15 replies to this topic

[kyrabowden]

Hey all,

 

We're in the process of updating our jewellery policy to SQF standards:

 

11.3.3.8: Jewelry and other loose objects shall not be worn or taken into a food handling or processing operation or into any area where food is exposed. Wearing plain bands with no stones, prescribed medical alert bracelets, or jewelry accepted for religious or cultural reasons can be permitted, provided these items are properly covered and do not pose a food safety risk.

All exceptions shall meet regulatory and customer requirements and shall be subject to a risk assessment and evidence of ongoing risk management.

 

We want to have an exception for wearing plain bands with no stones so they don't have to be covered. Does anyone have feedback on how we could conduct the risk assessment, and the "on-going risk management"? Or anybody think we should just have it covered with no exception?

 

Thanks!

[Brothbro]

As far as I've seen SQF facilities that allowed wedding bands also required that workers wear gloves so the ring is covered. This reduces the risk of the ring falling off into food/equipment while workers are doing stuff on the line. Do your workers not wear gloves?

[jfrey123]

Are you thinking of risk assessing no glove when wearing the plain band?  You could certainly try, but I think SQF code specifically calling out that the band must be covered presents an uphill battle for justifying it to an auditor.  The band itself is a food safety hazard should it fall off the finger and into product or equipment (such as a grinder or blender).  If you have any bulk mixing or grinding going on at your plant, it'd be really crappy to have to put a whole batch on hold because someone lost their ring in it.

[Scampi]

It really depends on your finished good, and how easily it could (or not) fall into the product

 

If you're running an enclosed process with very little human handling, a risk assessment would suffice (we allow all jewelry where I am (BTW not my choice))  and we've had no issues from SQF or CFIA due to the nature of our product

[G M]

Hey all,

 

We're in the process of updating our jewellery policy to SQF standards:

 

11.3.3.8: Jewelry and other loose objects shall not be worn or taken into a food handling or processing operation or into any area where food is exposed. Wearing plain bands with no stones, prescribed medical alert bracelets, or jewelry accepted for religious or cultural reasons can be permitted, provided these items are properly covered and do not pose a food safety risk.

All exceptions shall meet regulatory and customer requirements and shall be subject to a risk assessment and evidence of ongoing risk management.

 

We want to have an exception for wearing plain bands with no stones so they don't have to be covered. Does anyone have feedback on how we could conduct the risk assessment, and the "on-going risk management"? Or anybody think we should just have it covered with no exception?

 

Thanks!

 

 

If they aren't removed they're covered, that has always been our policy.   

 

Even medical alert bracelets or necklaces are expected to be restrained underneath garments.

[kyrabowden]

Thank you everyone for the feedback! Much appreciated and it helps in my decision making over here. 

[kyrabowden]

As far as I've seen SQF facilities that allowed wedding bands also required that workers wear gloves so the ring is covered. This reduces the risk of the ring falling off into food/equipment while workers are doing stuff on the line. Do your workers not wear gloves?

 

The production staff where gloves only when directly touching food. Otherwise handwashing GMP's apply

[MDaleDDF]

We don't even allow gloves anymore, unless it's a special reason, and jewelry isn't a special reason.   We had to sift too many batches to remove metal detectable glove pieces.    So we're 100% no jewelry, other than medic alert.  

It's just easier.    Otherwise people sneak in something with a stone in it, but accident (or not), etc etc etc etc.

[kyrabowden]

We don't even allow gloves anymore, unless it's a special reason, and jewelry isn't a special reason.   We had to sift too many batches to remove metal detectable glove pieces.    So we're 100% no jewelry, other than medic alert.  

It's just easier.    Otherwise people sneak in something with a stone in it, but accident (or not), etc etc etc etc.

 

This has always been my concern with gloves (unless directly touching food, they wear gloves). That and people washing their hands less. Personally I would like a 100% no jewellery policy, however some of our workers have wedding bands that they say won't come off. Makes it trickier when you want to work with the employees but still have to put these policies in place. 

