12 replies to this topic

[Annab]

Hi everyone,

 

someone could you be so gentle to explain or share a risk analysis example that shows hair covering (and beard) is required or not required in packaging industry.

 

More in detail, industry that produces packaging material for food and not food sector.

Is it possible to wear hair/beard covering just during food packaging production and allow their removal in the caise the operator sre produtiong packagin for cosmetics or parapharmacy sector?

 

Thanks for your feedback

[MDaleDDF]

You're opening a can of worms imho.   It would be much easier just to wear them and call it a day.    In the end, how is your risk analysis going to guarantee a hair from another day of production isn't still hanging around on a food production day?    It can't.   Soooooooo.......

[Annab]

You're opening a can of worms imho.   It would be much easier just to wear them and call it a day.    In the end, how is your risk analysis going to guarantee a hair from another day of production isn't still hanging around on a food production day?    It can't.   Soooooooo.......

You're right! However, what about a risk analysis that demonstrates hair and beard coverings are not required in certain production areas (even if not formally separated), based on the operators' roles and the specific activities they perform?

 

For example, in the packaging area, where operators are mostly seated and involved in packing items such as notepads, brochures, and diaries.

Thank you for your reply.

[GMO]

Your main question to answer (irrespective on whether it's packaging for food or cosmetics) is whether the packaging will be directly touching the food or cosmetic?  If so, yes you need hair coverings.  Personally I think cosmetics and pharmaceuticals are going to demand the same standards so I don't see that as a valid reason anyway but even if it was, as MDale said, it's just going to be a nightmare to control.  

[Tony-C]

Hi Annab,

 

This is always an interesting debate  

 

My question would be which of your customers would be happy receiving product contaminated with hair?

 

Kind regards,

 

Tony

[Annab]

Hi Annab,

 

This is always an interesting debate  

 

My question would be which of your customers would be happy receiving product contaminated with hair?

 

Kind regards,

 

Tony

Hi Tony,

ahaha, I think none, obviously! 

Fortunately, based on our analysis, foreign bodies are not a significant issue in our non-conformities.

The packaging area—where operators are mostly seated and involved in packing items such as notepads, brochures, and diaries—is not formally separated. However, it is located on the opposite side of the printing area (which is our only internal production process,of cardboard for food, as die-cutting, folding, and gluing of the finished product are outsourced).

Therefore, the risk of cross-contamination between these areas is unlikly.

For this reason, I believe it would be reasonable to conduct a risk analysis to potentially exclude one of the packaging areas from the requirement to wear hair covering.

 

Sorry, I didn’t mean to write a whole essay 

[TimG]

I've been kicking around the idea of removing requirement for hair/beard nets in my box making area. It's nowhere near processing or bottling. We're taking boxes and taping them and stacking them on pallets to be taken out to the end of the line. The boxes never come in contact with open jars.

But I KNOW if I make this change, there are going to be hidden risks/repercussions that I didn't think through. What happens when the line runner (person that comes and picks boxes up and takes it through the plant into the bottling room) 'forgets' that he has to wear one in the bottling room because he spent the last 2 hours helping by building boxes and then got called to run to the line?

 

I got into compliance because I hate stupid rules and wanted to change them. But I find out more and more when you do that, people will find a way to still screw it up.

[Scampi]

"I got into compliance because I hate stupid rules and wanted to change them. But I find out more and more when you do that, people will find a way to still screw it up."

 

Slippery slopes are best left alone for this very reason!

[Annab]

I've been kicking around the idea of removing requirement for hair/beard nets in my box making area. It's nowhere near processing or bottling. We're taking boxes and taping them and stacking them on pallets to be taken out to the end of the line. The boxes never come in contact with open jars.

But I KNOW if I make this change, there are going to be hidden risks/repercussions that I didn't think through. What happens when the line runner (person that comes and picks boxes up and takes it through the plant into the bottling room) 'forgets' that he has to wear one in the bottling room because he spent the last 2 hours helping by building boxes and then got called to run to the line?

 

I got into compliance because I hate stupid rules and wanted to change them. But I find out more and more when you do that, people will find a way to still screw it up.

 

Hi TimG,

I hate stupid rules too...

 

I think this might be a similar case (where the operator needs to remind the rule):

 

A small plant with a tasting room inside the production area. The operator who cooks and tests the food needs to leave the tasting room and enter the production area to collect samples. In the tasting room, hair and beard nets might not be required, but they are once you enter production.

A simple fix could be placing a net dispenser at the production/tasting room entrance to remind staff of the requirement.

It’s up to the QM or PM to make sure these rules are followed.

 

What do you think?

[MDaleDDF]

Nets should be required in the tasting room.   It's inside production.

I honestly don't see why everyone wants to bite back at this rule so badly.... Seems it's a constant area of discussion on here.    And generally the thought seems to be :    I don't want nets, so I'll draw up a HA that shows I'm in the right, instead of:   I'll do a HA and decide if nets are needed.

 

A hazard analysis is not supposed to support a predetermined wish, done correctly it informs in impartially about whether something is a risk and needs controlled.   If you perform one honestly, I don't see you not using nets....  My two cents.   I'm out, the horse has been led to the water, lol....

[MDaleDDF]

"I got into compliance because I hate stupid rules and wanted to change them. But I find out more and more when you do that, people will find a way to still screw it up."

 

Slippery slopes are best left alone for this very reason!

My folks figure out how to screw things up even if I DON"T want to change rules.....lol.

I agree with Scampi.  

[jfrey123]

You mention a tasting room:  are you producing actual food items and then packaging them, or is this an operation where you're taking prepackaged food and repacking it into boxes?  (Like a food distribution operation).  If there's open food in your production room, the use of hairnets only during food production is a hard no, and honestly, it's the least of your concerns when it comes to an entire side operation of non-food packing being done a few feet away.

[Annab]

Nets should be required in the tasting room.   It's inside production.

I honestly don't see why everyone wants to bite back at this rule so badly.... Seems it's a constant area of discussion on here.    And generally the thought seems to be :    I don't want nets, so I'll draw up a HA that shows I'm in the right, instead of:   I'll do a HA and decide if nets are needed.

 

A hazard analysis is not supposed to support a predetermined wish, done correctly it informs in impartially about whether something is a risk and needs controlled.   If you perform one honestly, I don't see you not using nets....  My two cents.   I'm out, the horse has been led to the water, lol....

 

"A hazard analysis is not supposed to support a predetermined wish, done correctly it informs in impartially about whether something is a risk and needs controlled."

 

Exactly, that's the point! 

 

Would anyone be willing to share part of their risk analysis on the foreing bodies from personnel? Where the preventive action is the use of hair/beard nets to minimize the risk? (Preferably from packaging industry)

Thanks! Thanks!