Allergen risk assessment and validation for allergen transfer to uniforms

Wondering if anyone out there can guide me with how to address an audit finding regarding allergens and uniforms.  We are a low risk manufacturing facility where we allow our employees to wear their uniforms in the break rooms.  The finding stated "The site has not conducted a risk assessment for the control of hazards associated with allergens and incorporated it into the food safety plan."  

How do you demonstrate that allergens from employee lunches are not being transferred to their uniforms?  

Looking for alternatives to disposable smocks and having employees change their uniforms for each break.

Any guidance would be appreciated.

KZ

Why are you low risk. It is an enclosed system, etc.? 

What is the uniform at the moment

It is mainly a closed system.  We do have a few employees who load bags onto a screen and slice open the bags to feed into a hopper, but the majority of our employees are dealing with product in a closed system with no direct contact.

Uniforms are issued by the company and include shirts and pants for production employees and lab coats for QA and management.

Where do the employees put their shirt and pants when they use the restroom?  :uhm:   Why a shirt and pants instead of a smock or lab type coat?

I get that the system is pretty much enclosed, though you have an open hopper feeding the system like most and that means the risk of dropping allergens or other FM is not zero.  Every operation I've worked for used smocks for employees, providing a place to hang the smock when using the restroom or taking a break, and requiring the smock to be exchanged for a clean one anytime it became soiled.  The maintenance guys sometimes get coveralls but then still have to wear a clean smock over them if they enter the active production areas.

The barrier should be a smock/lab coat that is removed and stuck on a hook outside the breakroom or restroom and then put back on again.

You could different colored ones to distinguish between QA, owners, production employees, maintenance, etc.

The gig of course was for not having a risk based plan in place - did the Auditor also indicate the breakroom as being the issue as it was not a part of the entered finding by the Auditor?

I agree with PP on the smocks

It's either that or you limit allergens allowed in the facility

Do you currently process product with allergens?

The only time I have seen a uniform being worn in a breakroom is in distribution centers, where they do not handle any open exposed products, all completely sealed.  You have an area where there is an open source or potential contamination and cross contact.  A proper risk assessment of the process should identify the risks involved ate ach processing step.  I also agree with the restroom aspect, your staff are wearing the same clothing all day and using the restroom.  Sound like as others have stated you implement a uniform that can be removed prior to breaks and restroom usage to reduce the risk.  

If you're allowing the PPE to be worn in the breakroom and restroom, then it is only functioning to protect the employee, not the product.

PPE that protects the product cannot be allowed to come into contact with contaminants, and that includes unrestricted consumables (ie lunch).

Thanks all for the feedback.

For those who work in low risk food manufacturing facilities, do your employees change out of their uniform pants and tops for each break?  Or perhaps most of you just use lab coats as the uniform that can be easily removed?  

Has anyone out there who does allow their employees to wear uniforms in the break room, ever completed random swabbing of employee uniforms for allergens to determine if allergen transfer does occur during breaks?   

It sounds as though we need to consider a different type of uniform to address this issue.

Appreciate your thoughts and advice.

I have worked in low risk and high care production facilities.  I agree with the above, the vast majority of low risk manufacturing now has a lab coat style PPE which is removed and hung up before going into a rest or break room.  The odd one will have a jacket for similar.  Rarely (and bad practice in my opinion) you will have no removal of clothing but this is in processes where there is minimal contact with the food (e.g. in beverages) and I have seen it challenged.

You could consider other options but they're probably all much more difficult than changing your uniform.  For example, excluding certain allergens on site, having additional PPE in the areas where open food is processed but compliance with both will be harder in my view.

You can often hire PPE in the UK (and I assume other countries too) which might reduce initial outlay.

Hi - our production staff wear tops / pants and QA & Management wear coats.  Tops and coats are removed to eat and placed in dedicated area / dedicated hooks.  Risk assessment for allowing pants in lunch room includes food crumbs likely to fall off pants when person stands, no open product areas below waist height, etc. Controls listed to re-enter production after breaks.