[Miss Frankie]

Every place I've worked at allowed plain bands.  Prior to the last place, I was able to wear my wedding ring with stones, due to this from the FDA. 
I'd just tell an auditor that my ring wouldn't come off and I put a glove after washing my hands upon entering the facility.  The last place I worked didn't care about this FDA policy so I had to have my ring cut off. 

 

(4) Removing all unsecured jewelry and other objects that might fall into food, equipment, or containers, and removing hand jewelry that cannot be adequately sanitized during periods in which food is manipulated by hand. If such hand jewelry cannot be removed, it may be covered by material which can be maintained in an intact, clean, and sanitary condition and which effectively protects against the contamination by these objects of the food, food-contact surfaces, or food-packaging materials.

[AltonBrownFanClub]

 

(4) Removing all unsecured jewelry and other objects that might fall into food, equipment, or containers, and removing hand jewelry that cannot be adequately sanitized during periods in which food is manipulated by hand. If such hand jewelry cannot be removed, it may be covered by material which can be maintained in an intact, clean, and sanitary condition and which effectively protects against the contamination by these objects of the food, food-contact surfaces, or food-packaging materials.

 

This excerpt can be found in 21 CFR 117.10 (b)(4)

https://www.accessda...h.cfm?fr=117.10

 

I keep a copy in my audit binder because, unfortunately, I am required to have this fight. We allow jewelry.

[mgourley]

Sometimes these "requirements" just become silly, and it all depends on your product risk.
I don't see the issue with plain rings. This is why metal detection has become a de facto CCP.

If someones ring comes off and is included in finished product, one would hope your metal detector/X-ray or whatever would detect and reject it.
Now, if you are in a facility that does not have a process "kill step" and people are handling materials whereby a plain ring is harboring bacteria, I would posit that your peoples hygiene is the problem...not the ring.

There is a reason that all major food safety standards include some mention of "risk assessment" or similar verbiage.

 

Marshall

Edited by mgourley, 19 April 2024 - 01:41 AM.

[kyrabowden]

Sometimes these "requirements" just become silly, and it all depends on your product risk.
I don't see the issue with plain rings. This is why metal detection has become a de facto CCP.

If someones ring comes off and is included in finished product, one would hope your metal detector/X-ray or whatever would detect and reject it.
Now, if you are in a facility that does not have a process "kill step" and people are handling materials whereby a plain ring is harboring bacteria, I would posit that your peoples hygiene is the problem...not the ring.

There is a reason that all major food safety standards include some mention of "risk assessment" or similar verbiage.

 

Marshall

 

Good point, makes it a bit more challenging for us because we don't use metal detection. We use pre-operational inspection in place of an x-ray/metal detector

[Scotty_SQF]

What of the surge in silicone wedding bands?  Playing devils advocate here, but those are becoming quite popular, so if those would fall of, I'm not sure metal detector would pick that up.

 

Risk assessment is key for anyone.  If there is a risk or concern there, then don't allow them.  If risk is minimal than allow them and ensure you can support this.  Also consult with your workplace safety person...I've worked for placed that wedding bands were not allowed due to workplace safety concerns, so then that makes things easier for you.

[cookinmaple]

however some of our workers have wedding bands that they say won't come off. 

 I hate this excuse/argument to my core. 

 

 

I personally 100% ban all jewelry. The video above is in my GMP training to demonstrate that ALL rings can come off.

 

 

I have seen someone's hand get caught in equipment because of jewelry. 

 

Both Quality and Health & Safety concern. 

Edited by cookinmaple, 22 April 2024 - 07:12 PM.

[ChristinaK]

My 2 previous places, we allowed plain wedding bands only if they were covered with a metal-detectable blue bandage. Solves the silicone or non-detectable metal issue, and also worked as a prohibitive measure against anyone "sneaking in" a ring with a stone (afraid of the bandage adhesive loosening or damaging the stone).