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Laux

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Posted 06 June 2022 - 05:32 PM

Hello,

 

My business produces packagings for food, we have the HACCP cause it is client's requirement and I have a question - is there a requirement to wear caps and beard masks or not wear jewelry on the line where it is safe for the workers? As for now I have implemented such need as one of the auditors pointed it out but I am not sure if it is really a requirement as I do not produce food.

 

Thanks for help!



olenazh

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Posted 06 June 2022 - 05:42 PM

Hi Laux, welcome to our forum! My strong believe is that food packaging manufacturing requires the same protective measures as food manufacturing. Because, facial/head hairs and jewelry present potential foreign matter contamination risk to the materials you're manufacturing - regardless, it's primary or secondary, etc. packaging.



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Posted 06 June 2022 - 06:09 PM

If you have a HACCP plan, your hazard analysis should address questions like "what are the potential sources of contamination for my product?" In your case I would agree with the auditor that the staff pose a contamination risk. In handling your product, hair could come lose and find its way into the material. For direct food contact packaging, this hair will end up in the food. Your customers are likely expecting this precaution as well, they probably requested the HACCP plan to boost their confidence in your process.



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Posted 07 June 2022 - 06:12 AM

Hi Laux,

 

:welcome:

Welcome to the IFSQN forums.

 

The important question here is if the packaging is food contact packaging. Below are the requirements of the 4 main GFSI benchmarked standards for food packaging. Prevention of contamination from hair and jewellery is prescribed in each. There is also an emphasis on risk analysis/hazard analysis.

 

BRCGS Global Standard for Packaging Materials Issue 6

6.5 Protective clothing

6.5.1 Hair coverings and/or beard snoods, where appropriate, shall be worn in production areas at sites manufacturing materials for direct contact with food or other hygiene-sensitive products.

6.2 Personal hygiene

6.2.1 The requirements for personal hygiene at sites producing materials for direct contact with food or other hygiene-sensitive products shall be documented and communicated to all personnel. These shall include, as a minimum, the following instructions:

• wrist bands, wrist-worn devices or watches shall not be worn

• jewellery including piercings shall not be worn on exposed parts of the body, with the

exception of a plain wedding ring, wedding wristband or medical alert jewellery

 

SQF Food Safety Code: Manufacture of Food Packaging, Edition 9

13.3.3 Clothing and Personal Effects

13.3.3.1 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.

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.

 

FSSC 22000 CERTIFICATION Scheme Version 5.1

Technical Specification ISO/TS 22002-4:2013 (Prerequisite programmes on food safety -- Part 4: Food packaging manufacturing)

4.10.4 Workwear and protective clothing

The organization shall ensure that personnel who work in or enter into production or storage areas shall wear work clothing which is fit for purpose, in good condition and which not present any potential for contamination.

Where appropriate, work clothing or other adequate protection shall provide coverage so that hair, perspiration and other loose items cannot contaminate raw materials, intermediate products, food packaging or equipment based on a food safety hazard analysis.

4.10.7 Personal Behaviour

A documented policy shall describe the behaviours required of personnel in production and storage areas. The policy shall at a minimum cover:

a)  permissibility of smoking, drinking (other than water), eating and chewing in designated areas only; the prohibition of wearing jewellery, wristwatches and visible piercings, unless they are appropriately controlled to minimize contamination. The organization shall clearly define the type of jewellery allowed to be worn as determined by hazard analysis.

 

IFS PACsecure Version 2 - Standard for assessing product and process compliance in relation to the safety and quality of packaging material

3.2 Personal hygiene

3.2.1*

Based on hazard analysis and assessment of associated risks, the requirements for personal hygiene shall consider, at a minimum, the following topics:

• coverage of hair and beards

• protective clothing (including their condition of use in productive areas and staff facilities)

• hand washing, disinfection and hygiene

• eating, drinking and smoking

• actions to be taken in case of cuts or skin abrasions

• fingernails, personal belongings (including medicines), and prohibition to use jewellery

Guidance:

(2) The usage of headgear is required. Considerations: If so, control activities shall be in place to prevent product contamination due to its misuse (e.g. check if the headgear covers the hair completely)

(3) The usage of wedding bands is allowed as an exception (after evaluation and justification). If so, relevant control activities shall be in place to avoid product contamination due to the exception.

