13. Personnel
Personal protective clothing (PPC)
What standard needs to be applied and when for protective clothing
The standards
This article is written to meet the following sections of the Standards:
| BRCGS Food Safety Issue 9 | 7.4 Protective clothing: employees or visitors to production areas |
| BRCGS Packaging Issue 6 | 6.5 Protective clothing |
| BRCGS Agents & Brokers Issue 3 | Not applicable. |
| BRCGS Storage & Distribution Issue 4 | 9.6 Protective clothing (Handling of open product) |
| FSSC22000 Version 6 | No direct clause to reference other than there must be a PRP for general personal hygiene (ISO 22000:2018 8.2.4j) which is where protective clothing would sit. |
| IFS Food Version 8 | 3.2.1, 3.2.2 Personal hygiene 3.2.8 Protective clothing |
| SQF Edition 9 | 11.3.3.1 – 11.3.3.7 Clothing |
The requirements for protective clothing
Personal protective clothing (PPC) or personal protective equipment (PPE)?
It’s common for us to call protective clothing – PPE. But actually, it should be PPC – Personal Protective Clothing, as PPE is Personal Protective Equipment, which is typically worn for H&S purposes. Whereas PPC is worn for food safety purposes.
Risk assessment
PPC needs a risk assessment – to determine the rules and what controls are needed. Every site may have slightly different rules, but what we can tell you – is what is required where the product is open, and the product is food or food contact packaging.
Procedure
There must be a document which details the site rules for Personal Protective Clothing (PPC). The rules must be communicated to all personnel 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 personnel. The term ‘personnel’ means, staff, agency staff, visitors and contractors.
Open product (food and food contact packaging) areas
When product* is open the following must be worn:
- Designated footwear.
- Overalls.
- Hairnets, covering all scalp hair and ears.
- Snoods for facial hair.
- Task-based PPC such as arm sleeves.
*Product is either food or food contact packaging.
The procedure for PPC must also include:
- Required design elements of the protective clothing.
- The process for how PPC must be put on and taken off.
- When PPC must be taken off and how to store it when not in use.
How stringent the exact rules are must be determined based on risk, but as a minimum – overalls should be removed before entering the toilets, canteen or before going to smoke.
Design
The procedure should define the key elements of design, that protect the product, including:
- Footwear must be designed so that it can be kept clean.
- The design of disposable protective clothing must not pose a risk of contamination.
- Overalls must not have external pockets above the waist or sewn-on buttons.
- Gloves must be made of food-grade material which is a visually distinctive colour from the product (preferably blue).
Disposable PPC
PPC which is disposable must be managed so that it doesn’t become a foreign body risk. It must be changed if it becomes damaged.
Where items aren’t disposable but have a life span – such as gloves, they must be checked regularly so that they’re disposed of before they become a risk.
Changing frequency
Overalls must be changed daily, or when they get dirty – whichever is sooner. If they’re not changed daily, the frequency at which they’re changed must be justified through risk assessment, using data from visual inspections, swabbing or contact plates.
Hairnets must be changed daily or whenever they’re removed. A hairnet must not be put back on, once it’s been taken off – this is because it might be put back on the other way out. Meaning the side of the hairnet that touched the hair, will end up on the outside, and this means that if hair is stuck to it, it may then drop onto the overall.
Protective clothing must be provided in sufficient quantities and in good condition, so that personnel can follow the rules.
Where product isn’t open
Protective clothing wouldn’t be required when all of the following conditions are true:
- The product in the area isn’t high-risk, high-care, or ambient high-care.
- The product is fully enclosed, either in packaging or by sealed equipment.
- The area is physically separated from areas where the product is open.
- People don’t pass through any open product areas to access the area in question.
Protective clothing would also not be required where the product is non-food contact packaging.
If all of the above criteria are met, the justification for not applying protective clothing must still be documented through a risk assessment.
BRCGS Food Safety Issue 9
There weren’t any changes in BRCGS Food Safety Issue 9 that impact this article.
A great and helpful article.
I have a team working in an open food environment. Chilled room around 1.9 degrees Celsius. Would laundered jackets and a thermal top underneath be sufficient?
Hi Chris,
Yes, that would be fine. The most important part is that the laundered items cover those that aren’t laundered.
Kassy
Hi Kassy,
Do you have any guidance on the style of hairnets which should be used? I firmly believe that certain hairnet styles have holes which would not contain all hair even if worn correctly. The standards I have seen only state ‘must contain all hair covering all scalp and ears’ or to those words.
Thanks in advance
Hi Josh
No, this is not something I’ve ever come across I’m afraid.
Please do share if you find anything!
Kassy
Hi kassy,
If risk assessed would half zip jackets with a zip collar be acceptable on the production floor in a brgcs aa+ site, metal detectors are in place on all lines. And zips are enclosed and covered with a material.
Just a question posed to me by the hr team
Thanks
Shaun
Hi Shaun
There’s no issue with zips, especially if the jacket is laundered. I’m not sure if that’s the context that you’re thinking?
