10 replies to this topic

[astro]

Hi

 

Just wanted to get your opinion regarding the wearing of earplugs.

 

I want to see if I am being to picky.... but for me it is all about reducing risk....

 

So here we go - I have been working for a food packaging printing company and I have been a pain in the butt i told all managers that they should be leading by example and stop pulling the cords out from the ear buds as this is a risk to contamination. The smart arse H&S coordinator said it has always been like this and no body has said anything so who is saying this which i replied me. They said they are metal detectable so it does not matter and if they fall out it will only be in the hairnet as we wear over our ears.

 

For me the cord is there for a reason.....

 

what's your opinions on this

[Setanta]

If they are truly, demonstrably metal detectable, I don't see an issue. 

BUT the individual ear buds must kick off your metal detector no matter how buried they are in your product. If you need the pair in order for it to register, no bueno.

[SQFconsultant]

Most times it is the cords that create the issue with safety - getting caught on things, etc.

 

A good quality ear plug will not fall out and if they did come loose the net would catch anyway.

[astro]

Thanks for your comments but we do not have metal detectors.

 

We are food contact packaging flexo printing.

 

My point is I would not want a ear bud to be laminated and go to a customer knowing we could of done more to minimise the risk by not removing the cord.

[astro]

I do have another point to make on this, when I have done GMP walks i do find the odd ear plug on the floor......

 

Which again for my point of view if the cord was still attached the risk would of been minimised.

[jfrey123]

Test that they're actually metal detectable in your machines, but honestly the H&S guy makes some valid points.  I've always kept them corded to let them hang around my neck for reuse, which beats shoving them in a gross pocket or discarding after each use.  If you notice the cut cords are ending up on the floor or tables around production during your GMP audits or walkthroughs, you can press the concern, but otherwise I'm not sure this would be worth the argument to me.

 

Edit - OP's extra replies came in while I was posting.  So you don't have MD's (making his point moot), and you are finding them on the floor.  Each one found stray is one that could've ended up in product, and since you're not MD'ing to control the hazard, now it's maybe worth the argument.  You could suggest switching employees to muffs if the earplugs can't be kept off the floor or wheverelse they're being found.

Edited by jfrey123, 28 March 2024 - 04:41 PM.

[GMO]

You know?  You're right, the cords are there for a reason.  The manufacturer doesn't add them just for fun.  I have to wonder at why anyone is bothering to remove the cords either?  I also have an allergic reaction to anyone who says "it's always been like this" and lastly, it's easier to see someone is wearing the damn things if there is a cord so I fail to see the H&S person's point.

But as I said on another post recently, "is this the hill you want to die on?"  If you end up with an ear plug in a product, yes, gross and will lead to a hugely embarrassing complaint but... It's not going to kill anyone.  If an auditor picks it up, again, well it's an independent pair of eyes saying the same thing (I'd probably raise it as a recommendation though if I'm honest.)

Sometimes as technical people we are prone to catastrophising.  I.e. thinking of the worst possible outcome.  After all it's our jobs isn't it?!  But with this, you've raised the risk, you've got a lukewarm response but this isn't like a food packaging company who had no HACCP plan who I audited once(!)  Oh AND dodgy calendars in the Engineering Workshop.  Not even joking.    

What you may be thinking though is "what does this say about leadership culture" and that's a valid thought but again, is this the issue that you'd judge that on?  It would perhaps make me more attuned to look out for evidence of leaders not following basic food safety controls and that's where I'd focus my attention if I'm honest.  For example, leaders not washing hands, allowing inappropriate equipment or chemical use or not wearing appropriate workwear to cover hair etc.  Absolutely that's where I'd lose my sh...  On this I think I'd roll my eyes and move on.

[Rick Reyes]

Good morning all, I don't know how many of you have actually taken the time to deconstruct the metal detectable ear plugs. As part of one of our risk assessments we did take the time to do this with two different styles of metal detectable ear plugs (foam type and silicone type). What we found was that the portion of the ear plugs that made them metal detectable was a metal sphere imbedded inside the shaft  of one silicone style, a metal band around the shaft of another silicone style, and a metal brad that was crimped onto the foam style of ear plug. In our assessment we looked at what would happen to the pieces of these ear plugs if they should come into a grinding, cutting, or forming equipment prior to the CCP Metal Detector, our conclusion was that the pieces would be small enough that they would not cause serious harm if consumed and would probably make it past the CCP Metal Detection since the pieces would definitely be separated from the metal they were fabricated with. While this would most certainly not cause a serious health concern it would definitely be a brand reputation hit to any company that would be difficult to explain to a customer who was purchasing our products. Again the issue comes back to making exceptions to GMP rules that weaken the foundations of what the intent is, to provide safe wholesome foods that a customer is confident in feeding to family and friends. I personally will stand by this rule. 

[Scotty_SQF]

You are in packaging, so I have to believe the risk is minimal.  Your concern is that it could get imbedded in the layers while laminating?  Then this would still not be a food safety risk as it is not on the food contact side.  Also I would feel if a plug fell out while printing/laminating you'd run the risk of causing an issue to the machine more than the product.  I would think the cords themselves would be a huge safety risk as it could get caught and could be pulled into a machine. Playing a little devils advocate here.

 

The likelihood of an actual ear plug getting imbedded in packaging is very very low.  I would think as long as you have proof they are purchased as metal detectable you should be good.  Look at the history, any customer complaints at all from an ear plug?  What would be the consequence of an ear plug being found?  I would think just an unhappy/annoyed customer, but not a genuine food safety concern with your product.  I would do a full on risk assessment and if you feel the risk is just too great then present it.  They do make non-disposable ways of hearing protection, ear muffs on bump caps, etc. that you could consider as well.

[G M]

...  I would think the cords themselves would be a huge safety risk as it could get caught and could be pulled into a machine. Playing a little devils advocate here. ...

 

Only after it pulls your hairnet off, and maybe rips your hair out.  The safety argument seems extremely weak.  If your earplugs are in so tight that a machine pulling the cord wouldn't just pull the plugs out then you're wearing them wrong.  Earplugs are no different than lanyards with credentials or pens, they pull away with minor effort.

 

I'm guessing these are the same people pulling snoods or masks down so they can talk (lots of people dislike something touching their lips, which have lots of pressure receptor nerves).  The real reason for the behavior is likely touch sensitivity (the cord is vaguely discomforting touching their neck), which is more important to them personally than GMP compliance and other peoples food safety.

[Scotty_SQF]

Only after it pulls your hairnet off, and maybe rips your hair out.  The safety argument seems extremely weak.  If your earplugs are in so tight that a machine pulling the cord wouldn't just pull the plugs out then you're wearing them wrong.  Earplugs are no different than lanyards with credentials or pens, they pull away with minor effort.

 

I'm guessing these are the same people pulling snoods or masks down so they can talk (lots of people dislike something touching their lips, which have lots of pressure receptor nerves).  The real reason for the behavior is likely touch sensitivity (the cord is vaguely discomforting touching their neck), which is more important to them personally than GMP compliance and other peoples food safety.

I never said it was strong, lol.  Just more of a risk in packaging than food safety IMO.