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.

First and foremost, I admire your reference to culture and the reference to interpretation.

As with everything referenced prior, it always ends up being risk related, if we made decisions based on what we think the right process and SOPS are for GFSI versus what the standards state, we all know how much of a mess the industry would be.

Simply put, every application, every plant and every process is different. I think this is why a interpretation guideline was made, to help fill the gaps for each processer.

Once again, I do not disagree that staff whom are in risk locations working should not follow the GMPs, GLPs or basic standards for sanitary and risk prevention.

Our internal KPIs and culture results with scientific and historical backed data showcase no findings in reference to the "nail" material in itself.  We coach, train, and listen to our staff members, and put them upfront for open dialogue and communication to keep our culture program at the forefront of our operation.  We all know they are the foundation of what we do on the daily. Without our staff we are nothing.

One has to consider the same mindset of: is it necessary for a office worker to use a metal detectable pen in the office outside of production? The answer in my opinion is no.  If the staff members are not within the production locations and not putting the process, or environment at risk, its not necessary. Risk assess it out, and manage the process of staff whom are in the risk locations, monitor it and verify it. Simple.

Food Safety culture and company culture are one of my passions, and it makes me very happy to see the reference in your own response, that you are passionate as well. 

I have personally adopted the mindset of change and growth with transparency in our process steps, training and overall food safety programs.  

I think its better to be upfront, honest, and simply risk assess the hazards as science and GFSI standards dictate, vs. make a rule that others state they will follow(working in various depts), and simply dont.  Once again, just my opinion.

I do want to also point out the variances in other GFSI standards below in relation to this topic. 

SQF:The wearing of false fingernails, false eyelashes, eyelash extensions, long nails or fingernail polish is not permitted when handling exposed food.

*Also, I did only place the evidence of 7.2 and interpretation from my own internal auditing documents so I would not be copying over copyrighted data. I do think its necessary to be able to reference data for those whom do not know how to find it as the original poster questioned.

Nice debate, I do appreciate your feedback and respect the dialogue!!!! :spoton:

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.

 We all know they are the foundation of what we do on the daily. Without our staff we are nothing.

You must have better staff than I do!   Lol......

You must have better staff than I do!   Lol......

I feel you! But I will say we are blessed.

First and foremost, I admire your reference to culture and the reference to interpretation.

As with everything referenced prior, it always ends up being risk related, if we made decisions based on what we think the right process and SOPS are for GFSI versus what the standards state, we all know how much of a mess the industry would be.

Simply put, every application, every plant and every process is different. I think this is why a interpretation guideline was made, to help fill the gaps for each processer.

 

Once again, I do not disagree that staff whom are in risk locations working should not follow the GMPs, GLPs or basic standards for sanitary and risk prevention.

 

Our internal KPIs and culture results with scientific and historical backed data showcase no findings in reference to the "nail" material in itself.  We coach, train, and listen to our staff members, and put them upfront for open dialogue and communication to keep our culture program at the forefront of our operation.  We all know they are the foundation of what we do on the daily. Without our staff we are nothing.

 

One has to consider the same mindset of: is it necessary for a office worker to use a metal detectable pen in the office outside of production? The answer in my opinion is no.  If the staff members are not within the production locations and not putting the process, or environment at risk, its not necessary. Risk assess it out, and manage the process of staff whom are in the risk locations, monitor it and verify it. Simple.

 

Food Safety culture and company culture are one of my passions, and it makes me very happy to see the reference in your own response, that you are passionate as well. 

 

I have personally adopted the mindset of change and growth with transparency in our process steps, training and overall food safety programs.  

I think its better to be upfront, honest, and simply risk assess the hazards as science and GFSI standards dictate, vs. make a rule that others state they will follow(working in various depts), and simply dont.  Once again, just my opinion.

 

I do want to also point out the variances in other GFSI standards below in relation to this topic. 

SQF:The wearing of false fingernails, false eyelashes, eyelash extensions, long nails or fingernail polish is not permitted when handling exposed food.

*Also, I did only place the evidence of 7.2 and interpretation from my own internal auditing documents so I would not be copying over copyrighted data. I do think its necessary to be able to reference data for those whom do not know how to find it as the original poster questioned.

 

Nice debate, I do appreciate your feedback and respect the dialogue!!!! :spoton:

Hey it's up to you.  But I think the standard and interpretation guideline are super clear on this.  I was only trying to point that out to save you pain later.

