Personal Hygiene Rules

I've added a poll to this thread - please vote.

I wonder what an auditor from Tesco or Marks & Spencer would say about this?

IME nothing. I've never had an auditor raise it as an issue and I've worked in sites supplying Tesco with no restrictions at all, with a "no heavy make up" rule and a "no make up" rule. We never had an issue from suppliers trying to enforce or encourage a no make up rule. Obviously in all factories I've worked in, even if make up is allowed, nail varnish, false nails and false eyelashes are banned for obvious reasons.

One other consideration is once you have a "no make up" rule in one factory, it has to be enforced in all factories across a group. It was a major source of conflict in the two places I worked in where there was this rule that other factories owned by the same company had the rule but it wasn't enforced.

As for make up on clothing (lipstick on your collar?) I would be more concerned that the staff washed before coming to work. I once had to have a quiet word with someone on that regard as he stank. It wasn't pleasant...

hi guys,

we have just reviewed our personal hygiene rules and now our work council asks why we want to ban make-up from our people in the production. For us in the QA it is the normal thing that you should not wear it when producing food products, but we do not find a document, a customer requirement or standard that we can show.
They make a fuss around it now, that we can not forbid it if we can not show any evidence.
You find everywhere no varnish fingernails and no juwellry but nothing about make-up. Can anybody help me with this? We are located in Europe and produce Cocoa Products.

thanks you very much!

Hi,
I just had a TESCO audit in Nov. and in there Food Manufacturing Standard 10.9.1, they have a Medium level that says False eye lashes or excessive facial make-up must not be worn. There Base level doesn't mention anything about make-up. We are a low risk commodity, apples, not peeled or cut, so we don't require this of our employees. Hope that helps you, I have attached a copy of their standard for you.
Steph

But what about Cocoa products that are mentioned in first topic ? did I miss something?

I gave my vote as for work place where staff have a direct contact with RTE food, not a place for packed products or unpeeled fruits that all buyers can come and touch in the shop.

Have a nice evening everyone

Because all of our production and quality control personnel are male, make up is not a problem. Especially since I´m the only woman entering the plant, and I rarely wear make-up. I used to work at a meat packing facility and there was a no make-up rule for all the women there.
Now beards: there´s also a no beard policy, but moustaches can be worn as long as the don´t extend any longer than the top of the top lip , nor are "wider" than the person´s mouth. I really don´t know about this. Would one of the gentlemen who wears a moustache enlighten us on how easily moustache hair comes off? On its own, of course.
Then there´s the issue of hairy arms. It´s not very comfortable to work with long sleeves and those working in milling have to feel (yes, with their hands) the wheat or different stages of the crushed wheat or "grits". I´ve seen a couple of almost bear-like millers. I think that the reasoning behind not using long sleeves is that any hair that falls into the unfinished product will be crushed into particles smaller than 180 microns, or removed by sieves that are found throughout the process.
As for chemical contamination due to make-up: if it´s safe enough to be put on your face (your eyes even!), it is probably safe enough to eat. In the minute quantities that it could end up in the final product, the risk is even lower, I believe.
As for microbiological contamination, I think GMO covered it very well with the "wash your hands after you touch your face" rule. I´d be much more upset that bodily fluids coming from someone´s face got into the product than makeup itself.
Inesa, I have no knowledge of cocoa production, but because cocoa is ground into such fine particles, I believe that some of my observations could apply.
I would really appreciate everyone else´s comments.

Dear Steph,

Thks for the attachment. Very interesting.

I had a quick look at the Tesco interpretation of Base / Medium. I can appreciate their concept of risk variation in respect to exposed / non-exposed material but the result as presented in their listed requirements for “Personal Hygiene” seems flawed to me. It is also IMO contrary to some aspects of standard HACCP requirements.
For example the idea that it is un-necessary to evaluate the handwashing efficiency of one sector of the workforce seems simply illogical. What happens if the worker changes functions ?? And similarly some of the other items, eg (false eye lashes / excessive make-up) on / off / on again ??. The jewelry item 10.13.1 seems equally weird if you compare the 2Base/Medium.
The requirement to initially "Wet Hands" seems to imply that Tesco do not approve of soap dispensers. Curious.

