False fingernails in a food packaging plant

Hi all,

I have a question concerning false fingernails and fingernail polish (covered by a glove) in a food packaging plant. The SQF code does not explicitly state false fingernails/fingernail polish is not allowed. Section 13.4.1.2 states, “The manufacturing process shall be controlled such that the packaging material produced is safe and free from contamination."  However, the guidance document does explicitly state false fingernails are not allowed.

Our current policy does not allow false nails or nail polish but we are reviewing this policy to allow it if the person wears gloves and the gloves are checked/replaced frequently.

Opinions on this are appreciated.

I am going to ask questions I think an auditor would...

You will need to demonstrate that your current policy is successful. How would you define frequently?  What happens if you find someone lost part of their nail or polish during a production run?

*I* would not want to take a customer complaint from someone who found a bit of fingernail or polish in our food and I would think twice about any supplier that I found a piece of fingernail in the packaging.

I also work in food packaging (SQF Level2 for 2 years) and we do not allow false fingernails or nail polish on the production floor. I'm not sure gloves were ever considered. However we do have one employee in our front office who does wear false nails and refused to give them up so she was banned from entering the production floor at any time.  

AIB would tell you to put it in  your GMP checklist - false fingernails AND false eye lashes are VERBOTEN!!!

BRC.  States it : False fingernails, nail art shall not be permitted

Guidance under the FDA states

1. (A) Food employees shall keep their fingernails trimmed, filed, and maintained so the edges and surfaces are cleanable and not rough. ^Pf
2. (B) Unless wearing intact gloves in good repair, a food employee may not wear fingernail polish or artificial fingernails when working with exposed food.

Food safety systems are most effective if they are kept as simple as possible.  If you bend to allow this, that and the other then it is you that has to put in place secondary measures that must be maintained, checked and controlled.  It makes life more complicated and complication leads to non-conformance.  You have to make tough decisions like no false fingernails, nail varnish, body jewelry, cologne etc.  The food industry shop floor is not the place for such things and if you can't stand the heat get out of the kitchen. Simple.

We also do not allow any false fingernails or nail polish in our food production facility. 

 

 

BRC.  States it : False fingernails, nail art shall not be permitted

 

 

Guidance under the FDA states

Fingernails 2-302.11 Maintenance.

1. (A) Food employees shall keep their fingernails trimmed, filed, and maintained so the edges and surfaces are cleanable and not rough. ^Pf
2. (B) Unless wearing intact gloves in good repair, a food employee may not wear fingernail polish or artificial fingernails when working with exposed food.

 

Conceptually I'm amazed that FDA adherents can retain false fingernails when donning medical-type gloves. They must surely be contortionists or having been assigned  a dedicated  floor cleaner.

In respect to limits, i recall that, at least a few years back, some locations, eg Australia, legally allow mouth/facial attachments  for workers in food manufacturing facilities.

We also do not allow any false fingernails or nail polish in our food production facility. 

 

 

BRC.  States it : False fingernails, nail art shall not be permitted

 

 

Guidance under the FDA states

Fingernails 2-302.11 Maintenance.

1. (A) Food employees shall keep their fingernails trimmed, filed, and maintained so the edges and surfaces are cleanable and not rough. ^Pf
2. (B) Unless wearing intact gloves in good repair, a food employee may not wear fingernail polish or artificial fingernails when working with exposed food.

 

This section applies to food establishments such as restaurants and the like, that sell directly to the consumer. In that section's (Food code 2009 chapter 1) definitions it is written that the regulations do not apply to food packaging plants. 

Tamale

In our Food Packaging Manufacturing facility fake nails are not allowed either. SQF is our standard and it  states;

13.3.4.1 Jewelry and other loose objects shall not be worn or taken into a product handling area or any area

where packaging is exposed.

13.3.4.2 The wearing of plain bands with no stones and medical alert bracelets that cannot be removed can be

permitted, however the supplier will need to consider their customer requirements and the applicable food

legislation.

I think that if an ear ring would be classified as a loose item, then surely a fake nail would as well. There is also always the argument that long fingernails would pose an obstacle to proper hand washing.

Thank you everyone for your responses. 

You are right the SQF Code doesn't say anything about fake nails, it also doesn't say anything about lip plates - both of which I have seen on SQF plants GMP's... as in no way, no how.

Food safety systems are most effective if they are kept as simple as possible.  If you bend to allow this, that and the other then it is you that has to put in place secondary measures that must be maintained, checked and controlled.  It makes life more complicated and complication leads to non-conformance.  You have to make tough decisions like no false fingernails, nail varnish, body jewelry, cologne etc.  The food industry shop floor is not the place for such things and if you can't stand the heat get out of the kitchen. Simple.

That is basic philosophy in food industry

Conceptually I'm amazed that FDA adherents can retain false fingernails when donning medical-type gloves. They must surely be contortionists or having been assigned  a dedicated  floor cleaner.

