GMP Issues - False Eyelashes, Nails, Piercings, etc.
Hi all,
Since our last SQF audit we've had increasing difficulty with retaining employees and enforcing basic policies like attendance and dress code. It's reached a point where our HR person doesn't abide by the GMP policy that we all agree to as employees. She conducts a new hire orientation weekly while wearing fake eyelashes, fake nails, and jewelry. Employees are noticing inconsistent enforcement of our policies.
A while back our food packaging facility wrote our GMP policy based in part on SQF Edition 8 - Module 13 guidance documents. Guidance for 13.3.4 specifically stated:
"Personnel.... should not be permitted to wear false fingernails, false eyelashes, eyelash extensions, long nails, or fingernail polish."
We now have employees (and supervisors!) pushing back against the GMP policies by wearing these items as well as body piercings.
So, not only do we now have high turnover causing hesitation to enforce GMP's, but Edition 9 guidance documents seem to have dropped the wording referring to fake lashes, nails, etc.
I'm wondering if there is still any reference to these items in the Edition 9 guidance documents?
Hi all,
Since our last SQF audit we've had increasing difficulty with retaining employees and enforcing basic policies like attendance and dress code. It's reached a point where our HR person doesn't abide by the GMP policy that we all agree to as employees. She conducts a new hire orientation weekly while wearing fake eyelashes, fake nails, and jewelry. Employees are noticing inconsistent enforcement of our policies.
A while back our food packaging facility wrote our GMP policy based in part on SQF Edition 8 - Module 13 guidance documents. Guidance for 13.3.4 specifically stated:
"Personnel.... should not be permitted to wear false fingernails, false eyelashes, eyelash extensions, long nails, or fingernail polish."
We now have employees (and supervisors!) pushing back against the GMP policies by wearing these items as well as body piercings.
So, not only do we now have high turnover causing hesitation to enforce GMP's, but Edition 9 guidance documents seem to have dropped the wording referring to fake lashes, nails, etc.
I'm wondering if there is still any reference to these items in the Edition 9 guidance documents?
Food Packaging Code -
13.3.3.6 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.
SQF Food Code(s) 8.1 included nails etc in its CODEs. SQF Packaging Code 8.1 copied the SQF Food Codes's Nails etc text into its Guidance document (not the CODEs).
SQF 9 (Food/Packaging) Codes followed 8.1 Codes for their material hence the revised Packaging Code lost the "Nails etc" Clause. The SQF 9 Guidance materials (shared for Food/Packaging) seem to not discuss basic GMP/hygiene topics.
PS - The SQF 9 amendments attached in post linked below seem not related to present thread query -
https://www.ifsqn.co...ts/#entry178471
PPS - Note that, inter alia, the Food (and presumably Packaging) Guidance Material is not auditable or necessarily definitive (see Guidance Info Sheet linked on webpage).
PS3 - Regardless of above, I doubt that SQF auditors will complain if you choose to include the requirements detailed in Packaging Guidance version 8.1 in your overall GMP Policy. IIRC all these items have been (Food) discussed in previous threads here with (mostly) positive affirmations.
The guidance document is important. I see the senior management commitment to food safety is more vital. They need to walk the talk to start with which enables GMP to be policed easier.
I have a similar experience lately which the supervisor commented that they were unable to hire staff due to ongoing staffing issue. One of his staff has fake eyelashes and he needed this staff for operations desperately. My answer was yes she can if she wears safety goggles in production areas.
On another occasion, a casual came with nail polish. We always have a bottle nail polish remover for emergency use like this one. They will not have any excuses to have nail polish in production.
These basic GMP are non-negotiable. The production manager learns quickly if he/she has to stop production once.
The guidance document is important. I see the senior management commitment to food safety is more vital. They need to walk the talk to start with which enables GMP to be policed easier.
I have a similar experience lately which the supervisor commented that they were unable to hire staff due to ongoing staffing issue. One of his staff has fake eyelashes and he needed this staff for operations desperately. My answer was yes she can if she wears safety goggles in production areas.
On another occasion, a casual came with nail polish. We always have a bottle nail polish remover for emergency use like this one. They will not have any excuses to have nail polish in production.
These basic GMP are non-negotiable. The production manager learns quickly if he/she has to stop production once.
