SQF Food Packaging and false Nails

Hello all:

Recently the women in the facility have approached me and asked if I would do a risk assessment on false fingernails (to include nail polish) for them. They are willing to wear gloves in our laminate converting facility if they have nails. I am inclined to deny this even though I, myself would love to have my nails done. I just don't want the added risk and additional monitoring. On the other hand, in this competitive work environment it is also essential to keep employees happy and if I could do this small thing for them, it would go a long way.

At this time, we do mostly pet food bags but that could change at any time and we could easily be doing human food bags for meat products. I know that there are packaging facilities that allow gloves over false nails, and I would love to hear your insight. I would like to know what type of gloves you use and something about your glove program. Our safety department is fine with this idea so at this point it comes down to my risk assessment. Any insight will be helpful.

Thanks in advance.

If you really want to do this, then move forward with the risk analysis.

Find out from these other packaging suppliers that are allowing it. What do they make? What is their risk?

Why are they allowing it? 

How do they monitor it?
Are they GFSI certified? 

Do you produce for anyone who has this specifically in their rules? Costco comes to mind...but I am not sure they prohibit it off the top of my head.

Worse case scenario, what would happen if you were to allow gloves to cover false nails? Is your senior management OK with this risk?

I decided to pull the code before speaking out of my rear, and was surprised to learn that the prohibition on false fingernails or nail polish in SQF Food Manufacturing code is not extended to the Packaging code.  From that standpoint, allowing them to wear the nails with gloves is defendable depending on your RA.

I can see a gray area under 21 CFR 110.10(b)(4) that an auditor might want to drag you into.  It's specifically the jewelry requirement for hands and it does call out "other objects".  But 21 CFR 110 also doesn't specifically prohibit nails or polish...

(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.