Wearing of short pants in high heat index environment

Hi all.

I'm hoping someone can help with food processing attire. We manufacture acidified foods, and the heat index is rather high during the summer due to weather, humidity generated during processing, and other smaller contributers.

I'm being asked if shorts are OK. My experience is that they are not, but putting together the proper rationale is difficult, and an AIB 2010 document (Establishing a Uniform Policy- Head to toe) appears to allow shorts in higher heat index environments.
Is there a universal rationale to support complete covering of the legs in a food processing environment?



Most appreciated,

Marty C

Looking through the AIB standards, BRC standards and the CFR im not seeing anything that exactly states short are not allowed in a food processing facility.

Stating this though, IMEX we have never allowed shorts in our facilities and we also work with Acidified and LACF foods in the mid-summer weather.

I have heard of and have known some facilities to allow shorts in the warehouse sections of their plants but not in the actual processing areas.

I believe this may be more a of safety issue, preventing cuts and scrapes, but the FDA requires long pants, (below the knee) This also may be a hair issue and then a uniformity issue.

I do not think shorts are a good idea. I have worked in hot, steamy areas, with no A/C and long pants, hairnets and shirts with sleeves were always a requirement in food processing areas.

S

It's a good question, and one that I've never really received a satisfactory answer for.

In baking, myself, and on both of the warm days that constitute an Irish summer this issue raises its head. The main risk to shorts auditors note is the hair issue, the main risk I see is the sweat issue. Which would you prefer in your sandwich?

The obvious answer is to hire only bikini clad women who are working their way through college, have impeccable personal hygiene and shave at least every two days. Unfortunately, this falls foul of employment law, and could result in hoards of hairy, sweaty men burning their unwashed underpants at the gates of your factory singing "we shall not be moved".

I believe this may be more a of safety issue, preventing cuts and scrapes, but the FDA requires long pants, (below the knee) This also may be a hair issue and then a uniformity issue.

I do not think shorts are a good idea. I have worked in hot, steamy areas, with no A/C and long pants, hairnets and shirts with sleeves were always a requirement in food processing areas.

S

It's a good question, and one that I've never really received a satisfactory answer for.


The obvious answer is to hire only bikini clad women who are working their way through college, have impeccable personal hygiene and shave at least every two days. Unfortunately, this falls foul of employment law, and could result in hoards of hairy, sweaty men burning their unwashed underpants at the gates of your factory singing "we shall not be moved".

I would say:

1. Hair control
2. Moisture control
3. Disease control - I know I'm more likely to bash my leg against something and have a nice little cut on my shin than I am pretty much any other part of my body...
4. Chemical control - lotions and creams applied to legs post-shaving?

21 CFR§ 110.10(b)(9) says - Taking any other necessary precautions to protect against contamination of food, food-contact surfaces, or food-packaging materials with microorganisms or foreign substances including, but not limited to, perspiration, hair, cosmetics, tobacco, chemicals, and medicines applied to the skin.

... they make really breathable, quite comfortable athletic wear today that would allow your workers to still be comfortable while not subjecting your company to any additional risk from either contamination or sassy auditors/inspectors.

Setanta, thanks for your reply.
I've poured over the CFR 110 (FDA) and was unable to directly draw the line between the clothing language and wearing of shorts. Could you expand on the FDA requiring long pants? That would be very valuable to me.

Much appreciated,


Marty C

I am reading the way that Marshenko did...

Setanta, thanks for your reply.
I've poured over the CFR 110 (FDA) and was unable to directly draw the line between the clothing language and wearing of shorts. Could you expand on the FDA requiring long pants? That would be very valuable to me.

Much appreciated,


Marty C

In the FDA Food Code dated 2013 section 2-402.11 (page 51) Effectiveness states "(A) Except as provided in ¶ (B) of this section, FOOD EMPLOYEES shall wear hair restraints such as hats, hair coverings or nets, beard restraints, and clothing that covers body hair, that are designed and worn to effectively keep their hair from contacting exposed FOOD; clean EQUIPMENT, UTENSILS, and LINENS; and unwrapped SINGLE-SERVICE and SINGLE-USE ARTICLES." as such employees with hair on their legs need to have on clothing that covers body hair.

What about nurse's scrubs? They are not very expensive and are lightweight and breathable for those unbearably hot days while still keeping the food safe by covering all of those questionable body parts.

There is an argument to say the greater risk is from upper body hair rather from the legs...depending on the height of work area / exposed food.

Not sure if I am going to be shouted down here or not, but I have absolutely no problem with workers wearing shorts. As long as they are knee length.

