15 replies to this topic

[Padfoot]

Hi Everyone,

I am doing an annual review on our GMP program. Our current program states that if a mustache is long enough to hang from the side of the mouth, a beard net must be worn. beards are acceptable until they reach 2 days of no shaving, but everyone grows hair at different lengths, making it hard to control. I am considering the length of eyelashes and eyebrows an an acceptable length with no risk (1cm), and wanting to switch our acceptable length to the same size (1cm). What are your thoughts? 

[Scampi]

Your new procedure OR clean shave or beard net

 

Who's responsible for measuring?  Much easier on you and your team to make it clear and simple

 

Clean shaven = no beard net

 

Anything else, including stubble = beard net

 

If you don't lock it down, they will push back-----hard

[Brothbro]

I agree with scampi, if you're anything less than clean shaven you need to wear a beard net. It's impossible to regulate all the different kinds of beards or stubble someone can have, and every operator is going to be trying to capitalize on the grey area in your standard.

[jfrey123]

I'm not interested in monitoring beard length down to the mm.  Saying only growth over 1cm requires a beard net opens the door to someone arguing their facial hair is only 9mm that day, and that ain't a fight I'm having.  I've always written GMPs to require beard nets when any facial hair growth is visible: if I can see your stubble, you need a beard net.  Of course, this practice left me open to an auditor trying to get me in a gotcha type moment, "What will you do when a female with a bit of hair on her lip comes to your facility?"  Told the auditor I'll cross that bridge when I come to it, but I'm not bashful about enforcing GMP's.

 

Of course the FDA and SQF are a bit vague on the topic.  FDA states beard nets "where appropriate" in CFR 21 A 110.10, and SQF says beard covers "where applicable".  Short story is if you've got an employee with a full beard that's trimmed to .5cm walking around without a beard cover, you're taking a hit from either party during an inspection.

[SQFconsultant]

When you started talking about measuring I immediately thought of my days in hotel inspections - we had a Red Roof inspector join us and he said he was required to measure blades of grass and how the problem was that not all blades were the same - anyway, I agree fully with Scampi.

[G M]

Hi Everyone,

I am doing an annual review on our GMP program. Our current program states that if a mustache is long enough to hang from the side of the mouth, a beard net must be worn. beards are acceptable until they reach 2 days of no shaving, but everyone grows hair at different lengths, making it hard to control. I am considering the length of eyelashes and eyebrows an an acceptable length with no risk (1cm), and wanting to switch our acceptable length to the same size (1cm). What are your thoughts? 

 

 

As others have said, if you aren't going to measure it don't set a measurement as the limit. 

 

There are things beyond facial hair this principle will apply to as well.  Some inspectors will expect to see records of measurement for whatever you quote a number for.

[MOHAMMED ZAMEERUDDIN]

Measuring the length of hair is a very tedious approach. GMP should be implemented and all the food handlers should cover hairs completely. Hairs and ears must be fully enclosed by the hairnets. Beard nets shall be worn to cover beards and moustaches.

[Evans X.]

Greetings Padfoot,

 

I would change the GMP and consider any mustache / beard should be covered with beard net, no matter the length, unless the person has a "military" shave or something close to it (depending on hair growth of each individual this can be a 1 or 2 days trimming). Generally as it is counterproductive to measure the length, you can set a general rule for eyebrows that should be trimmed a little when there seems to be an excess or "crazy" hair stand out. I would never set an issue though for eyelashes (apart from banning fake ones), as it is a delicate matter and none really trims his eyelashes. I mean it can be dangerous and cause eye-infections etc and trimming them can also cause more shedding (they don't exactly work the same as the rest of facial hair).

 

Regards!

[PQAManager]

We tried different lengths and it just got ridiculous.  Now we have no tolerance.  Clean shaved or beard guard.  You forgot to shave, beard guard.  Zero tolerance is a whole lot easier to monitor than a certain length.  And yes, I know, some have dark hair and get a 5 o'clock shadow.  If you don't shave before you come to work the next day, it is a beard guard.  And yes, I've seen arm air longer and busier than someone's hair on their head...what you going to do?  May need arm sleeve protection.  No matter the risk you need a risk evaluation and limits.  Good luck!  Set clear boundaries with your GMPs.  People will push where they can, and you need to make sure your product is protected at all costs! 

[WhySoCereus]

I agree with Scampi on this one as well. Have a clear set of expectations with a clear set of outcomes.

 

If in doubt, make everyone wear a shroud. This would also deal with pesky fly-aways and neck hair that never quite seems to be restrained.

[ChristinaK]

I've always implemented that beard nets must be worn unless the person is freshly-shaven. Hairnets must be worn even if the person is bald. Hair style and color don't matter, but all hair must fit completely in a single hairnet (we have 2 sizes). It's just easier enforcement.

 

You can ask, "If you found a hair in your food, do you care about the size of the hair? No, you care that you found a hair at all."

[Blending]

How do I respond to statements like--> several of the women have mustache and sideburns at 5mm... and they do. But then respond to our males that miss a day or two shaving? He had a possible valid point. I do not want to tell the ladies to wear a beard nets. I've stepped on my own foot saying. "what is good for one is good for another."

[GMO]

Zombie thread!!!

 

I'll comment anyway.  Oh I bloody hate all this beard snood palaver.  While I understand and will enforce workwear, I only think beard snoods in particular are completely valid in that it shows you an indicator of culture.  If someone isn't complying with basic rules, what else aren't they complying with?

 

But in some factories they wear beard nets and they're worse than useless.  Then all the length discussion.  The best compromise I've found is if you can pinch the hair and pull it, it's time for a beard snood / covering.  Otherwise some of our hairier staff would be needing one by the end of the day.

 

But do I genuinely believe it's a risk?  Sure if you're ZZ Top but most operators aren't.  Most are nowhere near.  I just really wish we could put more effort into other controls.

[TimG]

The FDA CGMP 117.10 (6) says: 

Wearing, where appropriate, in an effective manner, hair nets, headbands, caps, beard covers, or other effective hair restraints.

 

If you are under a food safety scheme, it might have specific wording you need to follow above and beyond any gov't GMP requirements. Also, I have no clue what Gov't requirements you are under, just using FDA as an example.

 

I have successfully removed the requirement for both hair/beard coverings in a facility, except on the platform the product was briefly exposed. It might come down to you performing a thorough risk analysis and proving what is appropriate and effective. 

That being said, if based on your risk analysis you require males to wear something based on the length of facial hair and then DON'T require females with the same length facial hair to wear them, that might be an issue during an audit.

Or not... an auditor might look over and see the bearded lady standing over the soup vat and decide to keep their mouth shut. 

[G M]

... several of the women have mustache and sideburns at 5mm... ... I do not want to tell the ladies to wear a beard nets. ...

 

Then make everyone wear a balaclava style hairnet.  No more hurt feelings, everyone is treated the same, all hair is contained.

[nwilson]

Then make everyone wear a balaclava style hairnet.  No more hurt feelings, everyone is treated the same, all hair is contained.

This is 100%!  Also controls the longer hair better IMO than a standard hairnet.