BRCGS v.9 Food Safety 7.4.1 and 7.4.2 - Hair coverings in low risk non open product areas

Good afternoon all. 

Seeking views on BRCGS v.9 Food Safety  7.4.1 & 7.4.2 - are hair coverings deemed mandatory, even for low risk / non-open product areas?

I remember a time in earlier versions of the Standard where this would be considered 'based on risk'. Does a site have any flexibility based on risk assessment nowadays?

At very least, I feel it’s a best practice principle applicable to all areas for simplicity and cultural discipline - hence we presently maintain this (hairnets) for all production and storage areas, but your feedack in reference to the formal Standard’s requirements and its interpretation guide notes would be appreciated. 

(On a related note, does anyone have a recognised definition of 'beard' in terms of hair length (besides the 'peg' test!)?)

Thank you. 

I've never been involved in a BRC scheme, but I have in the past defended no hairnets in a storage warehouse adjacent to production under SQF.  The trick for me was to ensure our program was written to fully prohibit any open material in our storage areas (not even quick product samplings).  Our storage areas did not require smocks or hairnets thanks to this distinction.  Employee training discussed this heavily as well, and employees interviewed by auditors were accurate in why they could work in storage without hairnets but needed to don the smocks and hairnets before entering production.

Hair is a physical hazard. Wearing a hair net or cap shall be compulsory when a person enters in the food production & packaging area. The hair net or cap shall cover all hair including moustache & beard. Wearing hairnet outside production & packaging area shall be avoided to control the cross contamination.

The Beard is defined as a growth of hair on the chin and lower cheeks. Length of hair does not matter.

Thank you for your replies.