14 replies to this topic

[FSQAManager2025]

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!

[GMO]

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.

[SQFconsultant]

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.

[paulam1]

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.

[GreyeagleA]

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.

[jfrey123]

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!!!

[KTD]

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.

[GMO]

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.

[FSQAManager2025]

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.

[GMO]

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.

[MDaleDDF]

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.

[kfromNE]

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. 

[paulam1]

Interpretation:

7.2 Personal hygiene: raw material-handling, preparation, processing, packing and

storage areas

The site’s personal hygiene standards shall be developed to minimise the risk of product contamination from

personnel, be appropriate to the products produced and be adopted by all personnel, including agency-supplied

staff, contractors and visitors to the production facility.

Interpretation

The site must have documented personal hygiene rules designed to prevent product contamination from personnel.

These should be based on risk and may take into account different requirements for different production risk zones,

and any national or regional legislation.

All personnel, including agency-supplied staff, contractors and visitors entering production areas (including raw

material storage, preparation, processing, packing and storage areas), must adhere to the company’s documented

personal hygiene rules, including those regarding personal belongings, hand-washing, injuries, illness and medication.

Clause Requirements

7.2.1 The requirements for personal hygiene shall be documented and communicated to all

personnel. These shall include, at a minimum, the following:

• watches and similar wearable devices shall not be worn

• jewellery shall not be worn, with the exception of a single, plain wedding ring, wedding

wristband or medical alert jewellery

• rings and studs in exposed parts of the body, such as ears, noses and eyebrows, shall not be

worn

• fingernails shall be kept short, clean and unvarnished

• false fingernails and nail art shall not be permitted

• excessive perfume or aftershave shall not be worn.

Compliance with the requirements shall be checked routinely.

 

Interpretation Documented personal hygiene policy

This clause is designed to ensure that personal items are not a source of product

contamination; for example, small parts that may fall off and become foreign-body hazards,

or a source of microbiological or allergen contamination (e.g. if the items were previously

worn in an area that was contaminated and the contaminant was transferred into the

production area).

The site must document its personal hygiene requirements. At a minimum, these must include:

• Watches are not permitted in open product areas (including devices used for fitness

monitoring and tracking). It is good practice to include details for all portable personal continued

items within site policies; for example, mobile phones and tablet devices (e.g. the site

might exclude all individuals’ personal mobile phones, but have specific rules relating to

company-issued equipment, which could, for example, include instructions for cleaning on

entry to production areas).

• Jewellery must not be worn apart from plain, smooth rings or wristbands (i.e. without

stones that may fall out), such as wedding rings. Exceptions must be minimal and must

not constitute a risk to product (e.g. wristbands identifying a particular medical condition,

such as epilepsy or an allergy, may be worn where product is not at risk of contamination).

Where religious reasons prevent the removal of an item of jewellery, it must be covered

and the site must complete a risk assessment to determine how this will be achieved (e.g.

by totally covering the item with the wearer’s clothing, or by wearing overalls that are

buttoned up to cover the item).

• The potential for broken, damaged or lost glasses and contact lenses to become a foreignbody

risk should be considered.

• Rings and studs must not be worn in exposed parts of the body such as ears, noses,

eyebrows and tongues.

• Long fingernails are not permitted, as they are a contamination hazard since they

may break off; nor are nail varnish, nail art or false nails. Fingernails must be kept

clean, commensurate with the level of hygiene expected within a food manufacturing

environment. Where visitors cannot comply with these rules, other controls (such as

limiting where visitors may enter and what they may touch, and the obligatory use of

gloves) must be implemented to minimise the risk of contamination.

• Excessive perfume or aftershave must not be worn, as this has the potential to taint foods.

These requirements are applicable to raw-material handling, preparation, processing, packing

and storage areas. The requirements for staff working solely in enclosed product areas may

be relaxed where no risk is presented to the products.

The requirements must be communicated to all personnel (e.g. through induction training

and sign-in procedures for visitors and contractors). Consideration must be given to the

language in which the training is completed; for example, where employees will be working

in their second or third language. Appropriate methods of training (e.g. use of translators)

must be provided for them.

Compliance with requirements must be checked regularly; for example, by incorporating

checks into daily or weekly good manufacturing practice audits (see clause 3.4.4), or through

the questioning of personnel at regular intervals.

 

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.

[paulam1]

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? 

[GMO]

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.