Nose Ring Risk Assessment
I work as an SQF Practitioner in a bakery, one of the employees put on a nose ring, knowing that it is not allowed to wear jewelry on the production floor, the employee claims that it is a cultural expression, the employee is very good, he never misses work and we don't want to lose it, since today it is very difficult to find employees. He agreed to cover his nose rings with a metal detector band aid, has anyone been through the same situation? And by any chance do you have an example of Risk Assessment for Nose Rings?
Thank you!
Is it cultural expression or religious expression? If it turns out to be religious, you may have to accommodate depending on the law of your state
The MD band aid only covers it---if the band aid falls of unnoticed, the ring theoretically could follow later ---now you have twice as much product on HOLD
If you allow this---you may as well throw all your GMPs out the window---this is an incredibly slippery slope and you will have lost control before you can blink
Everyone is in the same employment boat----reducing requirements will not change a thing except make your life more difficult
Is it cultural expression or religious expression? If it turns out to be religious, you may have to accommodate depending on the law of your state
The MD band aid only covers it---if the band aid falls of unnoticed, the ring theoretically could follow later ---now you have twice as much product on HOLD
If you allow this---you may as well throw all your GMPs out the window---this is an incredibly slippery slope and you will have lost control before you can blink
Everyone is in the same employment boat----reducing requirements will not change a thing except make your life more difficult
Thanks for your comment!
If you allow one person to put an md band aid over a nose ring all of a sudden you'll have others that will want to do the same with earrings etc.
I work as an SQF Practitioner in a bakery, one of the employees put on a nose ring, knowing that it is not allowed to wear jewelry on the production floor, the employee claims that it is a cultural expression, the employee is very good, he never misses work and we don't want to lose it, since today it is very difficult to find employees. He agreed to cover his nose rings with a metal detector band aid, has anyone been through the same situation? And by any chance do you have an example of Risk Assessment for Nose Rings?
Thank you!
You hopefully have a Company (GMP) Poiicy regarding jewelry etc. not being allowed on Production Floor etc. (refer SQF Code).
Simply add nose-rings to the Policy.
Potential hazards which are (appropriately) controlled by PRPs can be regarded as presenting no significant risk in a hazard analysis.
I can't see a way it would be permitted under FDA guidelines nor any GFSI program. If the person wants to press the issue under a cultural or religious protection, you'll run into one of those situations where a state/federal law conflicts with food safety.
In a previous plant I ran QA for, we had employees complain to OSHA that we prohibited them from taking water bottles into the production area. This rule was to comply with 21 CFR 117 subpart B, but OSHA cited their code that workers in hot environments be able to stay hydrated (can't remember the part). We pointed out the FDA GMP and informed them employees are not prohibited from taking water breaks in the break room, and that was deemed unacceptable as the breakroom was too far from their work area.
I share that story just to say good luck if the employee decides to push the issue, but the nose ring is prohibited under US law and most GFSI codes.
Thank you so much for your comments!
All of our employees are required to wear face masks (even prior to COVID). Someone could have a nose ring on and nobody would even know.
Not saying they are acceptable, but nobody would know and they aren't visible.
We also require employees to be clean shaven and haven't received any negative comments from that.
Our hygiene policy states specifically no nose-rings, earrings, necklaces, etc. that cannot be covered with clothing. The exception we have are stoneless wedding bands and medic alert bracelets/necklaces. Even those have to covered with gloves, necklaces tucked under clothing, for safety reasons beyond food safety.