8 replies to this topic

[kcanales02]

Hello, food safety peeps,

 

i joined a company (2 months) with a captive shoe program. we wear covers over everyday shoes.

 

people are constantly going outside with them on. we also have an outdoor patio which is an employee entrance and it is also connected to the breakroom. so they will go outside on the patio as well.

 

we have foam/sprayers at the entrances to production.

 

 

Any suggestions to monitoring and/or auditing this program?

 

 

IMO, we do not give the employees proper space, tools, or time to change into/out of the shoe covers.

at the end of the day, they go to the locker room, remove and clean them, and then put them in their lockers.

 

some other scenarios:

coffee and pastry party, they went outside with them.

evacuations, they come outside with them.

everyday lunch/break, they are going to the patio with them on. They are allowed to have them in the breakroom, but not outside.

 

i heard we had footbaths/tubs for after evacuations but the practice was stopped. not sure why, maybe cost or manpower for upkeep.

 

anyways, need help with creating or updating the program to include an audit or something. not even sure there is a written program at the moment.

 

thank you for listening

[Marloes]

Hi,

 

Can you give more information on the product scope? Is it RTE? Is there product contact?

 

What is the goal of the shoe covers? What are you trying to mitigate?
Is it about preventing allergens/microbacteria or keeping out general dirt?
It could also be geared more towards protecting your employee's and/or their shoes from production dirt/dangers.
 

If you do need to mitigate allergens, microbacteria and other types of contamination in your production area. Then you already know they shouldn't be out on the patio/break room wearing any production clothes. 
Your company should facilitate the tools and time for them to change in and out of the appropriate clothes.

 

Edited by Marloes, 02 November 2022 - 08:31 AM.

[Setanta]

Are you a RTE facility?
We have a similar set up with shoe covers, but we are not RTE. We do allow people to wear them outside on breaks, because they are primarily a slip resistant cover.

[jfrey123]

Are these covers reusable or something?  Facilities I've visited that use shoe coverings were all single use that came out of a dispenser, so employees didn't have to touch their shoes to put them on.  They were throw away after use, not to be worn outside, just like hairnets or smocks/aprons.

 

To stop employees wearing them outdoors, you'll need to conduct a retraining on procedure and handle the violations like any other GMP violation observed.  Somehow, your company's culture has taught them wearing them outside is acceptable, and it'll take hard work to change that mentality.

 

Back to one point you mention on evacuations, I think you'd run into a safety violation of sorts if you required employees to carefully remove them prior to evacuation.  The whole point of an evacuation is to get out as quickly as safely possible, so asking employees to stop to do something with shoes is likely an unsafe training practice.  But in every other scenario, yes, they shouldn't be wearing these outside before reentering the facility with them still on.

[kcanales02]

More info: we are NRTE. trying to mitigate Listeria and other micro. these are rubber covers that 'slip' on over shoes (not easy to put on or take off).

we do provide hooks for smocks, but no bench or easy way for them to remove covers at breaks and lunches if they choose to go outside on patio.

 

is this simply disciplinary actions for those who violate?

thanks for the responses,

K

[Gelato Quality Lead]

Hi,

 

Seeing that you are trying to mitigate Listeria and other micro, I immediately see a problem. Listeria, as well as other micro, are naturally found in the environment, so by wearing the shoe covers outside the production area, micro could be tracked in. 

 

I think incorporating footbaths again could be a good idea. You can validate that wearing shoe covers outside is not a good practice from the micro stand-point by doing some swabbing. 

 

We are RTE and the team wears rubber safety boots that never leave the production area and are cleaned beginning and end of each shift. Disposable shoe covers are worn in production area by any visitors. 

[Marloes]

is this simply disciplinary actions for those who violate?

 

 

NO

Don't just start disciplinary actions.
You need to make sure everything is perfect from your side.

Start to provide the correct tools.
Give your co-workers correct shoe wear. Ensure dedicated production/high care shoe wear. 
Provide a suitable way to change into said shoe wear. Ensure enough space to store them, enough space and time to change in- and out of them.
If co-workers need to change frequently, make sure that you provide quick changing option (no laces/straps).

 

Then start training on the procedure.
Provide visual aids within your production (signs for correct workwear, signs regarding no production wear outside etc.).
Double check that you covered everything (all exits, all types of work).
Make clear that starting from date XX violators will be given disciplinary actions.
 

If you did your job well, you don't need to use disciplinary actions.
Which will be good for all parties involved .

[Setanta]

NO
Don't just start disciplinary actions.
You need to make sure everything is perfect from your side.

If you did your job well, you don't need to use disciplinary actions.
Which will be good for all parties involved .

ALL OF THIS! Marloes is spot on. You don't start with a hammer.

[Jewl578]

I apologize if this is too long...

 

Our company has been back and forth on this subject of dedicated footwear since time began.

A bit of background. We are an RTE facility with completely separate RTE and NRTE areas and have approx.100 employees.

Employees are not allowed to move back and forth without changing PPE. Color coding for RTE and NRTE is in effect for PPE.

 

When we started on this dedicated footwear journey, it was with wellingtons and a bucket of sanitizer with brushes. Employees were allowed to wear the company purchased boots anywhere in the facility as long as they sanitized them upon re-entrance to RTE areas. They were not allowed to wear outside. There was, and still is room for this change-out of shoes and PPE in accordance to BRC.

 

​Then along came a customer who insisted on the using smart step sanitizing system. The footwear sanitizer was easy to use and we continued for a few years with it. It only sprayed sanitizer (Alpet D2) and did not scrub footwear. Employees wore dedicated shoes and as with the wellingtons, the shoes could be worn anywhere inside, just not outside. They would sanitize shoes upon entrance to RTE area.

 

All of this was fine until our most recent audit, unannounced, where the auditor said, we can either go with dedicated footwear and a footwear sanitizer with scrubbing or use disposable footwear; think the blue cottony disposable kind. So we decided to try these disposable booties. This did not work out because in the high heat oven areas, they tended to melt to the guys shoes. So back to square one because they melted and also after reading a recent article published by Techni-K stating "shoe covers aren't acceptable". Our certification body gave us the go ahead on the disposable booties by the way.

 

I have read and reread the BRCGS 8.4.1 clause, it's interpretation and have spent a lot time researching this subject and the following is what I have come up with: Someone please tell me if this is not correct because I am still confused by what interpretations, auditors and consultants say. Everyone is different!

 

1. You MUST have dedicated footwear purchased by the company.

2. Dedicated footwear must be donned in the changout area prior to entering the RTE area.

3. Dedicated footwear must be removed EVERY time you leave the RTE area, with warehouse, sanitation and maintenance employees following the same rules. 

4. Visitors and contractors can use disposable booties while following the same on/off procedures as employees.

5. There is no need for sanitizer as long as the dedicated footwear is cleaned nightly.

6. A risk assessment will determine if this system is working or not.

7. NRTE area employees do not need dedicated footwear as long as they stay in NRTE areas.

 

There's no doubt I'm missing something somewhere.

 

Thank you invance for any input.