Wearing of False Eyelashes and Hair Clips in Production
Hello again,
I have been trying to find guidance on the wearing of false eyelashes in production and I can't find anything specific.
I'd be grateful for any ways that you have addressed the issue in your own BRC environments as ideally we would like to say that the company policy is that they are not acceptable but how do we enforce it if someone says they are natural or that they are the expensive glued in/woven in kinds? A few workers have raised the issue and said it's unfair for us to challenge piercings but not false eyelashes.
Hair clips are also a bit of a challenge with some people wearing them to keep their hair out of their eyes etc.
We don't have a hair net policy unless it is for brands who specifically ask for it, but I have concerns over foreign body control.
I really value the advice you all give so thank you in advance.
Kirstin
What are you making that you don't use hair nets? Or use them only at customer request? We require hair and beard nets to even step onto our production floor, whether you're working the production line or not. And if you're not in uniform, you have to wear a lab coat.
The false eyelashes are a no go here. Long hair and a pony tail holder is ok, but it has to be metal detectable, and only one to hold it back, no multiples,and kept under a hair net at all times in production. No jewelry of any kind, no fake fingernails, etc etc.
What are you making that you don't use hair nets? Or use them only at customer request? We require hair and beard nets to even step onto our production floor, whether you're working the production line or not. And if you're not in uniform, you have to wear a lab coat.
The false eyelashes are a no go here. Long hair and a pony tail holder is ok, but it has to be metal detectable, and only one to hold it back, no multiples,and kept under a hair net at all times in production. No jewelry of any kind, no fake fingernails, etc etc.
Pony tail holders that are metal detectable - I didn't know that was a thing.
Depends on what you make - for hair clips/barrettes - for us, our policy says they have to be larger than a certain size. That way if they were to fall out, it would be noticeable. Our employees also must wear a hair net and hard hat too.
We also allow for stocking caps, ear covers since it's a cold environment. I have found the headbands/ear covers do a good job of keeping loose hair from coming out hair nets.
I agree - no fake eyelashes.
I would clearly state in your GMP policy that no false lashes are allowed on the production floor as well as no hair clips. I would also revise your policy to enforce hairnets being worn at all times and not just having it be customer specific. That way, it is standardized and not confusing for employees. No exceptions if they are expensive/glued in/etc., they should have been told that before being hired. As far as push back on them saying they're natural -- I feel the frustration. I've had employees push back with false nails saying they are "natural" when they clearly aren't.
Pony tail holders that are metal detectable - I didn't know that was a thing.
The most common ones of all! When I was a long hair this is what I used usually. Although also I used those asian dual hair spikes...lol. That was before my time in the food industry of course....
Hello again,
I have been trying to find guidance on the wearing of false eyelashes in production and I can't find anything specific.
I'd be grateful for any ways that you have addressed the issue in your own BRC environments as ideally we would like to say that the company policy is that they are not acceptable but how do we enforce it if someone says they are natural or that they are the expensive glued in/woven in kinds? ...
Our GMP policy that everyone reviews and signs at new hire and every year includes prohibition on clothing with "decorative features such as" and lists a few things like beads, glitter etc. Similarly another line prohibits "cosmetic items such as" and lists nail polish, false fingernails, and false eyelashes. Another one for consumables that people tend to carry in pockets during everyday life.
It ends with a statement about disciplinary actions being taken for failure to comply.
More broadly, during training it is emphasized that one of the general categories of things we're trying to avoid is allowing anything into the production environment that might accidentally end up in the product. People tend to remember that more generalized concept even if an individual doesn't remember the specifics.
Hello again,
I have been trying to find guidance on the wearing of false eyelashes in production and I can't find anything specific.
I'd be grateful for any ways that you have addressed the issue in your own BRC environments as ideally we would like to say that the company policy is that they are not acceptable but how do we enforce it if someone says they are natural or that they are the expensive glued in/woven in kinds? A few workers have raised the issue and said it's unfair for us to challenge piercings but not false eyelashes.
Hair clips are also a bit of a challenge with some people wearing them to keep their hair out of their eyes etc.
We don't have a hair net policy unless it is for brands who specifically ask for it, but I have concerns over foreign body control.
I really value the advice you all give so thank you in advance.
Kirstin
Hi Kirstin,
It helps if a Local, authoritaive reference is available for utilization/support within a Company Policy.
If above not available, Management should have sufficient Courage/Ability to issue a Generic Policy, ie avoid quantification of argumentally / ambiguously quantitable items/activities.
Hi Kirsten,
The BRC's list of hygiene do's and don'ts has changed a number of times over the years. Whenever they try to make a prescriptive list there have always been opinions and questions about 'why is x prohibited but y is not' and there are often no easy, logical replies.
If you make low risk, non direct food contact products, such as self adhesive labels for glass bottles, compliance with the Standard is relatively straightforward as you can do one of the BRC's beloved risk assessments. Depending upon the product and its use, this could demonstrate that neither piercings, hairclips nor false eyelashes are a risk to the product, particularly if the products are in reel form.
These items falling into a packing carton for a low risk, non food contact product may not be a product safety risk but could cause a complaint.
If it is a higher risk product, the fall back position is 'That's what the Standard says and that's what we must do'
If you do not have a requirement to wear hair covering, you should have already made a risk assessment. Make sure it is current and appropriate to your products. Hair covering for specific customers is unusual but not unknown. It does need clear documented, boundaries and policing.