Wrist Braces - Ready to Eat Food Manufacturing

Hey Everyone!

We've run into a discrepancy between how this is being handled at two of our facilities - specifically allowance or not for personnel to wear wrist braces into food production areas. I wanted to see if anyone had experience or guidance they've used to either allow or deny the use of wrist braces in food production as reasonable accommodation. 

We make refrigerated ready-to-eat foods as well as more shelf-stable baked goods in different areas of our operation. One facility does not allow wrist braces as the brace cannot be effectively cleaned, and as such the hands cannot be effectively cleaned. 

The other facility currently does allow wrist braces as long as they're removed for hand washing. 

The issue our FSQA team is trying to tackle - how can we ensure the brace themselves are clean (we can't) and even if they remove to wash hands, their hands become 'recontaminated' once they don the brace again. Operations is in the camp of 'they can just cover with a glove (or similar). However this seems, from a micro standpoint, to be an even more likely vector for contamination - especially in our higher-risk refrigerated RTE areas. 

Hoping for any insight, as it's hard to find specifics for food manufacturing vs. retail. 

Thanks in advance!

-CT

Let's go to the root first - why are people wearing these devices to begin with???

Let's go to the root first - why are people wearing these devices to begin with???

At the facility where they're being worn is our older facility, so there are more tenured team members there who need the braces for a variety of reasons. I imagine it could be some work-related and some non-work related. 

We allow this for medical reasons only and only with a glove overlay.  The employee is required to provide a statement from physical or occupation therapist or doctor to the employment office and an "approved" brace is supplied by the company that stays at the facility.

Put that into practice and very soon nobody will be wearing them anymore. 

I would require them to have a doctor's note then wear a glove over it. 

I had to wear a finger splint for a few weeks. It was covered by a doctor's note. We've had similar issues with other employees. I don't even think we cover it specifically in our policy. More a generic statement about bandages and coverings. 

Many times braces are given by doctor's for individuals to wear for various medical reasons. They most likely wear them outside of work, owned by the person and fitted to there hand/wrist. This would make it hard for your facility to keep them and supply them. 

Yeah I don't like it..  Even removing the brace for handwashing, as soon as hands are washed they're going to grab the dirty brace with both hands and put it on which fully negates the handwashing.  Covering with a glove seems reasonable to me, but at best it'll be open to an auditor's interpretation which can go either way and at worst is legitimately a micro hazard.

In your shoes, I think I'd require a doctor's note for the braces and move employees who need one into the storage areas so they're not handling open product.

Beyond SQFconsultant's comments in post #4 above, I would add that "reasonable accommodation" can also mean moving them to a position that does not require sanitary contact.

Wrist braces should be covered.

Make sure you understand the OSHA rules for your location as you may get yourself in hot water quickly

That being said, you should relocate said employees to positions that do not require as stringent controls as a ready to eat vs your baked goods side

In my opinion, jewellery should not be worn in any food operations and sure not at a RTE High Risk environment.
How did you document this in yourt HACCP or HARPC study?

In my opinion, jewellery should not be worn in any food operations and sure not at a RTE High Risk environment.
How did you document this in yourt HACCP or HARPC study?

The post wasn't referring to jewelry but a brace that someone may wear for like carpal tunnel or after breaking a wrist. (I can see where the confusion is. Brace is similar to bracelet)

Doctor's note for necessity of the brace, which needs to have the estimated duration of the treatment, and always covered by a glove. Check recommendations for supplying the brace but that seems like a difficult proposition given the different types of braces. Also, if it was me, I wouldn't wear a brace anyone else had already worn! Reasonable accommodation is one consideration but talk with your insurance provider also for their recommendations. They'll likely want that employee BTW immediately so if there is another lower risk position they could take you'll want to put them there as long as necessary. We typically put employees with certain restrictions on peripheral cleaning tasks (storage areas, racks, floors under equipment, corners, machine frames, etc.).