Jewelry revision to GMP's
Upper management wants me to figure out a way to amend our jewelry policy to include necklaces worn under their clothing, post/stud earrings and post/stud nose rings/facial pricings, and nail polish on nails. Currently our GMP policy prohibits all of those activities as we are SQF certified and operate under USDA and FDA regulations. Is this a matter of a risk assessment and revision to the SOP and how do I verify and validate cleanliness and jewelry isn't broken or damaged at the end of a shift. Would this even be acceptable regulatory wise?
Thank you,
K. Jordan
FDA says nope
The plant management shall take all reasonable measures and precautions to ensure the following:
(4) Removing all unsecured jewelry and other objects that might fall into food, equipment, or containers, and removing hand jewelry that cannot be adequately sanitized during periods in which food is manipulated by hand. If such hand jewelry cannot be removed, it may be covered by material which can be maintained in an intact, clean, and sanitary condition and which effectively protects against the contamination by these objects of the food, food-contact surfaces, or food-packaging materials.
Ditto USDA
https://www.ams.usda...anitationHB.pdf
b. Clothing and Personal Equipment. All persons handling commodities, ingredients, or their contact surfaces must wear clean outer garments. All persons must wear caps, hats, hairnets, or other effective hair restraints (including facial hair restraints) where exposed product is handled to prevent hair from falling into product. All loose or insecure jewelry, such as rings, wrist watches, etc., that might serve as a source of product contamination during work periods in which food or food components are manipulated by hand must be removed. Plastic or rubber gloves should be worn by all personnel who touch or manipulate processed food products by hand. If gloves are used in food handling, they should be maintained in a clean and sanitary condition. Such gloves should be of an impermeable material except where their usage would be inappropriate or incompatible with the work involved
https://www.fsis.usd...ompliance-guide
ngernails
2-302.11 Maintenance.
- Food employees shall keep their fingernails trimmed, filed, and maintained so the edges and surfaces are cleanable and not rough.
- Unless wearing intact gloves in good repair, a food employee may not wear fingernail polish or artificial fingernails when working with exposed food.
Jewelry
2-303.11 Prohibition.
While preparing food, food employees may not wear jewelry on their arms and hands. This section does not apply to a plain ring such as a wedding band.
Unless your product is one where the outside is NOT considered food, I think your senior management is pushing the boundaries significantly on this one
I did bring up the USDA guidance to management in which they replied " we do not handle exposed food". It is true we do not handle exposed food but it is food none the less and we still have to meet regulatory standards. For some background we are a High Pressure Processing tolling station. All food is packaged, intact and never exposed which puts us at a very low risk for contamination.
Scampi is right on this. The policy dictates, they are overstepping big time.
Cheers!
I agree with the others. It's policy that must be followed.
That said, I DID find a regulation (FDA, I THINK) recently that if jewelry can be covered it's allowable.
I have diamonds in my wedding ring and it will NOT come off, we've tried everything. I tell any auditor/inspector that comes to the plant, that it won't come off and as soon as we step foot into the production area, I put a glove on. So far, they have all be fine with that.
Anything else, earrings, nose rings, necklace, bracelet, watch, fake nails, or nail polish, are all prohibited. Except medical alert necklace/bracelet.
I agree with the others. It's policy that must be followed.
That said, I DID find a regulation (FDA, I THINK) recently that if jewelry can be covered it's allowable.
I have diamonds in my wedding ring and it will NOT come off, we've tried everything. I tell any auditor/inspector that comes to the plant, that it won't come off and as soon as we step foot into the production area, I put a glove on. So far, they have all be fine with that.
Anything else, earrings, nose rings, necklace, bracelet, watch, fake nails, or nail polish, are all prohibited. Except medical alert necklace/bracelet.
I had to have ring cut off once. lol.
The horror stories around ring cuttings. I saw one finger get lost and I forevermore have worn a silicone band.
yuck.
WHY does upper management want this changs?
I agree with all above, this is a no go and a bad idea.
I have a personal ring story back when I was a boat mechanic. It was always taboo to wear a ring around engines/motors because they can get caught on something and rip your finger off. I did not listen, and had on a titanium ring. I was working on a large outboard motor and had it trimmed up. The trim broke, and the motor fell creating a scissor effect right where my hand was. The dang ring took it like a champ, and had I NOT had that ring on, I'd be shy a finger right now. Still, I never wear rings now.
Got lucky tho....
WHY does upper management want this changs?
I am curious on this as well. Why are they asking for there to be changes in the first place?