 

If you are manufacturing food contact packaging then quite clearly you should have controls in place to prevent contamination with hair or jewellery.

 

Kind regards,

Tony



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Laux

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Posted 07 June 2022 - 02:21 PM

Thank you very much for all of your replies, they are really helpful. The packaging has direct contact with food but I guess that it does not matter that I have a requirement that it has to be cleansed first before actual use during food "filling"? Of course the topic is clear now and I know that the easiest way to solve it is just to wear caps and beard masks together with jewerly being forbidden, but I just wanted to know it to be sure :-)



Charles.C

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Posted 07 June 2022 - 09:46 PM

Re - Post 4 - Jewelry etc etc - the text in the FSSC22000 (4.10.7) and IFS (3.2.1)  Standards  supports the possibility of "negotiating"  various characteristics/activities which are typically forbidden in a food production environment.

 

Previous threads here have repeatedly demonstrated that (barring defined exceptions, eg medical)  the only effective solution in the majority of such cases is to avoid involving overt risk assessment/haccp considerations  and simply issue a Policy stating the Company's requirements.

(Pre-Requisite = Pre-HACCP).

 

PS - Re Post 3 - afaik, hair is not regarded as a (HACCP) safety risk. Definitely a quality objection though.


Kind Regards,

 

Charles.C


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Posted 08 June 2022 - 04:53 AM

Re - Post 4 - Jewelry etc etc - the text in the FSSC22000 (4.10.7) and IFS (3.2.1)  Standards  supports the possibility of "negotiating"  various characteristics/activities which are typically forbidden in a food production environment.

 

Previous threads here have repeatedly demonstrated that (barring defined exceptions, eg medical)  the only effective solution in the majority of such cases is to avoid involving overt risk assessment/haccp considerations  and simply issue a Policy stating the Company's requirements.

(Pre-Requisite = Pre-HACCP).

 

PS - Re Post 3 - afaik, hair is not regarded as a (HACCP) safety risk. Definitely a quality objection though.

 

Hi Charles,

 

Post 4, I guess that is me  :biggrin: I largely agree with your comment and explain in more detail below  ;)

 

The BRCGS Standard for Packaging tends to be the most specific, it is long established and the first standard to be recognised by the Global Food Safety Initiative (GFSI). The standard previously had two levels of hygiene but reverted to one due to poor uptake of the low hygiene level.

 

SQF Food Safety Code is specific to Food Packaging so you would expect it to have more specific hygiene requirements.

 

The FSSC 22000 Certification Scheme includes Technical Specification TS ISO 22002-4 which essentially covers the basics of the GFSI Benchmark Requirements for GMP. The whole scheme is supported by Additional Requirements to fill in any gaps and to ensure the scheme meets GFSI Benchmark requirements.

 

IFS PACsecure is a generic packaging standard.

 

BRCGS Global Standard for Packaging Materials Issue 6

The scope of the Standard

The Standard sets out the requirements for the manufacture of packaging materials that are used in the production of, and filling operations for, food, hygiene-sensitive consumer products (including cosmetics), raw materials, and other consumer products. Key changes to the requirements for Issue 6

Hygiene levels

Issue 5 published two levels of hygiene, basic and high, to reflect the risk-based requirements for different manufacturing sites to minimise the risk of contamination before, during and after production. However, from research, the basic hygiene level has had very little uptake. Following consultation and agreement, in this issue of the Standard, the basic- and high-level hygiene requirements have been consolidated into one level based on risk.

 

SQF Food Safety Code: Manufacture of Food Packaging, Edition 9

The SQF Food Safety Code: Manufacture of Food Packaging sets out the implementation, maintenance, and technical requirements for sites involved in the manufacture and storage of food sector packaging including flexible films, paperboard containers, metal containers, flexible pouches, glass containers, plastic and foam containers (PET, polystyrene, etc.), and single-use foodservice products.

 

FSSC 22000 CERTIFICATION Scheme Version 5.1

Technical Specification ISO/TS 22002-4:2013 (Prerequisite programmes on food safety -- Part 4: Food packaging manufacturing)

ISO 22000 sets out specific food safety management system requirements for organizations in the food chain. One such requirement is that organizations establish, implement and maintain prerequisite programmes (PRP) to assist in controlling food safety hazards. This document is intended to be used to support management systems designed to meet the requirements specified in ISO 22000, and sets out the detailed requirements for those programmes.