This whole "hair" argument is just nonsensical IMO. The only way to eliminate "all" instances of any "possible" contamination from hair is to require all workers to perform their duties in hermetically sealed suits.

Should everyone wear arm sleeves? Should there be eyebrow nets? How about plugs in the nostrils for the occasional nose hair?

This is why there are risk assessments. 

If you are working in a 100 degree F bakery, and all of the product is at waist level or above, what possible consequence could there be from leg hair if the arm hair is in play? Or the eyebrow hair, or the nose hair.?

Marshall

Not sure if I am going to be shouted down here or not, but I have absolutely no problem with workers wearing shorts. As long as they are knee length.

 

This whole "hair" argument is just nonsensical IMO. The only way to eliminate "all" instances of any "possible" contamination from hair is to require all workers to perform their duties in hermetically sealed suits.

 

Should everyone wear arm sleeves? Should there be eyebrow nets? How about plugs in the nostrils for the occasional nose hair?

 

This is why there are risk assessments. 

 

If you are working in a 100 degree F bakery, and all of the product is at waist level or above, what possible consequence could there be from leg hair if the arm hair is in play? Or the eyebrow hair, or the nose hair.?

 

Marshall

That's what I was trying to say.

100% agree.

Not sure if I am going to be shouted down here or not, but I have absolutely no problem with workers wearing shorts. As long as they are knee length.

 

This whole "hair" argument is just nonsensical IMO. The only way to eliminate "all" instances of any "possible" contamination from hair is to require all workers to perform their duties in hermetically sealed suits.

 

Should everyone wear arm sleeves? Should there be eyebrow nets? How about plugs in the nostrils for the occasional nose hair?

 

This is why there are risk assessments. 

 

If you are working in a 100 degree F bakery, and all of the product is at waist level or above, what possible consequence could there be from leg hair if the arm hair is in play? Or the eyebrow hair, or the nose hair.?

 

Marshall

I've been trawling the internet and the BRC & TPPS stds looking for a definitive answer to this - it gets brought up in meetings (and avoided) every time there is a 'heatwave'. I think my take from a food safety/technical view is as above... just use common sense!

Whoa zombie thread alert...

But this is an interesting question which has come up for me before.  Personally I wear skirts which are knee length (sorry everyone who thought I was a bloke).  I therefore see no reason why knee length shorts shouldn't be allowed.  That said, when I worked at 45oC in a bakery, we didn't allow them due to the risk of burns.  So the H&S police may get in the way of your plans...

The next argument for "no" is it doesn't half highlight when your coats aren't long enough.  I'm 5'8" and it's rare that I find a coat which goes to my knees.  If you have a 6'3" body builder like we do with his knees out, the auditors notice more than when his legs are tucked away (sorry but the conversation did descend to bikinis earlier!)  So that might be another way you get a gentle nudge not to do so.

Lastly you do have to set limits.  This is one for HR but obviously bikinis are not appropriate business attire but what is?  I had my days as a youngster where I went to my research lab in denim short shorts.  I was younger and my professors didn't mind(!)  However, in a complete double standard, if a member of staff appeared dressed like that in my team, I'd have a quiet word.  An unannounced auditor could turn up any day and we don't want them to have a heart attack do we...? 

It's a wonderful Zombie, fuelled by the inimitable SQ. Where are you Now ?

I'm still wondering what "nurse's scrubs" are ? (Post 10)

Or were the words inverted ? (No offence intended to the equally wonderful Nursing Profession)

Charles, I think its time for you to step away from the forum for an hour and go and relax with one of the many current nursing dramas on TV(Chicago Hope is pretty good) - you know those (generally) blue trousers and smocks you see the doctors and nurses wearing, they are called "scrubs"  Actually, they would be ideal for a hot environment as they do cover all the necessary parts and are very light fabric. ;-)

Personally I wear skirts which are knee length (sorry everyone who thought I was a bloke). 

Charles, I think its time for you to step away from the forum for an hour and go and relax with one of the many current nursing dramas on TV(Chicago Hope is pretty good) - you know those (generally) blue trousers and smocks you see the doctors and nurses wearing, they are called "scrubs"  Actually, they would be ideal for a hot environment as they do cover all the necessary parts and are very light fabric. ;-)

I agree lightweight clothing is the key. In a former life I was a commis chef and the light weight check pants with elasticated waistband were an absolute godsend. They let the wind blow freely where it was most needed.  As far as the chefs double breasted jacket, well that was the opposite.

Hi Kehlan,

thks for info.

Seems that these days, medical scrubs have somewhat "developed" -