May I ask you one question?  If you had a manager who was going into the factory and they had painted or false nails, would you allow the auditor to see or would you divert their attention or prevent the manager entering in front of the auditor?

Just curious.

And we're going to have to agree to disagree on the how it impacts culture.  I've had operators come to me in plants where someone allowed this to happen absolutely fuming.  They might be upset about it and may not be telling you but you know your culture more than I do.  I can't imagine it would go down well anyway in any place I've worked but I've never worked in the US.

I did have a manager visit once from Romania who had false nails, I told her to leave the factory.  Her words were "in my country, managers are not seen as equal to operatives".  Well they are in my head.  That's my point.  But as others have pointed out on here before, I can be intransigent in my views so am attempting to change.

While I understand 100% the clarification, absolutely not, why would you hide something you have risk assessed out? That's the whole point: be transparent.

I do think it evolves based on risk above all, as stated, every plant has a different outline of process, programs, risk, and associated applications based on the GFSI scheme. 

Culture is what you create, and if your process is low risk and the need is not there, why try to hide it?

While I personally am very blessed by having support from a great Senior Mgmt. perspective, I do understand others are not, and that we must continuously evolve. 

This is the beauty of continuous improvement and overall risk assessment. 

Much Respect to you and your team!

Fake fingernails are often long and sharp which means they cut through gloves. 

It is not something I would allow.

Would the level of risk depend on the specific product being manufactured? If there is minimal likelihood of a false fingernail or glove fragment contaminating the product, this may be considered a low-risk. If the product is filtered prior to the final packaging the risk is minimal and the employee should be able to wear gloves while working in the production area.

Would the level of risk depend on the specific product being manufactured? If there is minimal likelihood of a false fingernail or glove fragment contaminating the product, this may be considered a low-risk. If the product is filtered prior to the final packaging the risk is minimal and the employee should be able to wear gloves while working in the production area.

As I said before, the standard is really clear.  Not allowed.  Also are you ok to drink a drink if fingernails have been filtered out of it?  What about the micro risk?  

I know there is disagreement above but I personally think this is super undermining to your food safety culture as well if you let some people do it because they're managers.  I'd just not allow it at all.  

I have bad experience about this, it caused me a lot of stress.

There was a risk assessment done (it wasn't my decision, I was only a team leader, whole bunch of managers above me making the rules), so office staff could have had their nails done and put some gloves on when they entered production.

Well, let me tell you that production was not happy at all. We were listening to it every day, on every given opportunity. "Why are they better than us, they do come to production sometimes, why can't I wear gloves then?" So we said, no one can have fake fingernails.

Guess, what.. the office staff wasn't happy... "Why do we have to do this, we are not at production" so we were listening to it all over again just from the other side.

It was a big company with 300+ people and the whole thing blew up, all directors got involved. We had multiple offices and there was a complete reorganisation on who goes to which office, people who may go to production and people who don't go to production at all got separated and the rules were different for the office staff as well.

Don't know if there were any other changes on this as I left the company luckily, but as soon as you open Pandora's box, all hell breaks lose. It only takes a few unhappy people and HR to get involved and it won't be about food safety anymore.

I have bad experience about this, it caused me a lot of stress.

There was a risk assessment done (it wasn't my decision, I was only a team leader, whole bunch of managers above me making the rules), so office staff could have had their nails done and put some gloves on when they entered production.

Well, let me tell you that production was not happy at all. We were listening to it every day, on every given opportunity. "Why are they better than us, they do come to production sometimes, why can't I wear gloves then?" So we said, no one can have fake fingernails.

Guess, what.. the office staff wasn't happy... "Why do we have to do this, we are not at production" so we were listening to it all over again just from the other side.

It was a big company with 300+ people and the whole thing blew up, all directors got involved. We had multiple offices and there was a complete reorganisation on who goes to which office, people who may go to production and people who don't go to production at all got separated and the rules were different for the office staff as well.

Don't know if there were any other changes on this as I left the company luckily, but as soon as you open Pandora's box, all hell breaks lose. It only takes a few unhappy people and HR to get involved and it won't be about food safety anymore.

Perhaps it's a British thing lol...  But as soon as there's something which separates "office" from "workers" you can bet you're getting it in the ear right?  And you know what I agree!  If you want to dress up and have fancy nails, there are other jobs out there.  Food isn't glamorous.  Sorry!