BRCGS 4.9.6.2 Control and Monitoring of Electronic Devices
The use of Bluetooth earmuffs (by team members) was recently approved to be worn on the production floor. The current "rule" is that team members are not allowed to have their mobile devices on the production floor, unless they are using a Bluetooth headset, in which case their phone must remain in their pocket at all times while on the production floor.
I'm curious to know how others monitor/control the presence of cell phones on the plant floor? Do you perform an extra GMP check on a specific amount of team members each day and document it or ???
Your input would be much appreciated, thanks!
no mobile devices allowed---period
A) are you inspecting the headsets? Are they company issued? Shatterproof, cleaned?
B) major safety hazard IF they need earmuffs for noise levels, they can't very well hear anything happening around them
I have cellphones/apple watches etc on my GMP check and yes, I write people up for using them
Also, as an after thought, and I may be a hard a** while we all want our employees to come to work everyday , we need to put the company first every single time
Examples: Documenting product deviations, safety incidents, etc.
NOT for personal use and certainly not for music, for all of the reasons Scampi listed.
Thanks for the input! The Bluetooth headsets are issued by the company, and the decision was made to allow it by HR and others in management. Quality provided input, but did not have the final say in this decision. I agree with all of the reasons to ban them from the production floor, but what is the best way to proceed from here with the decision that was made?
Ask HR to get input from their insurance company.
Thanks for the input! The Bluetooth headsets are issued by the company, and the decision was made to allow it by HR and others in management. Quality provided input, but did not have the final say in this decision. I agree with all of the reasons to ban them from the production floor, but what is the best way to proceed from here with the decision that was made?
None of that changes the GMPs. It would still be unacceptable to touch contaminated surfaces, and doing so would presumably trigger a requirement to wash hands etc. afterward.
While we allow foremen/supervisors to carry devices in the production environment, and expect them to handle the communications equipment occasionally, they are also specifically not supposed to be touching product or contact surfaces. IF they need to do so, they're expected to wash and put gloves on first.
Curious as to what you are producing as I would imagine this is a huge NO when audited by a 3rd party, regulatory, customer, etc.. I can't see anyway around this from a risk assessment standpoint if you are producing any food item.
I am curious what you produce as well, is there a Health and Safety team? Not only a Quality issue, but I think a major Safety issue. Would a radio not work in the facility?
Quality side of it, The phones and headsets should be on the Glass & brittle plastics inventory list and checked regularly, Sanitation list and cleaned daily when used, and how could you be sure staff won't be touching the headsets and transferring bacteria and hair to the product? I hope HR listens to your quality team.
Thanks for the input! The Bluetooth headsets are issued by the company, and the decision was made to allow it by HR and others in management. Quality provided input, but did not have the final say in this decision. I agree with all of the reasons to ban them from the production floor, but what is the best way to proceed from here with the decision that was made?
It's a shame your HR and other managers allowed this over QA's objections. Did you bring up that employees will likely touch the headphones when they want to talk to one another and will need to rewash/reglove their hands after touching something unsanitary? Did you mention that under Federal law that clothing and personal items are supposed to be stored in areas away from where food is handled? eCFR :: 21 CFR Part 110 -- Current Good Manufacturing Practice in Manufacturing, Packing, or Holding Human Food. Did you mention the specific BRC code prohibiting personal items, pointing out that it is going to be a minor finding when an auditor sees the headsets? (I don't have access to a copy of BRC, but if this requirement is written like SQF's or any other GFSI code, I can't see how it can be permitted at all).
If your company has a legal department, you could try showing them the CFR and ask them to evaluate your firm's exposure. If you guys have a OSHA safety committee, you might bring it up to them as employees unable to hear what's happening around them in a manufacturing environment is absolutely a safety hazard. But ultimately, if management won't reverse course on this matter, you might be stuck waiting until a customer or 3rd party auditor makes it a finding. Or wait until a customer complaint finds pieces of a broken headset in your finished product. Or your lab results from COA's eventually show unacceptable micros that lead back to the presence of a headset. Once you've allowed the employees to use bluetooth headsets, you'll likely start finding more violations of cell phone use on your GMP audits (people will be making phone calls and changing songs, etc). It's just a matter of time until you can drive home how bad of a practice this is.