Are Fake fingernails allowed if you wear gloves over them?

So, I know that BRC says no fake fingernails/nail polish. However, does this still apply if they wear gloves over them? If my plant has a documented risk assessment for fake nails to support this does that help justify it? Or are there other ways to allow them that are considered acceptable? Not every employee wears them, but those that do are very adamant about not being willing to take them off. What does your plant do in this situation? Thanks in advance!

I get them to take them off.  The only exception is for visitors in the interpretation guideline and that's only where they cannot comply (e.g. I suppose gel nails).

Personally though I prefer to insist everyone takes them off and I've always given the visitors rules in advance so there's no excuse.  There's always one though and it really p---es me off.  Then I have all the whinging from the staff about how they're not allowed.

Managers 100% absolutely no tolerance.  You work in food.  Thems the rules.

if people are very adament about not complying with the GMP's/Hygiene policies, etc we are very adament in them not working for us.

Fake Fingernails are a real GREY area - length, sharpness, etc - most times not conducive for the wearing of gloves over them, then it will become an issue with the gloves hurting peoples fingers, or easily getting holes and cuts in the glove.

We make it simple - they follow the requirements or leave, or not even start there employment  -- you will be amazed how bending for people will result in bending more and more - not worth it.

So, this is a very good topic for discussion in my opinion. I believe transparency and true reflection of what's happening in facilities is the best policy.

Internally, we have a risk assessment for staff who are not working or handling products, contact surfaces, as well as those who are associated with physical risk, to allow them to wash their hands, apply gloves(at a segregated area preventing CC), and then walk through facilities without risk of cross-contamination or physical contact. 

There are many visitors/vendors and other associated staff who tour the facilities. Upon washing hands and applying gloves, without cross-contamination occurring (i.e., handling product or materials), the risk can be assessed as low, as well as the process we deal with is considered low risk as well (NOT RTE/OR SHELF STABLE), no cooking, etc.

Employees who work in the facility should follow the GMPS that do not allow them.

The policy can be written for administrative and corporate staff members who work in office locations to be allowed to wear them.

The facility employees who are on the floor live and do have interaction. I agree it is a higher risk and should not be allowed for Foreign Material, Sanitary compliance, as well as chemical hazards.

If you manage the process and monitor it, is it a failure is the ultimate question.

We do not allow them, and I have refused an inspector entry to the plant because they were wearing fake nails.  GMPs are for everyone to follow, not just the operators.

We do not allow them, and I have refused an inspector entry to the plant because they were wearing fake nails.  GMPs are for everyone to follow, not just the operators.

Bravo!!!

We have a risk assessment allowing them when covered by gloves. The only time we really see them is when quinceaneras pop up, especially in the summer.

For anyone operating to BRCGS standards, which this question is about, it's worth looking at the interpretation guideline on it.  It's really clear.  The only exception allowed is "where visitors cannot comply with these rules..." it permits it when using gloves and not touching products. 

But it's super clear that's visitors i.e. not managers, not someone who has a special event if they're an employee.  It's too permissive in my view allowing it for visitors but it's unequivocal for employees.

So anyone replying saying they permit it for their staff, managers, office based people etc, you're risking a non conformance if working to BRCGS standards.  It's super clear.  BRCGS isn't always but this one, chapeau matees, you've actually not put it down solely to risk assessment for once.

What is the interpretation guideline and how can I access it? 

For anyone operating to BRCGS standards, which this question is about, it's worth looking at the interpretation guideline on it.  It's really clear.  The only exception allowed is "where visitors cannot comply with these rules..." it permits it when using gloves and not touching products. 

 

But it's super clear that's visitors i.e. not managers, not someone who has a special event if they're an employee.  It's too permissive in my view allowing it for visitors but it's unequivocal for employees.

 

So anyone replying saying they permit it for their staff, managers, office based people etc, you're risking a non conformance if working to BRCGS standards.  It's super clear.  BRCGS isn't always but this one, chapeau matees, you've actually not put it down solely to risk assessment for once.

What is the interpretation guideline and how can I access it? 

Ah... money of course!  £200 in the UK and I guess the equivalent elsewhere. Global Standard Food Safety (Issue 9) Interpretation Guideline | BRCGS

The question is whether you need it.  I would say "no" in this case as if you look at the standard, which is free, section 7.2.1 is really clear, i.e. you cannot have false fingernails.  It's only the interpretation guideline that has a reluctant concession for visitors and even then, strictly speaking, the auditors do not audit against the interpretation guideline but against the standard. So, it is theoretically possible (but mean) that an auditor could ping you for a visitor having false fingernails even though that's allowed in the interpretation guideline as the standard is more strictly worded.

Not allowed here.   Nor are gloves other than specific cases, but as a daily use item, nope.   Had a customer find a piece of a glove in the product years back.   No fake fingernails, no gloves.

Not allowed here.   Nor are gloves other than specific cases, but as a daily use item, nope.   Had a customer find a piece of a glove in the product years back.   No fake fingernails, no gloves.

I found a fake fingernail in our handwash sink. That sent the message real fast of why we don't allow them. 

Interpretation:

Ah... money of course!  £200 in the UK and I guess the equivalent elsewhere. Global Standard Food Safety (Issue 9) Interpretation Guideline | BRCGS

 

The question is whether you need it.  I would say "no" in this case as if you look at the standard, which is free, section 7.2.1 is really clear, i.e. you cannot have false fingernails.  It's only the interpretation guideline that has a reluctant concession for visitors and even then, strictly speaking, the auditors do not audit against the interpretation guideline but against the standard. So, it is theoretically possible (but mean) that an auditor could ping you for a visitor having false fingernails even though that's allowed in the interpretation guideline as the standard is more strictly worded.

As with anything Food Safety related, one must assess the risk associated. If you have staff whom are administrative and dont work in the facility touching product or working within the facility, is it safe to say there is no risk associated with those employees wearing nail varnish or other associated applications of manicuring? 

Depends how you interpret risk.  Does it risk non compliance for your operators to see your managers wilfully breaking rules?  Hell yes.  Are they about to get on the line and pack products?  Those managers?  Almost certainly not.  

But in any case I think it's super clear.  The interpretation guide you shared said "where visitors cannot comply with those rules" which is what I shared earlier.  A manager is not a visitor and a manager can comply as they know the rules, they should be trained in them and so can plan for them. The visitor situation is someone turning up not realising they would not be compliant.  A manager will already know.

Why do your managers not think they should follow the rules?

In the words of Theresa May (ex prime minister of the UK) asked a question of Boris Johnson (then prime minister, whom she hated) in parliament when he was found to have broken lockdown rules during covid.

"So either my right honourable friend had not read the rules or didn't understand what they meant and others around.. [them], or they didn't think the rules applied to... [them]. Which was it?"

I.e. why should a manager insist on an operator doing something they wouldn't.  Are they also exempt from washing hands?  

I know I'm being a bit cheeky but to be honest, so many culture efforts die on leaders not walking the talk.  It's such a lot of effort you will have to go through to overcome how much those leaders actions in having false nails will undermine you and your food safety message.  That is a hill I will die on.  I will fight every bloody manager who fails to follow those rules (excuse the pun) tooth and nail!

But either way an auditor can ping you with the letter on how this is written even if you don't feel as strongly about it as I do!

Before someone else points it out, the interpretation guide is copyright by the way which is why I didn't copy and paste it.