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Is sunscreen considered makeup?

Makeup Sunscreen

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ft.tgif

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Posted 20 August 2021 - 01:26 PM

We just had our FSSC 22000 surveillance audit today and got an NC because one of our workers had eyeliner on. The NC was issued based on ISO/TS 22002: 2009 clause 13.8 personal behavior.

I know makeup is kind of a grey area since it’s not explicitly stated in the ISO/TS requirement that makeup is totally banned, and some production plants allow “light” or “neutral” makeup. However when I asked the auditor whether foundation is allowed since I would consider it as light makeup as long as it’s not a thick layer, she said it might still fall into the products. I understand this and however I’ve read the forum regarding makeup issues and many of you claimed that it is not that high of a risk. Some of you would support the total ban of wearing makeup in production area to be safe, and I agree with this.

However, one thing that concerns me the most is would facial sunscreen be considered as makeup? Would it be allowed if we were to ban makeup in our production facility? By facial sunscreen, I would refer to liquid sunscreen and not foundation powder with SPF or powdered sunscreen as it would still be considered as something similar to foundation powder, however liquid sunscreen, provided that it is not flaking or piling, and given that sunscreen is basically for cancer prevention, I feel like sunscreen should be allowed, rather than foundation powder, provided that it is not piling or flaking and this can be easily achieved with chemical, non-mineral (titanium dioxide or zinc oxide) sunscreens, and not layering your sunscreen with other cosmetic products.

Yes I understand that there will be no sunlight in the production facility, however I live in a tropical country with strong sunlight and high UV index all year long, and commuting to work daily would still expose us to high UV radiations as many people travel by motorcycles here. If I ban sunscreens too, would I violate any laws or employee safety rules?



olenazh

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Posted 20 August 2021 - 01:36 PM

Wow, that's rough! Never heard of this kind of comments before: jewelry, nail polish, false fingernails - yes, that's understandable, it's food safety risk, but eyeliner... How could it possible FALL IN THE PRODUCT? Or, I don't understand what eyeliner is? 



kfromNE

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Posted 20 August 2021 - 06:15 PM

I agree with olenazh - I don't think eyeliner is a risk. Nor do I think you should ban makeup/sunscreen. The auditor was being picky. Dry skin can flake. Also sunburn skin because an employee didn't have sunscreen on.



ft.tgif

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Posted 21 August 2021 - 01:53 PM

I agree with olenazh - I don't think eyeliner is a risk. Nor do I think you should ban makeup/sunscreen. The auditor was being picky. Dry skin can flake. Also sunburn skin because an employee didn't have sunscreen on.

yes i agree too that the auditor was being very picky on this. It was not stated in the ISO/TS standard that makeup is not allowed, however she kept saying that it was an industry norm. I know of course it's best to just do away with the makeup entirely, however i did not have the opportunity to refer to my ISO/TS standard during the audit to defend our stance on this matter as i was the only person handling the entire audit. Management has also agreed to just ban makeup altogether but i don't think we will explicitly state that sunscreen is also banned in our food safety rules. 



Vladimir Surcinski

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Posted 21 August 2021 - 08:36 PM

One option is to ban it completely, and to state that in the food safety rules. This is the easiest thing to do.

 

Second, you can perform risk analysis (for example use FMEA tool, or any other) and present in the analysis (as part of PRP) is there really risk in this case. In case that there is no calculated risk, you can use the makeup and that is it. 

 

From my experience, as an auditor, if company says to me there is no risk for the products, I would expect from them that they show me some logical risk analysis and to defend their opinion. If they show that there is no risk, I would say OK.  

 

On the other way, this is probably recorded as Minor NC, since there is no direct impact on the FSMS



ft.tgif

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Posted 22 August 2021 - 02:00 AM

One option is to ban it completely, and to state that in the food safety rules. This is the easiest thing to do.

 

Second, you can perform risk analysis (for example use FMEA tool, or any other) and present in the analysis (as part of PRP) is there really risk in this case. In case that there is no calculated risk, you can use the makeup and that is it. 

 

From my experience, as an auditor, if company says to me there is no risk for the products, I would expect from them that they show me some logical risk analysis and to defend their opinion. If they show that there is no risk, I would say OK.  

 

On the other way, this is probably recorded as Minor NC, since there is no direct impact on the FSMS

Yes, we got issued a minor NC for this. If we were to do a risk analysis particularly for this issue, do we have to document it? Do we have to come up with an official risk analysis form for any kind of risk analysis in the future for other issues or materials? So far we have a hazard analysis worksheet for our HACCP plan, supplier vulnerability assessment and material vulnerability assessment for food fraud mitigation, and also threat assessment for food defense. 

 

Sorry i am still new to this, and i'm the only one in charge of all these stuff in my company as it is a small enterprise, there's basically only 3 office workers including myself and i have no one to guide me on this matter. 



Charles.C

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Posted 22 August 2021 - 05:37 AM

Yes, we got issued a minor NC for this. If we were to do a risk analysis particularly for this issue, do we have to document it? Do we have to come up with an official risk analysis form for any kind of risk analysis in the future for other issues or materials? So far we have a hazard analysis worksheet for our HACCP plan, supplier vulnerability assessment and material vulnerability assessment for food fraud mitigation, and also threat assessment for food defense. 

 

Sorry i am still new to this, and i'm the only one in charge of all these stuff in my company as it is a small enterprise, there's basically only 3 office workers including myself and i have no one to guide me on this matter. 

 

I assume that the minor NC had no significant impact on the overall result of the audit.

 

Sometimes it's not worth splitting hairs with auditors. I suggest that you simply go with the first line of post 5/last line post 4 and reserve the time saved for other issues.


Kind Regards,

 

Charles.C


ft.tgif

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Posted 22 August 2021 - 05:53 AM

I assume that the minor NC had no significant impact on the overall result of the audit.

 

Sometimes it's not worth splitting hairs with auditors. I suggest that you simply go with the first line of post 5/last line post 4 and reserve the time saved for other issues.

Yea, that is what we're most likely to go with, we do not want to find fault with the auditor as well. 



samjhand

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Posted 23 August 2021 - 07:06 PM

 This is definitely one picky auditor.  Never heard of eye liner falling into the food product.

 I have had  irrelevant minor non conformance issued by my HACCP auditor couple of times. Some auditor are very  specific and only accept the way they are used to. I always try to  explain the auditor but avoid argument in general. However, I have contested about such minor NC's when completing the corrective action report. The technical reviewer above the auditor has fortunately dismissed  those NC's for me.

 

In your case, I would do a risk analysis but would not change the company policy as no makeup as it is definitely not a standard industry practice and there no such history of evidence.


Edited by samjhand, 23 August 2021 - 07:07 PM.





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