GMPs in Different Hygiene zones

OK, so normally I like to get all wordy and do my best to sound smart on this forum. It's because there are so many smart people here. But not this time, it's gonna be a straight jab. For SQF Food Safety; hair-nets in the warehouse? If the product is only in a state of vulnerability (open) in side a clean room, and all product in the warehouse is palatalized ready for shipping, are hairnets mandatory? It seems like over-kill. 

As always, you guys are the best,  thank you for your time

If there is no possibility of warehouse employees going into hair net areas the,answer is yes.

How does the product get to the production area? If it is brought in by the warehouse folks, they need hairnets...

OK, so normally I like to get all wordy and do my best to sound smart on this forum. It's because there are so many smart people here. But not this time, it's gonna be a straight jab. For SQF Food Safety; hair-nets in the warehouse? If the product is only in a state of vulnerability (open) in side a clean room, and all product in the warehouse is palatalized ready for shipping, are hairnets mandatory? It seems like over-kill. 

 

As always, you guys are the best than you for your time

Yes, agreed Plastic Ducky   

I usually only respond if I'm pretty certain on my facts..but in this case probably industry norms & your confidence in your site might be a better route?.

My understanding of both BRC & SQF is that the terms "where appropriate" & "production areas" are used respectively.

So, you'd need to challenge what you consider appropriate or what is a production area... and, although not mentioned in the body of  BRC 8, the interpretation notes do state:

All personnel entering production areas (including raw material storage, processing, packing and storage areas) must adhere to the company’s documented personal hygiene rules.

​(although your company's 'personal hygiene rules' could, of course, state risk assessment indicates no requirement for hairnets in packed product areas?)

​At approx 90% of warehouses I have visited & audited (as a customer not GFSI auditor) hairnets have been worn, so it does appear to be general practice.  Where they have not been worn & I have questioned why & been told that, as no ingredients or rework are stored in the warehouse, hence no backflow into the factory,  there is zero chance of hair entering product stream, backed up by records of hair complaints this makes sense, so I didn't give a NCF.

Regardless of written standards if I was going to opt to leave off the hairnets in warehouse, I'd have to be 100% sure that warehouse staff understand that they must be worn in processing areas and would NEVER EVER (excepting fire or other emergency) enter areas where hairnets are mandated bare headed, especially if you do have hair complaints. 

Because you know, people are people & like to bend rules?..

I have so far never seen people working in cold stores (-18degC) wearing hair nets. But balaclavas, yes.

Our policy is everyone wears a hairnet whenever they are in any part of the warehouse whether we are in production or not, day or night 24/7/365, regardless of activity.  It is simply easier to gain compliance by making everyone equally miserable all the time.  Occasionally we get someone who says, "I am bald so I don't have to wear a hairnet."  Oh yes they do.  If one person has to wear our fashion statement, then everyone wears the fashion statement.  Good luck!

Hi, Plastic ducky.

In my current site where the facility is designed to be in one box concept, all are required hairnet even in warehouses. There is one point in the entry point (before uniform change where hairnet is worn before anything else) where everyone is required to wear already hairnet and beardnet. Since there is also one entry point, all will be required to where hairnet from that point.

Previously, I worked with site where warehouse entrance may be different however there are some common walkways where hairnet would be mandatory, to avoid confusion or possible non-conformance, hairnet is the implemented across.

Sometimes, it would be better to follow things if they are simplified in implementation. It may be overkill in some point, but to justify to personnel the challenges and how they think to be the best possible solution, people seem to "buy-in" in the requirement.

Per the above:

1.  Do the warehouse people come into contact with any raw materials or ingredients?

2.  Do the warehouse people come into contact with exposed finished product?

3.  Do the warehouse people come into contact with any exposed work in progress?

4.  Is it easier to maintain compliance by stating that everyone in manufacturing areas (storage, productions, warehouse) have to wear hairnets?

On a few instances however I have heard of customer requirements that the supplier ensure that hair nets are worn in the warehouse.   

But for the majority I have seen hairnets required in the warehouse only if the drivers are moving between production and storage areas or while working in the raw material storage & processing areas.  If the warehouse does not contain an production areas or the drivers never/rarely enter production area they will not be required to wear the hair nets unless entering those areas.  As always you can justify your decision with a well thought risk assessment.