4 replies to this topic

[Rassmutten]

I am fully aware of what 13.3.3.5 says about gloves and what 13.3.3.6 says about "other loose objects" and wearing plain bands. My question is if I do a detailed risk assessment, and our customers have no issues with this policy change do you think an auditor would still ding us for allowing our production staff to wear nail gel and or possibly false nails. We have a robust glove policy now. 

 

Normally I would not even look into this, topic but we all know how hard it is to get and keep employees these days. We have no food in our plant. We manufacture food packaging. If we have the individuals that wear such accoutrements change gloves when needed, then there really should be no issue other than this is a slippery slope, and I do not abide a slippery slope well. 

 

Has anybody else had experience with this?

[KellyQA]

It can be tough to control. 

 

I have worked at a facility that had zero tolerance towards painted nails or fake nails. If you were caught with them, you would be sent home and were not able to return until the issue was corrected. I have also worked for a facility that, as long as you wore in tact gloves and follow proper hand washing, you are good.

 

Specifically for SQF Food Manufacturing, 11.4.1.2 ii "The wearing of false fingernails, false eyelashes, eyelash extensions, long nails, or fingernail polish is not permitted when handling exposed food."

 

A risk assessment for the use of intact gloves over the nails, should be sufficient enough for you. Employees who have fake or painted nails could also wear gloves, but be limited to non-exposed food handling. (or in your case, non-food contact packaging handling)

 

Personally, I think fake nails and nail polish should not be allowed in any facility. Gloves break all the time. Nails chip, and long nails damage gloves frequently. Long nails can harbor more bacteria and are harder to clean than natural nails. Gloves are not a replacement for handwashing and when gloves are damaged or contaminated, employees should be disposing the gloves, following the handwashing procedure after disposing the gloves, and then replace gloves. 

[kfromNE]

I am fully aware of what 13.3.3.5 says about gloves and what 13.3.3.6 says about "other loose objects" and wearing plain bands. My question is if I do a detailed risk assessment, and our customers have no issues with this policy change do you think an auditor would still ding us for allowing our production staff to wear nail gel and or possibly false nails. We have a robust glove policy now. 

 

Normally I would not even look into this, topic but we all know how hard it is to get and keep employees these days. We have no food in our plant. We manufacture food packaging. If we have the individuals that wear such accoutrements change gloves when needed, then there really should be no issue other than this is a slippery slope, and I do not abide a slippery slope well. 

 

Has anybody else had experience with this?

 

If the risk assessment is done right, an auditor shouldn't ding you. 

 

We manufacture food. I allow painted nails but not fake nails. This was done through an assessment. I don't love it but like you said, employees are hard to find. 

We can allow it because it's a cold environment so almost all employees wear cloth gloves (we provide and launder) then a disposable glove. 

So if a disposable glove were to break - the cloth glove would prevent contamination. 

[Setanta]

I think you gain a bit of leeway with the fact you are a packaging producer. 

 

With the right risk assessment, you could allow gloves to be worn over nail polish. I don't know that I would go so far as allowing fake nails, since that is a separate contamination hazard. 

[ChristinaK]

For me, it may vary depending on the type of food packaging you produce (for what type of food), and how it is handled by employees. For example, when I worked in packaging, we made bottles for pasteurized juice. Although we knew most of our customers pre-rinsed the bottles prior to filling, we still did not permit painted or false nails for anyone in production or QA. It wasn't necessarily high-risk for our product, but it could become so for our customers. Currently I'm working with gift sets that have pre-packaged food; our personnel practices allow nail polish and false nails because of the extreme low-risk.

 

So if you do allow nail polish, I would be sure to specify that nails cannot be longer than the fingertip. Shorter nails are less likely to break and easier to keep sanitary through handwashing. Long nails would require using something like a nail scrubber or brush, and then each person would need their own to prevent any kind of person-to-person (or nail-to-nail) contamination spread. Since false nails put on at home rather than in a salon are more likely to fall off, I wouldn't allow false nails at all. Including regular training, reminders, and strict enforcement of the glove policy may be additional steps to take. 

 

I don't think I have the file anymore, but I had previously made a couple of GMP posters/slides about the topic. One compared the cost of salon nails (real nails and acrylics) vs. cost of lost pay from being sent home for coming to work with false/painted nails and the second was about how long nails (fake or natural) harbor bacteria.