BRC 7.4.1 - Removal of work clothes in canteens, toilets & smoking

Hello,

Can someone explain this requirement , where it states that This shall also include policies for wearing of protective clothing away from the production environment, e.g. removal before entering toilets, use of canteen and smoking areas.

What measures can be taken for policies for wearing of protective clothing away from the production area ? e.g. removal before entering toilets, use of canteen and smoking areas.

In our industry its quiet difficult to remove the clothing for entering the toillets , use of canteen and smoking areas ..
Are there any other measures that can be taken for this requirement ?

Thank you
Pavan

Hello Pava.
I would suggest something very simple such as coat hangers outside of the facility. This is what we have in place at the moment, although more clarification would be needed if the requirement is to include the removal of trousers.

We have a combination of workwear depending on the area staff work in. Where the workwear is a top and trousers (necessary due to the temperature in the area) we do require full removal before toilet or canteen breaks. It's probably a good time to review your workwear if you are not using coats covering personal clothing. I would much prefer to have that kind of clothing for everyone but it's just not possible considering the heat in a bakery. If you aren't in a hot environment, I would suggest changing to coats removes a lot of headaches.

Hello,



We use both coats for the Quality and Laboratory department, but the problem is with the workers - they use tops and trousers , Its really hard for us to change the trousers and tops every time they go to canteen or toilet, As it is totally time consuming . Are there any other procedures which we can prove that its safe to use the clothing in canteen and all ?


Thank you

Pavan

Hi Pavan,
I could only suggest that if after a risk assessment you can give certain guarantees for the trousers to be kept on (taking into account allergens etc.) then removal of just the jackets may be an option. Smoking areas (if you must have them) I'd suggest is an absolute removal of both, and toilets too would definitely be better for removal of both. As people tend to visit toilets only once or twice a day I don't see this as a major issue.
I do think our old friend "risk assessment" is key here though.

Dear Pava,

In our industry its quiet difficult to remove the clothing for entering the toillets

I am intrigued. What kind of food industry is this ?

Rgds / Charles.C

Hello,



We use both coats for the Quality and Laboratory department, but the problem is with the workers - they use tops and trousers , Its really hard for us to change the trousers and tops every time they go to canteen or toilet, As it is totally time consuming . Are there any other procedures which we can prove that its safe to use the clothing in canteen and all ?


Thank you

Pavan

Why is it hard? We do it.

You've still not explained though what industry you're in and therefore why you have chosen trousers and tops rather than coats? If the coats are ok for the quality department, why not for the production team?

A halfway house if the staff don't want to mess up their own trousers (if it's a messy environment) is to keep the trousers (but don't consider that as hygienic workwear) but then issue them with a knee length coat which is removed prior to the canteen and toilets.

Hello,



I am presently working in a Baby Food indsutry and we also produce family cereals and Frozen food products . We take utmost care to produce the baby food products as it is very sensitive.

It is very difficult for people to work on coats in the production line as it is very hot and people prefer Tops and trousers rather than a coat. About 60-80% of people use trousers .

I have already spoken with my higher authorites about removal of clothes is a Must, but they say that it is really time consuming and people tend to waste time during this process.

Any suggestions for this ?



Thank you

Pavan

Hello,



I am presently working in a Baby Food indsutry and we also produce family cereals and Frozen food products . We take utmost care to produce the baby food products as it is very sensitive.

It is very difficult for people to work on coats in the production line as it is very hot and people prefer Tops and trousers rather than a coat. About 60-80% of people use trousers .

I have already spoken with my higher authorites about removal of clothes is a Must, but they say that it is really time consuming and people tend to waste time during this process.

Any suggestions for this ?



Thank you

Pavan

How hot is really hot?

It's difficult this because we've all suggested options but none of them have been acceptable. I suspect what you want is for us to say "It's ok, don't bother, here's a risk assessment which says it's ok" but it's not really is it?

I would suggest they put up with the heat or change. It's up to them. It's a JFDI moment for me I'm afraid. Not all issues can be resolved.

I am not expert but your products do not seem to be necessarily associated with particularly hot processes like GMO's bakery so maybe the question is for your Engineering department: what can be done to make the working temperature more tolerable (and therefore coats could then be worn)?

this is what we did. We are in a similar situation and our employees where trousers and shirts
1) smoking is only allowed outside the facility so they are only allowed to smoke on breaks. If they need to go outside for any reason, they must first take the time to change in to their street clothes
2) They remove nothing to go into bathroom as it is impossible...If they are wearing a disposable apron over their uniform, they must remove that.
3) employees going to the canteen must wear a protective lab coat over their uniform to prevent cross-contamination of their uniforms. (we went with the idea of instead of removing, we simply cover up...

It seems to work and our employees have not complained since we started this about a year ago
good
luck

How hot is really hot?