Cheers!
They asked me to see if the change could be made because we have a few employees with facial jewelry and piercings that repeatedly leave them in on the floor. It was said to me this is "a sign of the times" and we should adjust with the trends of today. Basically, changing the policy would allow these team members to keep their piercings in without a GMP violation. Again, we are low risk for cross contamination or foreign material because we only handle packaged product.
They are going for "hearts and minds" which is positive. The downside is that if you contradict the standard then you are in violation. USDA will not budge on this (you could always send an email to ASKFSIS). I would let management know that the food safety program trump's keeping up with the times. USDA does not specifically mention anything about face jewelry but it is safe to say that if it poses the risk of falling into food then it should not be permitted.
Cheers!
Keeping up with the times? Uh, ok. I'm also worried about keeping up with the times in our facility. Not the fashion times, the food safety times. We all know this stuff is getting tighter and tighter. (Honestly I hope to be out of this business before the squeeze gets to be too much to bear.) This seems to be a case of the 'lunatics running the asylum'. If your current rule is no jewelry and they're wearing jewelry, send them to their locker to remove it before they're allowed back on the floor. Tell them they're not clocked in until they're ready to work, which includes removing said jewelry. But I personally wouldn't move the goalposts on it...
Thank you everyone. I think I already went into it knowing it would be a hard sell from a regulatory standpoint. Appreciate all the input.
So management wants this, thinking you will retain more employees with a piercing-friendly mindset...? Paraphrasing, greatly, I know, but here's the thing.
IME, people who have facial piercings have either had them a long while and then, most are then removable for a work shift or they are brand new and we then ask that they cover them with a metal detectable band aid until they heal enough for daily removal. This has satisfied the USDA and SQF auditor, so far..
No problem,
You came to the right place if you wanted to find people that would stand in your corner and choose food safety over people's feelings and corporate redirection :shades:
Cheers!
Keeping up with the times? Uh, ok. I'm also worried about keeping up with the times in our facility. Not the fashion times, the food safety times.
I LOL'ed about this :roflmao:
It sounds like a knee-jerk linked to the drying up of the labor pool. If you relax your rules on potential food safety risks for a blip be it "fashion" or sign of the times or labor shortages it will make it much more difficult in the future to regain the control you lose now. The requirements, especially GMPs, are not likely to slacken but the opposite. In a very professional manner just tell the owners to get a spine and enforce the rules. We don't even allow visitors to wear earrings, watches or rings when they visit our production areas and we're a packaging manufacturer. We've had several new employees come in claiming they can't remove their piercing(s) and I respond that there are many companies that allow piercings but this is not one of them, if they want to stay and work they'll find a way to comply. It's a rule, not an opinion.
This thread was from a few years ago and Charles mentions one that was done even earlier. Hope it helps. If nothing else it is good reading.
Cheers!
Upper management wants me to figure out a way to amend our jewelry policy to include necklaces worn under their clothing, post/stud earrings and post/stud nose rings/facial pricings, and nail polish on nails. Currently our GMP policy prohibits all of those activities as we are SQF certified and operate under USDA and FDA regulations. Is this a matter of a risk assessment and revision to the SOP and how do I verify and validate cleanliness and jewelry isn't broken or damaged at the end of a shift. Would this even be acceptable regulatory wise?
Thank you,
K. Jordan
Hello,
Wondering what type of Food Facility you are in? I am going up against the same thing. We are a produce dry packing house, packing whole watermelons and pumpkins. We also have a processing dept on site that does juice. Ownership would like me to let some GMPs pass for the packing house, they feel that its not applicable considering our operation. I do understand its a watermelon. However, we still have guidelines and regulations to follow, we are GFSI Certified. This seems to be a never ending up hill battle with trying to enforce GMPs and to gain the backing of ownership.
For the sake of discussion: I once ran QA for a third party toller where we had our processing area completely separate from our storage area (separate warehouse suites with a proper rollup door connecting the two). At that time, I was able to defend having a more lax GMP policy in our storage area: warehouse manager was our only lift operator in the storage area, and he was not required to wear standard outerwear nor wash his hands unless he entered the processing area. The primary factor in SQF accepting this was that no product was ever permitted to be opened in the storage areas (no sampling, no nothing). Storage area was also included in our sanitation and EM programs, and had a solid history of no concerning hits.
I'm not sure what a "High Pressure Processing tolling station" is, but if OP's company is not directly processing exposed food, what's the difference between them and say a LTL shipper moving pallets of product?