Beard nets control procedure

I am writing up GMP's for a meat operation, and I am really on the fence about beard nets, to me they have an unintended consequence, we now have hands to the face area with the wearer adjusting it. I recently had a discuss with my FSIS inspector who told me at another facility he inspects an employees bread net was literally discolored from the seasonings he was working with, coming from his hands as he adjusted the beard net.

I would like to write into my GMP's something like; Any beard over 1/4" (the length of eyebrows or mustache) will be required to were a beard net.

That way I am not running into the questionable unshaven man on a Monday morning that did not shave all weekend, not having to deal with the hands to the mouth face area because the beard isn't even long enough to hold a net in place and is thus constantly being adjusted. I think we sometime put these feel good controls in place without really looking at the potential consequences, does anyone have any thoughts or experience with this or written such a criteria into their plan.

Thank you

Every facility I've worked in followed the simple policy that if you have -any- facial hair, it needs to be covered by a beard net. Giving staff any wiggle room for facial hair length is unfortunately an invitation for the standard to be debated at every step. If operators are adjusting their beard nets too much, it means they aren't wearing them properly or your beard nets are not designed very well, there is a way to wear them so that they don't need constant adjustment. 

Clean shaven or beard net               Who'd policing the length?  

The best solution? Find better nets that stay in place

With my previous employer, we just switched to hood caps for everyone.  This was more effective for us, with less fuss, less pushback.  

To answer the question on who is policing the length; I guest the same person that says a guy with stubble has to wear a beard net. I ask all of you to take a good look at the effectiveness of a beard net, take a good look at the beard net wearer, how much hair is exposed after an hours work. Watch how many time their hands reach up and adjust that net. I have yet to see one that covers all of a beard, less the hood type and then they are not 100%. I think you may be surprised what you see when you take a good look at it.

And what about eyebrows that I mentioned, is that not facial hair? Most plants allow mustaches, why, it is facial hair. How about the hair on a persons hands, knuckle hair :-)? 

Getting back to my original question, will SQF allow for a policy that has a criteria built into it; as in the .25" or eyebrow length beard, it is pretty hard, not impossible, but pretty unrealistic to make someone cover their eyebrows.

I am beginning to think this is just a feel good aesthetic Band-Aid that in reality has more unintended consequences than what it achieves. 

You make fine points, and SQF is written in such a way to make sure you decide how to handle it. 

11.3.3 Clothing and Personal Effects

11.3.3.1 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.

They go so far as to specifically require hair and beard nets:

11.4.1.2 Personnel working in or visiting food handling or processing operations shall ensure that:

iii. Hair restraints and beard covers, where applicable, shall be used in areas where product is exposed.

Arm and hand hair?  My GMPs require long sleeved smocks and gloves because auditors called out arm hair concerns.  Eyebrow hair is hair, but until we have an effective and safe way to control it without blocking an employee's vision, there isn't much that can be done.  The code prohibits things like false eyelashes due to the risk they present (chemical and physical), but we can't fully control actual eyelashes falling out very well, can we?

All of these steps are to mitigate the hazards to the best of our abilities, but they aren't fool proof 100% preventative measures.

I'll end with a reminder of SQF's makeshift motto:  "Say what you do; Do what you say."  If you say you are going to maintain .25" beards don't meet the requirement for a beard net, then your SQF auditor will be free to ask you how you monitor that specific limit you've set, heck even ask you for validation on that critical limit.  Are you prepared to show documents where you've measured employee facial hair?  If they decide to bring a ruler out into the area during an audit, are you prepared to take a minor for violation of your own program when an employee's stray whisker measures .3"?

Again, I'm not arguing with your points.  We've all been in your shoes and looked to justify what we do.  For me, the solution is clean shaven or wear a beard net.  If you want to run with your measured limit, go for it and let us know how it works out for you.

I would not get into having to take measurements - this gets old real fast.

We use full mesh hoods - no issue with the beard nets remaining in place, covers everything.

"Say what you do, do what you say"  Cowboy up and put it in your policy and enforce it!  SQF will be fine with it being .25 and you can monitor all you like.  I got tired of fighting on the subject and we do just clean shaven or beard guard.  Your fight, your problem...your solution.  As long as it's in your policy and you are enforcing it you should be just fine.  I did loose a point for .25 length for one of my employees the Auditor thought should have worn a beard guard.  That's why we went clean shaven or beard guard.  You can still be challenged by an Auditor like we were.  You can be right all you want and still someone could challenge you.  Be prepared to defend what you choose with validation. 

Thank you, as mentioned in my original post, the hands to the face, as witnessed by myself and the FSIS inspector is a real issue with a beard net and I think we all need to be cognoscente of it. To simply implement a beard net policy and disregard the consequences of it accomplishes nothing and actually creates a greater food safety issue than what we are trying to control. Again, the rule of unintended consequences applies here.

at the end of the day the aim is to avoid any contamination like hair in food - how do you teach your employees that ,25" is no hair ? Imaging you have it in your meal what do you think - do you like it? That is the same as already mentioned with hairs resulting from arms.

T-Shirts allowed or not - do you like drops of sweat in your food? 

it is not about pleasant working conditions - it is about safe food for human nutrition.