It's difficult this because we've all suggested options but none of them have been acceptable. I suspect what you want is for us to say "It's ok, don't bother, here's a risk assessment which says it's ok" but it's not really is it?

I would suggest they put up with the heat or change. It's up to them. It's a JFDI moment for me I'm afraid. Not all issues can be resolved.

Hello, Sir


The temperature is around 80° in few zones .

Im not saying that we wont remove tops and trousers, but the management has asked me to find out if there is any other alternative for this .

Yes i accept that there arent any procedures we can bring up for this clause and removal is must.

I hope to convince my management in implementing this clause .


Coming to the Smoking zones, I had already spoke with the management to put in place over coat or plastic coats which can be replaced every 2-3 weeks and i hope this will reduce the costs compared to using a coat for a single use .


Pavan

Dear Katja,

They remove nothing to go into bathroom as it is impossible.

Interesting decision. How did the auditor feel about this logic? (Especially in the case where the employee wears no over-garment while working).

I also have to assume you have exceptionally clean bathrooms / toilets. Even if so, I would be surprised if no audit criticism because if it comes to a risk assessment scenario, this situation is surely a classic case for "undefendable" ?.

Yes it's true, many upper managements will resist a control step due to the inconvenience factor, and this is where their committment is validated, or otherwise.

Rgds / Charles.C

Hi
I think the comment has already been made that if you wear coats, covering from Wrist to neck and neck to knee, then the trousers can be considered as protection for the employees clothes and not 'whites'.

But they have to be removed when eating, smoking or going to the toilet.
I can see of no scenario that would permit the wearing of 'whites' in those environments.

In all the bakeries I have worked we replaced the tops and trousers with coats, the staff complained about the temperature, but still wore the coats, and trousers in some areas to protect their own.

I see the temp is around 80, but that aside, food safety is not up for compromise, especially when producing for vulnerable groups. I think they will have to accept the change.

Ian

Hello,



I am presently working in a Baby Food indsutry and we also produce family cereals and Frozen food products . We take utmost care to produce the baby food products as it is very sensitive.

It is very difficult for people to work on coats in the production line as it is very hot and people prefer Tops and trousers rather than a coat. About 60-80% of people use trousers .

I have already spoken with my higher authorites about removal of clothes is a Must, but they say that it is really time consuming and people tend to waste time during this process.

Any suggestions for this ?



Thank you

Pavan

HI, I would assume that given that you are producing baby food you would have identified a high risk production area within your facility. I would then refer you to Section 4.8.5 of the BRC standard which outlines the requirements the staff facilities that are required to be provided. This includes changing facilities at the entrance to the high risk areas. Similar requirements are required for High Care facilities (Section 4.8.4). Section 7.4.1 only refers to the documentation and communication of the protective clothing requirements.


Not providing the appropriate facilities could be seen as lack of management committment which could be raised as Major or Critical against a fundamental clause.

80F???? 80F!

That's what 27 degrees? THAT'S NOT HOT! Sheesh! Try working in a bakery in summer!

Anyway, even wearing trousers and tops is a compromise when it comes to food safety because you cannot put trousers on hygienically (try it!) But it's a compromise which you have when you have no choice because of temperature.

Seriously, there is no reason why they can't wear coats.

If they insist upon wearing the trousers and tops I would insist on removal for toilets, canteen and smoking. IMO there is no safe way otherwise. The risks are:

faecal bacteria in the toilets, these will be on the floor for example which the trousers may touch.
allergens in the canteen (not all food allergens will be banned) as well as incidental pathogens
smoke (taint) and debris outside (as well as incidental pathogens)

I don't think these risks can be controlled in any other way. Even if you get through audit, is it 'right'? Are you really happy with your staff making baby food with clothing tainted with faecal bacteria, allergens and smoke?

As in previous replies, I would lean more towards all employees wearing coats (frocks). You could look into a different material (lighter) coat for the higher temperature areas thus aiding in not making people uncomfortable while saving time when removal of coats are required.

Jorge

How does the set up work in situations where work wear does have to be removed for using the toilet? I assume you have to install extra large cubicles where you can undress at one end away from the actual toilet as it would be fairly unhygienic to be undressing in a regular/small cubicle right next to it? Also, is all this necessary also for using urinals or just for "number twos"? Do you do away with urinals if so...?

How does the set up work in situations where work wear does have to be removed for using the toilet? I assume you have to install extra large cubicles where you can undress at one end away from the actual toilet as it would be fairly unhygienic to be undressing in a regular/small cubicle right next to it? Also, is all this necessary also for using urinals or just for "number twos"? Do you do away with urinals if so...?

We have a dedicated male changing area and female changing area which opens onto the toilets so they can either get changed into their own clothes or strip off down to underwear to use the toilet without concern about members of the opposite sex.