11.3.3 Clothing and 11.3.5 Visitors

We are currently evaluating and changing our policy regarding clothing at the plant. We currently provide uniforms to employee's and have them laundered, but have not required them to change into and out of their uniforms at work. We have now decided that we are going to make that change this year at both of our facilities. With that, we are looking at smocks for management and visitors, but are stumped on how to handle contractors.

Curious to what other facilities do - are contractors required to wear a disposable covering? Is it based on the type of work and where they are working in relation to the product?

You mean right now your employees wear their uniforms to and from work?     We have white coats for production employees and BLUE for our maintenance department. I would suggest segregating by colour for the maintenance staff and any outside contractors.  One other place I worked, production employees all changed into blue coveralls, and the maintenance staff had pants and shirts.

I prefer outside contractors to be very visible, particularly if you are running something proprietary....keep an eye on 'em

Yea, we currently don't require employee's to change at work. We do have maintenance, production, sanitation, and transport all 'color coordinated' with the uniforms they wear - we will just be shifting to them being required to change at work.

So, your contractors are required to put a smock or overcoat on when entering the facility?

YES! I have (and am required by FSEP to have)  a visitors log that explicitly states what is expected of them. Someone escorts them to get geared up, and then to the problem area and then they do their thing. That includes using the boot dip, hand washing, hair/beard net. The whole idea is to Control Hazards. The contractor could have an chest pocket, and foreign material could fall out of the pocket and into your product.

I'm not familiar with SQF, but my place of employment runs HACCP and the pre req's are stated by the federal government in Canada, one of which is uniforms. I don't even allow the employees work foot wear to leave the building (unless its a firealarm)

How do you control the allergens when the uniforms are out and about?

I agree with scampi, to use smocks, lab coats, hair nets, etc., to make outsiders highly visable. Really it should be part of your food defense/food security plan. The whole concept of uniforms as a GMP is to minimize new and different contaminants from coming into your facility. Certainly every facility has its own native "dirt" but the point is you don't want employees, contractors or visitors of any category bringing in new and different filth and allergens and Pest. At one IPM short course I took, it was explained that most institutional/facility infestations are caused from employee belongings. Even if you have a uniform program, but allow employees to wear it to the lunch room or out to lunch, then you have negated the purpose. What if they go out and pet contaminated with peanut allergen from that cany bar orThai food peanut sauce? Then they come back from lunch and pose a dire risk. You have no clue where the sales representatives coming to your facility have been before they come to see you. They could have walked through a barnyard or the pigeon and duck mess at the park. My point is a uniform program is not complete without a shoe/boot program as well. If you send individual workers from a zone 1 or 2 area of exposed product out to fetch boxes or labels from a zone three area, then they will bring contaminants back to your most vulnerable area. This is why you should have disposable aprons, sleeve protectors, etc., in addition to uniforms to minimize zone to zone contamination. Uniform programs must also have a strict prohibition of wearing or taking uniforms into restrooms and providing ample facility and procedure for accomodation of that policy.

One of the most difficult chalenges to a uniform program are posed by the uniform vendors themselves; many do not have progarms, certifications or any warantee whatsoever concerning the efficacy of their washing, sanitizing and protection from contamination for the uniforms they provide. A qualified uniform vendor needs to provide their customers with supporting documentation. Without the science based data and certification from an acredited body, you have no clue if the uniforms are providing any more protection than if your employees were wearing their street clothes in your processing room.

Uniforms are notorius for having unwanted pockets, loose buttons and threads that get into food. If you don't insist on a contractual specification to prohibits buttons, pockets and a criteria for wear/damage replacement then you create a new problem of contamination.

Has there been an issue, from a safety perspective, of the contractors in disposable lab coats? I don't mean a contractor coming in to quote a project, or just walk the floor - one that is fabricating equipment, crawling, climbing, etc. while working. We are taking into account any risk posed to exposed product, but most (if not all) work is done on lines that are shut down, will be cleaned/sanitized prior to start up, etc.

Either way you are fine, but in my experience, the disposable kind are hot and noisy and your outside vendors will be your biggest challenge when it comes to dressing as per your company's rules, as they have zero investment, and therefore the rules shouldn't apply to them.

In Canadian federal plants, we have to use an approved vendor list for everything that may come in contact with the food, so ask your supplier for a letter of guarantee ( or some such thing) weather your using disposable or washable smocks etc

ALSO, don't forget that you need to have the same general hygiene standards across the board, once you start making exceptions for contractors where do you stop......

In twenty years I have only facilitated contractors performing work in a vulnerable area after hours on the sanitation shift when I know that intrusive maintenance inspections and forms, sanitation and pre-op inspections and the reports that accompany that process will be performed by our own engineering and food safety teams. There are always exceptions to the uniform program that come up (as you point out for example SAFETY), but at all times precaution for exposed food, packaging and food-contact equipment and vulnerable areas must be taken. I believe an aspect of the uniform GMP and all GMP is that they need to apply whenever it is possible. Making an exception for personnel safety and instead taking other equivalent precautions that still deliver the aims of the GMP is one thing, but to set aside the GMP because of the convenience of someone who thinks they are more special than food safety is another matter.

Another exception we have is for warehouse and premises employees that never enter any production areas. They still have a uniform/boot program, but it differs from the program for prodcution.

Our written policy and practice is to send a formal communication letter and "GMP Agreement" for vendors and contractors to sign and return for us to keep on file. This cuts down on their surprise and dismay at our reception desk and gives them an opportunity to voice their concerns. Then the reception desk has the warning signs, agreement forms, disposable booties, lab coats, etc. for fulfilling the terms of our written program. By the time their escort gets up to reception, our receptionist has them all suited and ready to go. Vendors, contarctors, etc. always have the extra incentive to comply because they know we can find a replacement, but a few sales people all decked out with perfume, jewelry, high-heel (open-toed shoes) have showed up and tried to resist. They either have to comply or they can be replaced as well.

We are currently evaluating and changing our policy regarding clothing at the plant. We currently provide uniforms to employee's and have them laundered, but have not required them to change into and out of their uniforms at work. We have now decided that we are going to make that change this year at both of our facilities. With that, we are looking at smocks for management and visitors, but are stumped on how to handle contractors.

 

Curious to what other facilities do - are contractors required to wear a disposable covering? Is it based on the type of work and where they are working in relation to the product?

It is important that your policy is consistently applied.

For contractors I see there being two options:

1. Shut down and hand over the area where they are working. When it is handed back have a system in place for ensuring the area is hygienic and suitable for food operations.

2. They follow the same rules as employees and wear laundered clothing or hygienic disposables supplied and approved by your company.

Regards,

Tony

In my old facility the contractors wore red lab coats when doing any work in the processing area. I am in the process of putting together a uniform policy for my current facility

I had contractors wear a different color smock than my management staff and production workers. The contractors wore the same color as my maintenance staff. The contractors were escorted at all times by the maintenance staff while in the production areas in the facility.