 

In respect to limits, i recall that, at least a few years back, some locations, eg Australia, legally allow mouth/facial attachments  for workers in food manufacturing facilities.

As an Australian Food Industry worker I'd say that would vary from place to place. There can be a tendency for 'if we can't see it we don't want to know i.e. tongue, belly, but everywhere I have worked has either been zero tolerance on facial piercings or you had to wear a blue band-aid over it, and in that place the band-aid had to be signed in and out of the factory by a first aid officer so it really wasn't worth the hassle.

Hi Wyldlce,

(Slightly )

Thanks for comment. Is there an actual definitive requirement in the ANZFA Regs ?

Actually this was the (2006) post I recalled –

http://www.ifsqn.com...ngs/#entry11581

I think the situation was that of a, presumably, be-ringed worker/Union challenging the Company. As I recall, successfully.

I note that this was not E. Coast so maybe your (localized) opinion valid. Also possible that Nationally a less tolerant situation now exists.

I also noticed this, slightly more anecdotal, (2005) observation on Australia regarding nose-rings –

http://www.ifsqn.com...lery/#entry5201

Another more recent and quite interesting thread (BRC-oriented) on the topic here –

http://www.ifsqn.com...wed/#entry37636

FWIW (slightly more OT), i found the (Australian)  "Judge's" closing comments (see paras 32 et seq) in this recent case of a "ringed" waitress quite interesting -

 DLC vs HA, 2014.pdf   251.42KB   60 downloads

You're right, there isn't anything that specifically states that facial piercings are prohibited however jewellery is mentioned in the ANZFA code 3.2.1 Food Safety Programs - 

 

Food can be contaminated with physical objects such as glass, metal, plastic, insects, adhesive dressings and jewellery. If these things are found in food they may introduce microbial hazards and may also result in physical harm to the consumer, for example choking, laceration and broken teeth. It is only necessary for potential hazards to be identified if they are ‘reasonably expected to occur’, that is, that the hazard is foreseeable, typical or likely to occur due to the specific nature, storage, transportation, preparation or handling of the food

and

Microbiological, physical and chemical hazards that arise from staff handling unpackaged food - Staff health and hygiene - Contamination of food with pathogens from sick food handlers, contamination from hands of food handlers and from jewellery, hair and clothing are controlled.

Is there a potential for a piercing to fall out? Yes there is. I know there are some types of piercings that can only be removed with special tools but unless you were willing to verify and document daily that the type of piercing being worn is the right one then I can't see it being worth the risk. I know if I was auditing someone and noted an employee wearing a piercing I would definitely be querying it at the very least.

Your examples seem more to do with front of house staff, waitresses and the like and if the establishment allows standard jewellery to be worn then they have no right to discriminate against facial piercings. 

Your examples seem more to do with front of house staff, waitresses and the like and if the establishment allows standard jewellery to be worn then they have no right to discriminate against facial piercings

 

The original link  referenced had long gone of course but I managed to locate the related files in my archives.

 Policy - Body Piercing Jewellery,W.Australia.pdf   147.63KB   45 downloads

 ir122005.pdf tongue piercing australia.pdf   407.15KB   48 downloads

First one is source of forum quotation and includes not much else.

Second one is more factually interesting and describes a specific case of a stubborn foodhandler being dismissed (pg 4-5).  Seems the worker initially won versus the (well-known) named Company but lost on appeal.  rather to my surprise, there is no mention, plus or minus, of any  specific FS-related factors other than "hygiene".  The aspect of "reasonableness"  of Company Policy appeared to be the ultimate criterion !. I suspect that 10 years on, the situation may be somewhat different.

A caveat for false fingernail lovers perhaps !

The original link  referenced had long gone of course but I managed to locate the related files in my archives.

 

Policy - Body Piercing Jewellery,W.Australia.pdf

ir122005.pdf tongue piercing australia.pdf

 

First one is source of forum quotation and includes not much else.

 

Second one is more factually interesting and describes a specific case of a stubborn foodhandler being dismissed (pg 4-5).  Seems the worker initially won versus the (well-known) named Company but lost on appeal.  rather to my surprise, there is no mention, plus or minus, of any  specific FS-related factors other than "hygiene".  The aspect of "reasonableness"  of Company Policy appeared to be the ultimate criterion !. I suspect that 10 years on, the situation may be somewhat different.

 

A caveat for false fingernail lovers perhaps !

That second article was quite interesting, and I can understand how it came about. And I agree about things having changed over the last 10 years, though I actually think that it may partly be to do with the fact that body piercings are so common now that it's no longer seen as discrimination to be asked to remove them when handling food, especially when no other jewellery can be worn either. And if there are no discrimination cases for it then the legislation writers are probably not really thinking about that section too hard. Why change something that's no causing an issue? 

