12 replies to this topic

[clrmwebb4350]

Good day everyone,

The subject of piercings has risen it's ugly head again. Our current procedure states, " Removeable jewelry and other loose objects including bracelets, watches, or earrings are not to be worn or taken into the food packaging production areas.

 

No removeable jewelry is to be worn above the waist in food packaging production areas. Piercings that cannot be removed and contain a captive bead ring or similar closure that secures the piercing from falling out, are acceptable". We have also allowed Daith piercings with a doctor's note.

 

The problem is how to determine if a piercing meets this criteria. We are a food packaging company and are low risk. Has anyone successfully completed a risk assessment and audit that allows face jewelry in a food packaging plant? 

 

 

 

Thanks in advance for the input. I know everyone is struggling with retaining employees. With today's culture most people have some sort of piercing so this is hard. Many face and ear piercings cannot be removed except by a professional. 

[GMO]

I just don't allow it.  Never have done.  No plasters over the top, just remove it.  This is the industry you work in.  Accept it or go elsewhere.

[Scampi]

I agree with GMO   slippery slope etc

[TimG]

I inherited a program where they allow piercings that can't be removed to be covered by a high vis covering (we provide blue bandaids). I wish I was there at the start to say flat out no right from the beginning. It's a bigger hassle than it should be and it's just for 3-4 people who have piercings they claim can't be removed.

It's been a headache..but ownership is hesitant to go scorched earth as they consider it and remove them.

[kconf]

That's a viable option, Tim.

 

At our place we do not have anyone with jewelry that can't be removed. 

[TimG]

Just because sometimes it's good to see the rules (also, the SQF code below is for manufacturing. Might be different for packaging):

FDA

SUBPART B – CURRENT GOOD MANUFACTURING PRACTICE §117.10 Personnel

 

(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.

 

SQF

 

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.

[Bo16]

FDA 21 CFR 117.10(b)(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.

 

We require coverage if the jewelry cannot be removed.

[clrmwebb4350]

Thanks for all the replies. I decided to keep out policy as is and not make waves. I do have a question though, several people quoted,  "FDA 21 CFR 117.10(b)(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".

 

Isn't this for FOOD production not food Packaging?  Also, how do restaurants in particular fast food restaurants get away with letting their employees have piercing's?

[GMO]

Isn't this for FOOD production not food Packaging?  Also, how do restaurants in particular fast food restaurants get away with letting their employees have piercing's?

 

Oh now this is a slippery slope that people in food manufacturing can't understand. It's the lack of hair coverings as well.  Along with often appalling sink location and provision for hand washing.

Put it this way, UK at least, you're far more likely to get food poisoning or an allergic reaction from a restaurant than a food factory.  Compliance (even for the rules they have) are poor but the rules they have are lax.

[Hoosiersmoker]

FDA doesn't involve themselves with packaging (yet) as it's not food or drugs. It's easy to cover all your bases and make the rule one that's actually enforceable. Our rule states "No visible piercings". All visible piercings must be removed unless the employee has a note from their doctor for a Daith piercing. That's it. We don't buy into the "I can't remove it" argument, there really is no such thing. If you include piercings that you don't actually want to look for, you've created an unenforceable rule and grey area unnecessarily. I personally DO NOT want to know about or police any piercings I can't see, nor would I be able to check legally (Nipple piercings LEAP to mind. Male or female). Make sure your RA  proves this out, which it should for very low risk packaging manufacturing.

[GMO]

 I personally DO NOT want to know about or police any piercings I can't see, nor would I be able to check legally.

 

Put it this way.  One operator told me he couldn't stand too close to the metal detector.  The piercing is named after the late Queen Victoria's husband.  DO NOT google that at work...

[TimG]

I guess I always assumed food contact packaging followed cGMP's. I know a few of my food contact package supplies have a GMP statement, but maybe they just follow them even though they aren't enforceable by FDA for them?

Do food package manufacturers need any state health certs? Sorry, this is a bit off track..I just realized I don't know much about the food contact packaging regulatory world.

[Hoosiersmoker]

I guess I always assumed food contact packaging followed cGMP's. I know a few of my food contact package supplies have a GMP statement, but maybe they just follow them even though they aren't enforceable by FDA for them?

Do food package manufacturers need any state health certs? Sorry, this is a bit off track..I just realized I don't know much about the food contact packaging regulatory world.

As a certified SQF Manufacture of Food Packaging facility we follow GMPs including hair nets in our critical processing areas. We treat our packaging as if food was actually going to touch it (because it is!) and take measures to ensure the cleanest possible products for our customers. We received 100% Food Safety and Quality scores for our certifications last year. The FDA only regulates to Food and Drugs so we're not really on their radar.