6 replies to this topic

[AtomicDancer]

We are SQF certified, and I was asked about bone conduction earbuds, wrap around style and if they can be worn on the production floor. 

 

We don't allow ear buds for 2 reasons

1. We have forklifts and headphones/earbuds reduce your ability to hear your surroundings

2. Foreign material risk. 

 

I was asked to look into allowing the bone conduction earbuds, wrap around style, because this would allow employees to listen to their own music, retain area awareness, and encourage making phone calls to other team members instead of texting. The wrap around style is unlikely to fall off the head into the product. 

    Note: We currently discourage phone use on the production floor, but don't have a radio system at this time. That is a different discussion. 

 

What are your thoughts on the bone conduction earbuds if they are the wrap around style in production areas/GMP zones?  

 

[TimG]

My thoughts?

We don't allow ear buds for 2 reasons

1. We have forklifts and headphones/earbuds reduce your ability to hear your surroundings

Bone induction is no better or negligibly better in this regard. I have several people who use them in the office, and they still have to take them off to have a discussion.

2. Foreign material risk. 

You have no less FM risk from bone induction. It's still plastic bits with wiring.

 

You already have a risk analysis that says no and the reasons you say no aren't going to be negated by going bone induction.

You could possibly re-assess your total RA and allow ear buds. I did it. We now allow them as long as ONE ear is free (for the safety/forklift) and they are inside the hairnet completely (hairnet must completely cover the ear bud/ear.

 

Saying that, I wish I didn't do it. I've regret it several times, as there are always employees who push those boundaries or can't handle the little bit of extra freedom. Oh yes Mr. Skidder, I wonder why your box code miscode #'s are up when I come out and watch you glued to your phone watching a movie (absolutely NOT allowed) while you're skidding and supposed to be checking boxes. Oh, hey forklift driver who I noticed has been breaking pallets and running into stuff constantly, I came to talk to you and watched you talking at full volume holding a 5-minute conversation while on the forklift MOVING PALLETS and you didn't see me here for 5 minutes watching you. Oh what's that, you weren't on the phone you were just talking to yourself? Right...

 

Give em an inch, you will lose a mile. Sorry..I might be a bit jaded on this one.

[kconf]

If you want to inspect everyone's earbuds everyday, sanitize, document records, do risk analysis, add to brittle plastic items audit, etc.  then go ahead. 

[Setanta]

Nope. TimG and kconf encapsulated it all.

[GMO]

God no.  Agree with all of the above.  Even before you get to the food safety risks there is a distraction risk. Even with hands free in cars, which is a pretty similar application, no restriction in what you can hear (you can still hear car horns etc) you are more likely to be in an accident due to the cognitive distraction.

 

Here's a link for you: Mobile phone use while driving | Brake

 

Any additional sound also consider what that does to overall loading. I assume that's still an issue with bone conducting as you still effectively "hear". What I mean is you might not need hearing protection without them but they would push the overall sound over the Db limit. Might not be the case in the US but in the UK there are frequent and expensive cases of hearing loss. It would be a pain if you company has to pay out due to hearing loss which was more to do with their own choices.

 

Also to bring in something not suggested by others, I think headphones limit interaction with others. Even if you are wearing hearing protection, the lack of distraction of a call or music means there is going to be less interaction between people. That has safety implications but also implications for wellbeing, cooperation, support for each other. All that soft stuff that's hard to measure but REALLY important to how people hear about work.

 

Lastly it's not just the headphones but if you have them you'll also have phones on people and then you'll have people messing with screens they are also using when they're sat on the toilet (you know they do it) so you have additional foreign body and micro risks from then AS WELL AS the fact that given 5 minutes they'll be playing candy crush rather than monitoring the production line...

 

So in SOOOOO many ways I'd say no.

[jfrey123]

I can hear it all now:  "If we allow earbuds covered with a hairnet, why do I have to take off my earrings if I can cover them with a hairnet?"  "I can't afford the expensive bone conducting earbuds, you should just let me wear my regular ones."  "I can't afford wireless earbuds, why can't I use these corded ones?"  It's a slippery slope of "if this, then that" and not a door I'd be willing to open myself to for ALL of the reasons cited above.

 

You also mentioned you think a wraparound style is "...unlikely to fall off the head into the product", so that's suggesting to me you're being asked to allow them in active production over open food.  Do you really want QA staff to be policing people who want to switch their music on the production line, handling the buds or the phone with now dirty hands?  Do you want to justify allowing it for non-production staff while excluding production staff from the privilege?

 

If they won't accept logic, you can point to the SQF code broadly prohibiting unsecured personal items that could fall into open food (11.3.3.8).  If they want to risk it with SQF, you can remind them CFR's prohibits personal items that could fall into food, equipment or containers (117.10(b)(4)) and requires all personal belongings to be stored away from product or equipment washing areas (117.10(b)(7)).

[AtomicDancer]

Thanks everyone. These are the same concerns I have with them.
Knowing others in the industry also have the same concerns helps my argument they shouldn't be in production.

I also appreciate hearing from people who have RA'd and approved them, and regret doing so.

I had not thought about the hard/brittle plastic in production aspect either. :)