8 replies to this topic

[NorCalNate]

At our facility, anyone moving through Production is required to wear a Hi-Vis vest.

 

My SQF question: Are individuals required to remove their vest prior to entering or using toilet rooms? Section 11.3.5.6 notes that toilet rooms shall be "Located inside or nearby areas for storing protective clothing, outer garments, and other items while using the facilities", though it doesn't specifically state that such clothing or garments are required to be removed. Seems a bit subjective and/or open to interpretation. Is there a section that I'm missing?

 

Thoughts and or experiences greatly appreciated!

 

Toilet rooms shall be:
i. Designed and constructed so that they are accessible to staff and separate from any processing and food handling operations;
ii. Accessed from the processing area via an airlock vented to the exterior or through an adjoining room;
iii. Sufficient in number for the maximum number of staff;
iv. Constructed so that they can be easily cleaned and maintained;
v. Located inside or nearby areas for storing protective clothing, outer garments, and other items while using the facilities; and
vi. Kept clean and tidy.
Tools/equipment used for cleaning toilet rooms shall not be used to clean processing areas.

 

[Scampi]

It's inferred that since it's says they will be located nearby, that you would write your procedure to state that PPE must be removed and hung on the hooks provided before entering the washroom

 

Wearing any PPE inside the washroom is gross and can lead to cross contamination issues 

[Setanta]

Everyone here wears smocks in production and the smocks must be removed prior to going to the restroom. I don't see a difference here.

[NorCalNate]

It's inferred that since it's says they will be located nearby, that you would write your procedure to state that PPE must be removed and hung on the hooks provided before entering the washroom

 

Wearing any PPE inside the washroom is gross and can lead to cross contamination issues 

 

I understand what the verbiage was inferring but that's exactly my point, its inferring; not specifying. Was trying to determine if this is a requirement as I will need to add verbiage to my GMP Policy and do some spot trainings which I'd like to avoid as our audit is in 10 days. 

[jfrey123]

I'm one for arguing with auditors on code issues.  But this one is pretty clear to me:  "... for storing protective clothing... while using the facilities."  The point of having the storage for clothing next to the bathroom is storing the clothing while they use the bathroom.

 

Why do we store protective clothing outside the restroom while using the facilities?

 

Because 11.3.3.1 states:  "The site shall undertake a risk analysis to ensure that the clothing and hair policy protects materials, food, and food contact surfaces from unintentional microbiological or physical contamination."

 

Since you're saying anyone moving through production is required to wear a hi-vis vest, there is absolutely no risk analysis in my mind that can justify exposing a hi-vis safety vest to the microbial contamination of a restroom and then allowing it to be worn in a production area.

[Charles.C]

Two comments.

 

The OP omitted to state what kind of Product/Process involved which does not change the previous "inferences" but might even further boost their relevance,

 

No idea what a HiVis vest is but I presume it is a vivid garment worn over the normal attire. I have visited some facilities manufacturing baking ingredients where IIRC the employees (all male) in some extremely hot/dry areas wore only T-shirts and jeans. No supply of temporary over-garments was evident, Toilet access Procedures were not observed but I anticipate created some conflict with the SOPs previously detailed.

Suggestions ?

[DeadPresident]

Two comments.

 

The OP omitted to state what kind of Product/Process involved which does not change the previous "inferences" but might even further boost their relevance,

 

No idea what a HiVis vest is but I presume it is a vivid garment worn over the normal attire. I have visited some facilities manufacturing baking ingredients where IIRC the employees (all male) in some extremely hot/dry areas wore only T-shirts and jeans. No supply of temporary over-garments was evident, Toilet access Procedures were not observed but I anticipate created some conflict with the SOPs previously detailed.

Suggestions ?

Charles,

 

Hi Visibility Vest- Like the ones you would see a construction worker wear.

[Brothbro]

I worked in an SQF facility that initially only wore smocks/hairnets, but eventually implemented hi-vis vests for safety. Vests were treated the same as smocks in that they had to be removed before using the washroom. So even if you're a warehouse worker who only wears a hi-vis vest, it was a policy to remove it before the bathroom. Like others have mentioned it simply makes sense to remove ppe to reduce the risk of contamination, it takes only a couple seconds to do and has a big improvement on sanitation. 

[Xoinks]

I concur with others here.  I worked one hot bakery facility of low risk items that had uniform pants provided and shirts (not smocks), which pants weren't realistically feasible to remove.   But we did require the shirts to be removed (everyone just wore something under), and we assured that any product contact zones were higher than pants level.  

 

Can't see risk assessing out of PPE above waist level unless everything is automatically piped and processed through a closed system and there's somehow zero chance of product or food surface contact.