Hi Aliali,
Thanks but where is the reference to fingernails etc in current SQF 9 Packaging Guidance Documentation ??
Should is a passive word, must have an action and should is we might or might not kind of word.
Personnel are not alloed to have...
The following specific and like items are not allowed in our facility.
Youe policy on the GMPS needs to address what the outcome will be for infractions against the GMPS.
Years ago I got a call from a bakery owner/president of the company - one of their locations had failed an SQF Audit do to massive infractions with GMPs and he asked me to go to their Boston facility and see what the hell was wrong with these employees - his words.
We found that virtually all GMPs were written with non action words and the policy basically said the employee may receive a warning and on repeats may be terminated.
The major issue however was that office workers, managers and supervisors for the most part thought they did not have to follow the gmps because they were above that!
The situation bleeded over into many other areas of the audit to the extent that when the shit hit the fan, two major customers suspended their business with the bakery.
Upon discussion with the owner pulled a super nova (I remember this term from my sams club inspection days) and fired every manager and supervisor at that bakery and then brought in replacements and actionable GMPs, policies were rewritten and training done.
We handled their turnaround and for the last 10 years they have aced or come close to acing their SQF audits.
The absence of the exact wording does not mean it's not applicable, nor should it need spelled out to do the right thing
13.3.3.6 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. 13.3.3.7 All exceptions shall meet regulatory and customer requirements and shall be subject to a risk assessment and evidence of ongoing risk management.
False nails and the like are considered loose items, you need to perform a risk assessment---once you've done that properly (including your overall hazard analysis in your food safety plan) then you can adjust (or not) you policy
It needs teeth---everyone is in the same HR boat these days, that is not an excuse for HR to flaunt the rules-----it would seem that person doesn't understand the risk to the business (or doesn't care)
If your customers don't want pieces of fake nail in the product and they get it---you will loose business Maybe explain it that way to HR
The absence of the exact wording does not mean it's not applicable, nor should it need spelled out to do the right thing
13.3.3.6 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. 13.3.3.7 All exceptions shall meet regulatory and customer requirements and shall be subject to a risk assessment and evidence of ongoing risk management.
False nails and the like are considered loose items, you need to perform a risk assessment---once you've done that properly (including your overall hazard analysis in your food safety plan) then you can adjust (or not) you policy
It needs teeth---everyone is in the same HR boat these days, that is not an excuse for HR to flaunt the rules-----it would seem that person doesn't understand the risk to the business (or doesn't care)
If your customers don't want pieces of fake nail in the product and they get it---you will loose business Maybe explain it that way to HR
Hi Scampi,
Re-^^^(red) - unfortunately "other loose objects" is previously interpreted by SQF as items such as watchbands, rings and bracelets. Admittedly this knowledge disappeared with the issuance of Ver 9 however jewelry etc and the (Packaging) missing items are in 2 clearly separated Clauses in the ver 9 Food Code.
("loose objects" is also hardly applicable to polish or long nails[long = ?] ).
My guess is that in some earlier ver X.Y, SQF forgot to copy the "false fingernails etc" clause in the Food Code into the equivalent Packaging Code so they craftily later added it into the Packaging Guidance for convenience. This worked Ok for subsequent versions until both Food/Packaging Guidances were abruptly jettisoned for ver 9 and the Packaging Code lost out. :smile:
Basically seems to require an additional clause to be added to the Packaging Code (assuming SQF still wish to ban these items).
Alternatively, déjà vu, maybe just delete the "loose" and slip an interpretation list of "objects" back into the Guidances. ;)
PS - I would have thought that this Bermuda Triangle type deficiency would already have been noticed before this so maybe a solution has already been issued by SQF "somewhere". ??
I missed that altogether
My guess is since SQF has become heavy handed with the use of risk assessments---they felt it was safe to omit it. I also belief the auditing guidance should go away altogether thank you--auditors believe if the guidance mentions something then it is auditable and you'll be dinged if you don't do that thing/have that thing, but you've met the code requirement
Risk assessments will bite you in the a$$ if not well written and researched (real hard data)
Now--admittedly--most packaging manufacturing is all or almost automated--so the risk isn't really coming from nails and eyelashes, but more likely grease/oil from the machinery
SQF is riddled with errors---someone should start a new challenge---who can find the most errors! Followed up closely with which clause is the most ridiculous and why--best argument wins!