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Personal Hygiene BRCV9 - 7.2.1

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Posted 28 June 2023 - 10:17 AM

Hello All 

I'm looking for some guidance advice, we have recently had some challenges with employees/agency with facial dermal implants, have any of you come across this before and how did you deal with it? My understanding is that they are surgically implanted and if the jewellery end is removed then the implant can't fall out. We have a large employment pool and i want this to be very clear and two fold in that these considerations are part of the recruitment process in the fact that they may not be permitted, and how we deal with current. The last thing we want to go down is carry out risk assessments for each individual and having blue plasters been issued. 

I have checked for any advice in BRC but there is nothing that goes down to the level of detail that i think we need to include. The retailers are specific in the fact that its jewellery and should be removed.

I want to investigate all avenues before making recommendation's. 

Many Thanks in advance, Jo  :tongue:  :wacko:



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Posted 28 June 2023 - 12:37 PM

I guess you could argue that the implant itself isn't jewelry but an implant--depends how important the customers are to you but I would caution you that this is a very slippery slope


If you're NOT having recruitment issues than is it a no go--------if you cannot find enough staff than perhaps speak with a physician to understand how the implant is secured and generate a risk assessment based on that 3rd party information (not what your employees tell you) and go from there


If they really cannot "fall out" then the bandage covering may pose an unnecessary risk

Please stop referring to me as Sir/sirs

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Posted 06 July 2023 - 06:05 PM

FDA 21 CFR 117.10(b)(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.


Using the same regulatory statements we allow jewelry that cannot be removed as long as it may be covered, either by plasters (band aids: blue, metal detectable), gloves, frocks or uniforms, and and then if in an open area with band aides, like the ears, we have the employee checked in with Supervisor when completed.  

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