@Inesa - first mention I could see of RTE
(I guess the Cocoa Process could be a mixture of everything although I agree that finding visible "make-up" stuck to the wrapping of a bar of chocolate seems more palatable than on the inside although the additional implications are pretty unpleasant in both cases maybe ? )

Rgds / Charles.C

I will probably write some nonsenses now, but I cant keep it me

It's about handwashing. I know it is key important in personal hygiene, but I never kept it as an absolute stopper of microbial contamination from humans.
Then we can say lets touch whatever we want to, just remember to wash hands
Let's have jewellery on, anyway our newest super metal detector will finally detect it

IMO even if the risk is low, it handles about the high quality food making performance. If the company states that they are making no compromises on food safety and seek highest level of hygiene, their should clearly state No to make-up and other foreign body stuff in their policy.
Another: Why to use time and make more blah in making restrictions? Women will always find a way to put some "invisible" make-up on, that noone can see it and prove she has it on

Dear all,

thanks a lot for all your opinions. I agree with Simon, that black or white is always easier whe n you discuss with the people on the plant floor.
As we have there 98% men it is really no big issue. As Inesa mentioned you can always argue it, but I hopped there is something simply that can be shown, beside just saying "it is headquarters policy" as in fact it is.
The topic pops up every month when the girls from administration go very colourful to the production for the inventory and the guys working there complain about it.

regards Beanny

Dear cocoabeanny,

black or white is always easier

Yes, i agree, the problem is that food safety control measures are (ideally) required to be scientifically validated.

I hopped there is something simply that can be shown

Yes, i understand. Unfortunately there are, AFAIK, very few reported health incidents related to consumption of make-up.

As we have there 98% men it is really no big issue

I'm reallly pleased to hear that.!

So what is yr policy on aftershave?. Also black and white ??

The topic pops up every month when the girls from administration go very colourful to the production for the inventory and the guys working there complain about it.

Really? I suspect you may have a "no camera" policy also ?

Anyway, thanks for initiating a very interesting and worthwhile discussion. Any further input totally welcome of course.

Rgds / Charles.C

This question must be answered by doing a risk assessment. Once you understand the hazards associated with a particular cosmetic or personal hygiene issue, the procedure required to control the hazard often becomes self apparent. The other advantage to decisions based upon a risk assessment is that you can justify your decision rather than making a decision based on "gut feelings".

Hazard may be microbiological contamination of the product as a result of an operative touching their face and then handling the product. The vector may be cosmetics.

Likelihood may be 3 - high risk of incidence

Severity may be 3 - consider staph aureus

Overall risk is 3 x 3 = 9

Control measure - prevent cosmetics being worn

Revised likelihood - still 3 as you do not need makeup to transfer bacteria

Severity will still be 3

The overall risk will still be 3 x 3.




Consider your control method of being washing hands every time an operative touches their face and before contacting food, the risk assessment then is

Likelihood of transfer may be 1 or 2 - clean hands now

Severity is still 3 - still may be staph aureus

Overall risk now is 1 x 3 or 2 x 3 so you have reduced the overall risk by a different control method.

Add training into your control method and you can definately reduce the risk to the product

Include personal hygiene and the requirements of food safety and you will almost remove the risk.

As this is a grey area, one can argue the point that it is yourcompany policy which is signed by the CEO or MD and that everybody should obey it. I am sure the work council cannot challenge that. If for example a major multinational brought their own rules and regulations then i am sure the work council would not challenge them. Just use this example to your council and see what they say.

Regards

Ajay Shah

I would like to see a definition of "heavy" or "excessive" make up if anyone has one.

Dear Tony,

And presumably by consensus.

Rgds / Charles.C

We are an fresh apple packer and makeup on the face is not an issue, but it is for the employees who purchase it and then reapply it or try to carry it on them
in the production area. So this is the only concern I could see. So we say no heavy make up and make up products must remain in locker area and hands
are to be washed after use of products.

Hi

I know strong parfums / bodylotion are not allowed as well in some areas. I saw a documentary on discovery - painting a expensive car... I know not at all food related but it has to do with hygiene. The wrong chemicals in the air can make little bumps in the car. Of course a customer wants a smooth cover and not bumps or dents. Same goes for cocoa the smell of the parfum can get attached to the cocoa - but depends on the state of the cocoa (just PPP cocoabutter of ready to eat chocolates etc).

As for make up - you can rub into you eyes...and the products in on your hands...and then you touch the product and conteminate it. I guess it depends on how much make up anybody uses. In our policy make up is not mentioned and we don't have any problems. Maybe to do with the fact that only guys work in the prodcution area.

