5 replies to this topic

[RAM86]

We had an unannounced BRC audit this week. The auditor noted a non-compliance issue regarding jewelry, specifically gauges worn in the ears of warehouse employees. Our GMP currently states that jewelry is only prohibited when handling food labels and packaging. However, the auditor indicated that jewelry is not allowed at any time, and covering it with a bandage is also not acceptable.

 

I am unsure why this has not been flagged by previous auditors, but it was raised during this audit. Can this requirement be addressed differently, or is jewelry truly prohibited at all times, regardless of the type of packaging being handled?

[TimG]

Did you look at the code they referenced? SQF has similar code but also says:

All exceptions shall meet regulatory and customer requirements and shall be subject to a risk assessment and evidence of ongoing risk management.

 

If BRC has wording allowing an exception, you need to follow what it says. If BRC does NOT have wording for exceptions, I think you're going to have to update your GMP to align with the FSQ scheme you're under.

[GMO]

Do you have the interpretation guideline?  I don't for the packaging standard but for the food standard which is normally aligned, it appears that there is some leeway where products are fully enclosed.

 

The only problem you might have though is if you have shared entry and exit areas as then it's not fully separate but if your warehouse is accessed differently then you might be able to argue that.  Although why didn't you when the auditor was still on site?  Now it feels a little late and you will probably struggle to have that non con removed.

[beautiophile]

Do you have the interpretation guideline?  I don't for the packaging standard but for the food standard which is normally aligned, it appears that there is some leeway where products are fully enclosed.

 

The only problem you might have though is if you have shared entry and exit areas as then it's not fully separate but if your warehouse is accessed differently then you might be able to argue that.  Although why didn't you when the auditor was still on site?  Now it feels a little late and you will probably struggle to have that non con removed.

The first two paragraphs of interpretation for BRCGS 6.2.1:

Sites must document a risk assessment to show it has considered the risk of product contamination from personnel practices dependent on the hazards posed to the intended use of the finished product. For example sites manufacturing products that are going to be used for food, feed, beverages, cosmetics, hygiene sensitive or pharmaceutical products are likely to require more stringent rules regarding personal hygiene than sites producing products for non-food or hygiene sensitive product contact.

This clause is designed to ensure that personal items are not a source of product contamination – for example, small parts falling off and becoming foreign-body hazards, or a source of microbiological or allergen cross-contamination/cross contact. Items previously worn in an area that was contaminated could transfer the contaminant into manufacturing or storage areas. Clear guidance must be given to all personnel on site regarding the hygiene requirements and what can and cannot be worn in the relevant areas. The site may choose to enforce requirements in addition to those stated in the Standard.

 

I saw in OP: Our GMP currently states that jewelry is only prohibited when handling food labels and packaging. 

I thought it should have been where. Like GMO, I still don't know well the context to object the auditor's NC.

[Tony-C]

Hi RAM86,

 

Normally having different policies for different areas leads to confusion, IMO it far better to apply one standard to all product areas regarding jewelry. At a minimum a risk assessment showing no risk of packaging contamination would be required if you are going to allow these personnel with gauges in areas where they are working with your products.

 

BRCGS Global Standard Packaging Materials Issue 7 clause 6.2.1: The requirements for personal hygiene shall be based on risk assessment of the potential hazards that could occur during manufacturing and storage, and appropriate to the intended use of the finished product.

The requirements shall consider as a minimum:

• wearing of wrist bands, wrist-worn devices or watches

• jewelry, including piercings on exposed parts of the body, except for a plain wedding ring, wedding wristband, medical alert jewelry or medical monitoring devices

• fingernails including length, hygiene, varnish, false nails and nail art

• excessive perfume or aftershave, where there is a tainting risk.

 

BRCGS guidance also indicates that only plain wedding rings/wristbands (i.e. without any stones that may fall out) or continuous-loop sleeper earrings (hoops) are permitted to be worn and the site must complete a risk assessment if having a policy any different to that.

 

Kind regards,

 

Tony

[GMO]

I completely agree.  1 standard makes it easier to explain and control but it really depends on the layout of the OP's site.

 

My experience is mostly food but one site I worked at permitted no hair nets in a warehouse area but this warehouse was separated from the production area completely, i.e. there was no people traffic between the two areas and you had to actually go outside into another building to get to the warehouse, it was a completely separate operation.  That made sense to me, the controls in there were the same as those adopted by a supermarket warehouse so I saw no need to change them.

 

In another site the warehouse area was just off the low risk packing area with changing areas shared with low risk packing.  In there we had full workwear, no jewellery.  Again that makes sense.

 

Perhaps the OP can explain the layout and thus if there is genuine risk?  But as I put before, it's always better to argue the toss before the auditor leaves, it's harder to later for the reasons we're seeing, without being on and seeing your site you can't really assess risk.

Edited by GMO, 17 October 2025 - 06:23 AM.