How to determine the personal hygiene requirements for your site

Contents

• The standards.
• The requirements 
• BRCGS Food Safety Issue 9.

The standards

This article is written to meet the following sections of the Standards:

The requirements

Risk assessment

You must risk assess what personal hygiene controls are needed for your product and then each area of the site. In theory, if you apply a high level of personal hygiene – you don’t need to do a risk assessment. However, many standards (for example BRCGS Packaging) haven’t stated a risk assessment is needed. Which means you may fall foul of getting a non-conformance if you don’t do one – even if your personal hygiene standards are really good.

For this reason, the requirements for personal hygiene will vary depending on your site, but what we can tell you clearly – is what the minimum requirements should be in areas where the product is open, if your product is food or food contact packaging.

Standards of personal hygiene

The standard expects there to be a high level of personal hygiene where the product is open and the product is either food or food contact packaging. Where product is enclosed and doesn’t come into contact with food (or other hygienic products like make-up or toiletries) the level of personal hygiene doesn’t need to be as high and can be reduced.

Procedure

There must be a document which details the site personal hygiene rules. The rules must be communicated to all staff through training. The best way of doing this is to have a procedure – rather than having separate policies. You can then use this procedure to train your Staff. The term ‘staff’ includes agency workers, visitors and contractors.

Minimum handwashing requirements

The minimum requirements for handwashing on entry to open product* areas, is that hands must be washed:

• Before entering open product areas.
• After any break which involves leaving the product area.
• After going to the toilet.
• After eating or smoking.
• After blowing your nose or sneezing.
• After handling shoes.
• After handling waste (including dropped product or contaminated material).
• After handling cleaning equipment.

The handwashing method must take at least 20 seconds:

• Wet hands with water.
• Apply soap.
• Rub the hands so that all the parts of the hands are cleaned, including palms, backs of hands, between fingers, backs of fingers, thumbs and fingertips.
• Rinse hands to remove soap.
• Dry hands thoroughly.
• Sanitise if necessary.
• Handwashing instructions with pictures, must be in place, and these must be provided in the appropriate languages.

Minimum jewellery requirements

• The minimum jewellery requirements for open product* areas are:
• Wrist bands, wrist-worn devices or watches shall not be worn.
• Jewellery must not be worn, with the exception of a plain wedding ring or wedding wristband.
• Rings and studs in exposed parts of the body, such as ears, noses, tongues and eyebrows, must not be worn.
• Religious jewellery and medical jewellery are only permitted if the item is totally covered with the wearer’s clothing or PPE.

*Where the product is food or food contact packaging.

Minimum requirements – personal items

The minimum requirements for personal items in open product* areas are:

• Personal belongings, including personal mobile phones, must not be taken into production areas without the permission of the management.
• Smoking equipment must not be taken into product areas.
• Spectacles are allowed, all staff must be trained to understand that they must report any broken, damaged or lost spectacles and contact lenses to a supervisor immediately.
• Fingernails shall be kept short, clean and unvarnished.
• Nail varnish, nail art or false nails shall not be permitted.
• Excessive perfume or aftershave shall not be worn, as this has the potential to taint foods.

*Where the product is food or food contact packaging.

Requirements for enclosed product areas

If you don’t apply the rules for open product in enclosed product areas, then you need to be able to justify why. This means a robust risk assessment must be carried out that explains that all of the following are true and therefore there’s no risk to the open product:

• The open and enclosed product areas are segregated.
• Staff in these areas don’t pass through the open product area to get to or leave the enclosed product area.
• Staff don’t go into the open product areas without applying the open product area rules.

Smoking

Smoking is only allowed in designated areas and not in locker rooms, changing facilities or product areas. This includes e-cigarettes.

Eating and drinking

Eating and drinking is only allowed in certain areas, which are away from the product. No food, including sweets, chewing gum and tobacco, or drinks shall be taken into product areas or stored in locker rooms.

BRCGS Food Safety Issue 9 – changes to personal hygiene

Clause 7.2.1 has been expanded to:

• Clarify that all wearable devices are not allowed, such as apple watches, fit bits etc.
• Include a new requirement to have documented rules about portable devices which are permitted (because they’re company issue).
• Clarify that tongue piercings are now not allowed, as they are deemed to be an exposed part of the body.
• Clarify that translated training should be provided for staff where needed.