Protective Clothing

We produce direct food contact cartonboard packaging. For the past 20 years our production team have worn hair nets, beard snoods, shoe covers and long sleeve jackets with no external pockets.

During a recent audit it was raised that we were not required to wear the long sleeve jackets and they could be replaced with short sleeve "scrub tops" as long as they had no external pockets and were only worn in the same production areas as the long sleeve jackets were.

My concern is that whilst one auditor may think this acceptable another one might not and raise a non-conformance. 

We have to wear hair nets and beard snoods to protect against the risk of lose of hair - people have hair on their arms and if we move to short sleeves we will have nothing to protect this from potentially contaminating finished product.

Im interested to hear what other people do in a similar position.

Thank you,

Andrew

Hi Andrew,

Your concern is reasonable. Although you are not required to wear long sleeve jackets, but you choose to wear them to minimize risks, go for it!

Another auditor may not necessarily give you NC for it (short sleeves), but if you find it risky for your business then don't. 

Aw man, been through this!   One of the major gripes with these systems on this wonderful site, is they're open for interpretation in many ways.

So we had an auditor write us up for nothing having sufficient handwashing sinks.   We only had one large sink, but it was at the only door into production, and it was actually really easy to see if everyone was washing their hands.   There would be a line at break time and stuff of course, but time loss isn't NSF's problem, right?   That's up to our owner....    Anyway, the wrote us up for that, so we added two portable handwashing sinks to our dry mix blending facility.   The next auditor the following year said 'this is insane, water is the last thing you want in this facility', sooooooo we took um back out....lol.

Can't make up this level of insanity....

And I'll say this:   Whatever I decide to do in here now, I back it up with a risk analysis or some like data, to back up my decision making process.   It makes it harder for them to find fault or have differing opinions on your operation.

Good luck!

I'd suggest it depends on how hands on your staff has to be with the process.  If it's primarily machines doing all of the work on the food contact surfaces of the packaging, operators standing by to move cased and protected product, I think you can write a risk assessment that supports the shorter sleeves.  If your operation has employees dedicated to standing at machines to help the products flow down the line, maybe hand boxing/bagging the cartons you produce, I think the longer sleeves are justified.  I do admit bias for full sleeve smocks: I think it's just more sanitary in general and hard to argue against, but concessions can be made where no actual risks are observed.

If you do find you can switch out to short sleeve smocks, I'd suggest making sure your hand washing in your GMP includes washing the exposed forearms when employees enter the production area.

I've been an Auditor and now a Consultant - One key thing I learned early on is that Auditors are "Reporters" and not "Consultants"  Just because an Auditor tells  you it is not required doesn't mean you should make a change in fact the next Auditor will tell you something else - they need to stick to what they do.