Hi Wyldlce,

Thanks for the observation on Australian culture. Very illuminating.

 Perhaps one can generalize (ie including the OT) that, from a QA / legal POV, before intiating a confrontation, QA shud verify that –

(a) A “legal” Company budget exists

(b) The “rule/requirement”  is documented in Company Policy (this necessitates that a documented validation exists and  Top Management is on-board [the buck-stop factor])

(c) No potential Regulatory / common / local factors oppose the Policy. Ideally the opposite of course. Either way, shud already have been verified of course for [b]). If opposition does exist, a legally adequate counter-response should/must be available.

(d) The Policy / Company actions can be legally/convincingly presented as “reasonable” (whatever that  means).

For a QA, the crunch is probably, usually (b,c).

The OT was focused (partially) on the bracket in (b). So far there appears to be nil data/no Regulatory cause for a yes/no Rule decision except the positive note in FDA’s Retail Code. This tends to suggest that in many locations  para. (b) +/- the bracket, and (c) are relied on if action is taken. Hmmm.

PS –

I anticipate that false fingernails are likely to be also common in Australia and would be (foodhandler) tolerated if under gloves. Until they’re forbidden in the Company Policy of course.

In my previous life, Fake fingernails and fingernail polish were prohibited  in the production area. In the place I work now it is only prohibited to the product handlers. We passed BRC V6 last year. But then again there are the employees that complaint all the time about it and the ones that try to sneak in the production area. To me It is easier to control if it is prohibited all together no exceptions.

I am of course only generalising based solely on previous experience and conversations with other industry members. I tend to be a 'if those are the rules then that's what you do' sort of person, unless it's something so far out there that you need to question the sanity of the policy writer

PS –

I anticipate that false fingernails are likely to be also common in Australia and would be (foodhandler) tolerated if under gloves. Until they’re forbidden in the Company Policy of course.

Possibly, but I'd honestly be surprised if there were more than a handful. I admit I've only worked in 4 factories in my relatively short career (by comparison) and all 4 factories have expressly forbidden false nails and polish, and in 3 of those factories it was mandatory to wear gloves. Generally I've found that if the company includes it in the agreement an employee must sign prior to starting work i.e. agree to follow company personal hygiene policy, etc, then a company is covered from any potential backlash. 

I am of course only generalising based solely on previous experience and conversations with other industry members. I tend to be a 'if those are the rules then that's what you do' sort of person, unless it's something so far out there that you need to question the sanity of the policy writer

 

 

Possibly, but I'd honestly be surprised if there were more than a handful. I admit I've only worked in 4 factories in my relatively short career (by comparison) and all 4 factories have expressly forbidden false nails and polish, and in 3 of those factories it was mandatory to wear gloves. Generally I've found that if the company includes it in the agreement an employee must sign prior to starting work i.e. agree to follow company personal hygiene policy, etc, then a company is covered from any potential backlash. 

TBH, i was only extrapolating from yr "ring" frequency prediction, perhaps the objectives (fashion, protest, cussedness) are different, and so on to nail polish, perfume, face masks, unmentionables, the book of greyable areas  is substantial.

It's true that like pathogens, the natural, and convenient, tendency is to apply the Precautionary Principle, ie zero tolerance.  And kiss RA goodbye. The choice maybe also reflects on the Company Management Philosophy. In auditing I have met both extremes, Draconian to near-nonchalance and various shades of lip-service in between. This is why we have FSs of course, to (hopefully) pass the buck. Unfortunately it can be cyclic.

We are a BRC registered Packaging facility - we do not permit any type of false nails or nail polish. Recently a broken acylic false nail was found in a box of IML labels. We raised a complaint against our supplier whose initial response was "we don't allow cheap glue on false nails but we have permitted the hard acrylic ones' - we soon disabused them of the notion that that was okay and insisted that their policy be changed.

Good Morning, 

I come from a job that has zero tolerance for fake lashes or fake nails, however I just started me new position as QA Manager and the decision has came up on whether or not to allow fake nails due to every employee wears cotton gloves and plastic gloves while handling product.

I'm curious what was your decision did you allow it or not?

We also don't allow fake nails, however, the gloves make it a more interesting question.    IMHO you'd have to do a risk assessment and write it up, and that could justify your position. 

Good Morning, 

 

 

 

I come from a job that has zero tolerance for fake lashes or fake nails, however I just started me new position as QA Manager and the decision has came up on whether or not to allow fake nails due to every employee wears cotton gloves and plastic gloves while handling product.

 

 

 

I'm curious what was your decision did you allow it or not?

My facility - employees wear cotton gloves and plastic gloves as well. We don't allow fake nails. We do however allow nails with fingernail polish. Like MDaleDDF mentioned - I was able to do this after I did a risk assessment.