allow shorts, etc or have long pants.

We are a paperboard packaging manufacturer also. Our policy does not specifically state "no shorts", only that all clothing must be intact, no holes or ripped pants or cut-off pants. Our risk assessment states that all operations performed are performed above the waist and therefore any risk associated with shorts is negligible. Proper shoes are a safety requirement. Employees wear beard snoods (if applicable) and hair nets in high hygiene areas - AKA finishing where cartons are folded and glued and completely exposed, food surface side up.