 

IFS PACsecure Version 2 - Standard for assessing product and process compliance in relation to the safety and quality of packaging material

The IFS PACsecure is applicable for the production, processing and/or conversion of packaging components and / or packaging materials, intended to be used as primary or secondary packaging.

 

As I posted before, if you are manufacturing food contact packaging then quite clearly you should have controls in place to prevent contamination with hair or jewellery.

 

PS - Re Post 3 Whilst predominantly viewed as an undesirable presence, it is possible for hair to be a source of Staphylococcus aureus

 

Kind regards,

Tony



Charles.C

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Posted 08 June 2022 - 07:42 AM

Hi Tony,

 

Thks for the expanded details. (actually SQF9 Packaging has curiously "lost" some prescriptive GMP requirements as existed in ver 8.1).

 

The specific Standard (if any) in the OP is unknown however I assume below that a GFSI connection may exist in Poland.

(If  Polish Packaging HACCP simply references, say, use of a local Regulatory GMP document, the options discussed in this thread may be moot from OP's POV).

 

I speculate that GFSI's ("Generic") Benchmarks are at the core of issues such as discussed in this thread, eg GMP EL 16 -

 

The standard shall require that documented personal hygiene standards based on risk of product contamination be in place and personnel
trained in them. Hand washing and toilet facilities shall be provided. Suitable and appropriate protective clothing shall be provided. a medical
screening procedure shall be in place. In all cases, these requirements shall also apply to contractors and visitors.

 

 

Offhand Prescriptive Standards like BRC/SQF which "arbitrarily" define various GO/NO GO Sanitation requirements are  seemingly not in compliance with GFSI  (unlike FSSC22000/IFS ?) unless BRC'/SQFs approach can perhaps be interpreted as auto-achieving zero risk by default (or equivalently being supported by a GFSI-superceding Authority, eg FDA).(or maybe there is some, System-wide, "escape" clause situated somewhere in the Standards ;) ).


Kind Regards,

 

Charles.C


Scotty_SQF

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Posted 08 June 2022 - 12:35 PM

I have always followed the hairnets, beard nets and no jewelry in packaging.  That being said I have visited and audited some packaging suppliers who have been GFSI certified and jewelry was allowed along with no hairnets.  When I inquired they told me they were able to risk assess it out and it worked with auditors.  I have even asked an auditor before about it and they stated they must have risk assessed it out, but it would have to be a very good risk assessment.  In my experience though there is very low risk in terms of jewelry in packaging manufacturing.  Simply because if your watch or earring fell off, it would more or less damage the equipment rather than 'contaminating' the product.  The exception being if it fell off while palletizing, but even then, the film is already in roll form, so it would just be a customer finding your watch and you having to explain it.  It tends to be more of a workplace safety issue.  However, I always say it is just best practice to follow along with GMP's.



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Posted 09 June 2022 - 03:21 AM

Hi Charles,

 

Not sure where the SQF prescriptive elements were “lost”, Edition 9 has more text for the relevant sections for this topic:

 

The SQF Food Safety Code: Manufacture of Food Packaging – Module 13 Edition 9 13.3.3 Clothing and Personal Effects = 296 Words

 

SQF Module 13: Good Manufacturing Practices for Production of Food Packaging Edition 8.1: 13.3.3 Clothing/13.3.4 Jewelry and Personal Effects = 158 Words

 

Where is the GMP EL 16 quote is from? here are the relevant GFSI Benchmark Packaging GIP requirements for Personal Hygiene & Protective Clothing:

 

Attached File  GFSI GMP Packaging Hygiene Version 2020.pdf   1.01MB   27 downloads

 

Kind regards,

Tony



Charles.C

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Posted 09 June 2022 - 06:09 AM

Hi Charles,

 

Not sure where the SQF prescriptive elements were “lost”, Edition 9 has more text for the relevant sections for this topic:

 

The SQF Food Safety Code: Manufacture of Food Packaging – Module 13 Edition 9 13.3.3 Clothing and Personal Effects = 296 Words

 

SQF Module 13: Good Manufacturing Practices for Production of Food Packaging Edition 8.1: 13.3.3 Clothing/13.3.4 Jewelry and Personal Effects = 158 Words

 

Where is the GMP EL 16 quote is from? here are the relevant GFSI Benchmark Packaging GIP requirements for Personal Hygiene & Protective Clothing:

 

attachicon.gif GFSI GMP Packaging Hygiene Version 2020.pdf

 

Kind regards,

Tony

Hi Tony,

 

Thanks for Packaging attachment which I slightly extracted -

Attached File  GFSI Personal Hygiene - Packaging (truncated).png   162.04KB   0 downloads

 

Re ^^^(red) -

See this recent thread, especially Posts 2, 7 -

https://www.ifsqn.co...tc/#entry186011

 

Re^^^(blue) -

My quote is for Food Manufacturing which I took from the randomly located GFSI Guidance Document (2013) attached below. I long ago gave up searching in GFSI's utter atrocity of a Website and guessed that their Packaging Equivalent would almost certainly be equal to or even more risk "Generic" than that for Food. Thanks for (probably) proving me right.

Attached File  gfsi guidance document,2013.pdf   1.65MB   7 downloads

(See Pg 142)

 

I have some sympathy/respect for GFSI inasmuch as their attempted offering of meaningful (auditable) Safety Benchmarks across the diversity of  Food/Packaging Manufacturing is IMO a near-Herculean Task. And particularly in respect to deciding whether absolute or relative criteria (ie risk-based) need to be made, eg Prescriptive vs Generic. Clearly GFSI chose Generic.

Whichever of the 2 routes is taken, both ultimately demand that their implementations  be Validatable and/or Verifiable (yet another terminological jungle)  and it is this latter stage which seems to be putting auditors under pressure, particularly/predictably where Generic responses are facilitated. (I deduce the [Generic]  ISO22000 encountered related headaches as illustrated by their removal of non-quantitatable CCP/CL criteria in the 2018 HACCP revision).


Kind Regards,

 

Charles.C


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Posted 10 June 2022 - 04:18 AM

I agree Charles, the GFSI Benchmark Requirements are somewhat a basic foundation and as you have said in their defence, there is quite a broad range of 20 Food Sector Categories:

 

Attached File  IFSQN GFSI Food Sector Categories.pdf   75.1KB   10 downloads

 

Kind regards,

Tony



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Posted 13 June 2022 - 08:04 PM

 

 

PS - Re Post 3 - afaik, hair is not regarded as a (HACCP) safety risk. Definitely a quality objection though.

 

I disagree on the human hair not being a food safety risk

Discussion

We investigated the interaction and growth kinetics of Gram-positive S. aureus and S. epidermidis and Gram-negative E. coli and P. aeruginosa in the presence of human hair shafts. For the first time, we showed the colonization and adherence of E. coli and P. aeruginosa on hair shafts, where P. aeruginosa formed a biofilm, while E. coli inhabited only the edges of the cuticle scales. Furthermore, this study demonstrates significant antibacterial effects of human hair shafts on S. aureus and S. epidermidis.

https://www.frontier...2018.02145/full

 

Staphylococcus aureus and S. epidermidis are common pathogens in hospitals, and care should be taken not to disseminate these organisms among patients. We have focused on human hair as a source of bacterial contamination. We treated hair with culture solutions of S, aureus and S, epidermidis, and then performed scanning electron microscopy, Bacteria were detected on the surface of the cuticles of the hair, and the attached bacteria were not completely removed even by repeated washing with detergents. These results suggested that hair could be a source of bacterial contamination and indicated the importance of decontamination of hair.

https://www.research...rgent_treatment


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Charles.C

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Posted 14 June 2022 - 08:55 AM

Hi Scampi,

 

Yes. Snap. 

 

Might add that hospitals are possibly a slightly different situation with respect to significant risks. (And Food Pckg vs Food ?)

 

Can have a browse  through this 2010 thread -

 

https://www.ifsqn.co...rds/#entry35622

 

And this "Popular" view -

https://www.popsci.c...od-health-risk/

(Quite old [2010] so perhaps FDA's POV has changed ? - here is a 2021 follow-up -

 

Though finding a hair in your food can kill your appetite, eating it probably won’t kill you. In fact, it likely won’t affect your health at all.

As Popular Science explains, hair mostly comprises keratin, a protein that poses no threat when eaten. And while it is technically possible that there’s Staphylococcus aureus bacteria clinging to the hair, it’s probably not enough to cause any gastrointestinal distress. If the hair snuck into your food before it got cooked at a high temperature, chances of illness are even slimmer. “Ingesting a hair or two … will likely not be problematic and will just pass right through you,” Adam Friedman, a dermatology professor at the George Washington University School of Medicine and Health Sciences, told VICE.