As for evidence...why do you want to ban it? You must have your reasons to ban the make-up.

Good luck!

Anne

Maybe some of the ladies could answer this - If applied with a trowel is it possible for make up such as foundation to break up like plaster and crumble by itself and especially with hand touching?

Maybe some of the ladies could answer this - If applied with a trowel is it possible for make up such as foundation to break up like plaster and crumble by itself and especially with hand touching?

Not ever in my experience. Even when I used to be in plays as a teenager. There is a very small possibility of mascara flaking if very, very heavily applied.

As to a definition for Tony, I would say it's better to be vague. I know it's a bit naughty but if you have a standard, perhaps with photos, you then leave yourself open to question on whether your standard is right and whether it's applied. Personally as well I've never had anyone take the p*** with a "no heavy make up" rule. Perhaps someone else can enlighten me if they have? But I have had a situation where a female visitor with a small amount of concealer on was told to remove her make up before entering the factory. To me that is demeaning.

I would never let a clown enter my factory. A difference between a clown and a woman with make up is, that the clown is colourful and has an extra nose :)

I would never let a clown enter my factory. A difference between a clown and a woman with make up is, that the clown is colourful and has an extra nose :)

Dear all,

I've visited medicinal company Leo Pharma today ( http://www.leo-pharm...e/About-us.aspx )- excursion with the GMP course I have (for all: Food, farmacy and biotechnology students together)
So, at the section where they make tablets, before putting visitors clothing, girls were asked to remove all make up .
I asked: - why?
The guy answered shortly: - because make up flashes, and we have to control pathogens in the air.

because make up flashes

What does this mean? "Flashing" in English either means "bursts into flames" or "runs around naked at sporting events". I'm thinking neither are correct in this circumstance, I hope...?

It could be I heard it wrong
My question was unexpected I could see in his reaction, he was trying to remember words in English , while trying to answer my question, was touching his face to show make up can move to the air and they need to control pathogens in the air.
I'm not English expert either, was hurrying to share here what I've heard. But the main meaning I think, particles of make up can move to the air.

He was actually the second person I asked, the first one couldn't explain, said it's FDA requirement, but he wasn't sure...

I'll send an e-mail to them and try get some more detailed info. I'll post it here afterwords

Dear Inesa,

But the main meaning I think, particles of make up can move to the air.

and we have to control pathogens in the air.

I suppose one further interesting test query might hv been to ask about possible flying pathogenic species ?

Was there a strong wind within the factory that day ?

It reminds me of a raw seafood process audit where i accompanied the auditor who asked about concentrations of detergents / sanitisers and I happened to casually mention that the levels might vary for different product situations. The response was that he didn't care whether it was seafood or hotdogs, the same rules applied. Luckily he wasn't looking at me as he answered.
(I later found out that his usual responsibility was veterinary inspection of cattle farms )

Rgds / Charles.C

I would say the risks of pathogens in aerosol droplets from someones mouth is higher, yet facemasks are unheard of in the UK.

Perhaps we should ban talking too, just to be on the safe side...

I believe FDA has mentioned of some ruling regarding the microbial content of cosmetics (i.e. cosmetics also have microbial specifications).

 

Having said that, ask yourselves " If we are to allow cosmetics, how can we be sure that its microbial content is within the ACCEPTABLE RANGE? Can you ask your employees who wear makeups to submit as certificate of compliance from their suppliers/brands?" The point is how can we prove that our food handlers are clean if they have on their body something that is considered as "not natural" to their body? (By the way, in food safety, something that is NOT A NATURAL PART of the product's set of ingredients is considered  as a CONTAMINANT. With this definition in mind, COSMETICS, then are CONTAMINANTS of the body (being not a natural part of it considerably, right? So the next question, will you allow the contaminant of your body to reach your product? Allowing it will increase the probability of contamination, right?

 

So, I'll say YES to total ban of cosmetics.

 

Oh, by the way, before I forgot... allowing "moderate make ups" has big question... How moderate is moderate? How can you distinguish a moderate from a heavy make up? What is your measure? How can you measure? To top it all, it can only trigger an endless debate between the implementors and the subjects. Moreover, it can also be a cause of envy to those not allowed to wear make ups. So you will hear some of your crews... "Why are they allowed to wear make up when our group is prohibited?" Oh, well, another headache.

I have the same question.  GMP states no false nails, polish, false eyelashes, make up.  However BRC iOP does not mention anything.  Which one do I comply with??