You could choke on a hair, or it could cut the mucous membrane in your mouth—but neither of those are common issues. If you have a habit of eating hair, on the other hand, that’s a different story. Trichophagia is a psychological disorder where people compulsively ingest their hair, which can cause hairballs called trichobezoars to get lodged in their stomachs. Not only is that a rare occurrence, but it definitely wouldn’t be the result of a single hair-in-food incident.

The FDA doesn’t seem to think swallowing a few hairs now and then is harmful, either. Manufacturers are allowed to include an average of up to 11 rodent hairs per 25 grams of ground paprika or ground cinnamon, for example, and plenty of other food products can contain rodent hairs, too. As for human hair, the FDA doesn’t mention it at all in its Food Defect Levels Handbook. It does come up in the FDA Food Code, which recommends that food employees wear “hair restraints such as hats, hair coverings or nets, beard restraints, and clothing that covers body hair.” Not every department of health rigorously enacts and enforces that mandate.

But while a piece of hair on your plate isn’t a huge risk by itself, it could warn you of a larger problem. “Hair can be an indicator of lack of sanitation at the facility where the food was prepared,” USDA food safety specialist Archie Magoulas told VICE. At the very least, you should probably get a free meal out of the debacle.

[h/t Popular Science]

https://www.mentalfl...ood-safety-risk

 

 

Regardless, perhaps this is the Scientific way to go -

 

Attached File  haccp approved hair containment products.pdf   3.11MB   9 downloads

 

or from a more HACCP POV -

 

Attached File  Requirements to Implement a Risk Assessment of Hair and Beards.pdf   559.4KB   15 downloads


Kind Regards,

 

Charles.C


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Posted 14 June 2022 - 10:26 AM

Hi, 
The food packaging will be in direct or indirect contact with the foodstuffs. As long as there is a risk of contamination of these packaging by the hair or by the staff, the wearing of suitable and clean clothing is required to prevent any  risk of contamination which  should  be based on risk analysis.
 
Along with that the explanation added by Tony confirms these requirements


Laux

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Posted 15 June 2022 - 11:24 AM

Thank you very much everyone for all the responses - this is a huge portion of knowledge. The biggest problem for me is that there is a huge space for the interpretation. To be fair, for me the hair or beard nets are not as problematic as the jewerly.

Correct me if I am wrong - if I would make a good risk analysis, then the jewerly prohibition would not be necessary?

Regarding my HACCP it has been implemented basing on the requirements of DIN 15593:2008.

 

Thank you



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Posted 16 June 2022 - 03:31 AM

Thank you very much everyone for all the responses - this is a huge portion of knowledge. The biggest problem for me is that there is a huge space for the interpretation. To be fair, for me the hair or beard nets are not as problematic as the jewerly.

Correct me if I am wrong - if I would make a good risk analysis, then the jewerly prohibition would not be necessary?

Regarding my HACCP it has been implemented basing on the requirements of DIN 15593:2008.

 

Thank you

Hi Laux,

 

It is important to appreciate that any meaningful Risk Analysis will ultimately be limited to the specific (ie your own) situation.

 

Regret not familiar DIN 15593, what does it say regarding jewelry ?

 

Yr context/query is similar to that adressed in 2nd attachment of Post 14 for the case of hair/beards. The Logic IMO may equally apply to yr query.

 

The above suggests you initially first determine a typical "Best Practice" (and IMO a corresponding Company Policy). This necessitates you selecting an "appropriate reference(s)" for your context (eg the relevant FSMS Standard).

 

I anticipate that your "Best Practice" result for jewelry will be a requirement to maintain partial or total absence of such.

(Of course if the "Best Practice" is a Regulatory requirement this ends the discussion).

 

The aforementioned attachment suggests that if you wish to deviate, (eg relax) from the Best Practice, you need to evaluate the answers to a (listed) series of questions so as to implement a hazard analysis, after which -

 

Attached File  hazard analysis.png   205.08KB   1 downloads

 

PS - Some examples of the use of Risk Matrices in assessing cleaning programs, etc  here -

 

Attached File  Safefood360, risk assessed FSMS programs.pdf   992.44KB   5 downloads


Kind Regards,

 

Charles.C




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