Kassy
hi – would protective hats (bump caps/hard hats etc) used for H&S been deemed as PPC in a low care environment? Trying to determine if these can be stored in personal or PPC lockers?
Hi Emma,
They should be stored in the PPC lockers, as they’re worn inside the factory.
Thanks
Kassy
Hi Kassy,
Thanks for this article.
Would like to seek your opinion.
We are ambient high care and face mask is a must for us. Our order for protective clothing is:
1) face mask
2) Hair net (so that staff does not need to fiddle with the hair net again to loop on the face mask)
3) Overall
4) Boots
5) Wash & Sanitize hands
6) Disposable gloves (can be donned at production area or at the changing area itself)
Any issues? Is the above order justified?
Thanking you in advance.
Hi Judy
It depends on what zone you’re going into. Ideally, you would wash hands after touching the face and hair, as well as after putting on boots. I would move boots to number 3, then wash hands, so that you put the overall on after that.
Kassy
Hi Kassy,
Could you please advise if fleece with inside pockets is allowed in production?
Hi Ema
Unfortunately, the answer is ‘it depends’.
If you mean over the top of your whites, and the product is open in the area – then no. UNLESS, you’re going to wash the fleece as often (and to the same standard) as your whites.
Kassy
hello Kassy
kindly asking for some advise please
PPC is worn in the open bag area where operatives pick from open products, . However, when they need more product they enter the warehouse to get it but dont change .
my second question is the personel wears black safety shoes inside and outside of the prduction area to move between sites .We are low care ambinet blending operation ? no desinfection of the shoes just a dry brush .
Hi Anytsuj
With regard to the first question – I’m presuming that operatives don’t need to wear PPC in the warehouse? If that’s the case, then it depends. Would going into the warehouse in their PPC put the cleanliness of their PPC at risk? Do they come into contact with personnel who are not wearing PPC?
Regarding the second question – Staff shouldn’t wear their inside shoes to go to other sites. But if you have a designated walkway between the sites, which is cleaned then you could mitigate the risk. You would need to do a risk assessment to identify the risks and the controls that you need.
Kassy
Dear all, Please advise how the requirement to wear beard and moustache protection is interpreted. When such protection must be used (visible hair, three-day beard, over 1 cm?…..etc.). I would appreciate your guidance on this topic.
Hi Danuta Swies
This is the age old question! There is no set rules for this and so you can come up with your own rule. Some sites say that you need to be able to pinch it, some say any visible hair requires a hairnet.
Kassy
Hi Kassy,
If long coats are worn in open product areas, would operatives still need to wear trousers that are provided by the company and changed on a daily basis. We are looking to stop providing trousers so staff would just wear their own that they have come to work in. Would this be acceptable. Thanks
Hi Kate Louise,
No, as long as the coats are to the knee – then it doesn’t matter what is underneath (within limits).
So to answer your question, yes that’s acceptable.
Kassy
Hi Kassy,
I am looking for some advice on the wearing of trouser belts in a food factory. Most workwear comes half elasticated but that isn’t enough to hold trousers up. Is there any specific type?
Many thanks
Helen
Hi Helen,
This would depend on whether the belt was underneath PPE. If staff are wearing a knee length coat, then in theory, there are no requirements to control the garments underneath. Unless you work to retailer standards, who specify certain things (like no sequins).
Kassy
Hi Kassy
Could you please advise if protective clothes with zippers are allowed ?
Hi Ema
Yes in theory, you’d just have to make sure that the cleaning technique validation included assessment of the gaps inbetween the zippers. But there’s no risk from a zipper causing a foreign body, that’s any greater than a press stud.
Kassy
It would be good to include a section on the actual procedure to put on – and remove – PPC. The relevant BRC standards don’t always stipulate a stringent order that personnel need to go through when entering or exiting high risk, low risk and enclosed product areas and I’ve been at numerous sites that seem to spend a lot of time debating the running order of applying PPC and when the hand wash stage(s) is/are required.
Also, the last paragraph where enclosed product areas are mentioned and a list is provided where all need to be met to avoid using PPC in those areas – I wouldn’t necessarily agree with the first point about the products being high risk, high care or ambient high care. As long as the product is in its enclosed/finished packaging
and segregated from open product areas (and people working in open product areas) then I don’t think PPC is needed as I’ve rarely seen standalone warehouses, cold stores, etc. (who store a range of food products/packaging) feel the need to enforce PPC procedures.
Thanks Danny, our intention is to add to these articles as we go – so we can definitely look at adding this detail in, in the future.
Hi Kassy excellent article.
Can you please advise about following points
1. Protective shoes: can you wear them both in open production site and outside?
2. Hairnets and snoods would you wear them outside environment and in production site if they were not removed?
Thank you.
Hi Ankit
Protective shoes should be kept to inside. There can be agreed exceptions to this, for example for goods in staff who’s role involves going inside and outside on a regular basis.
Hairnets and snoods are primarily used to stop hair getting onto the product, so when worn in low-risk areas they can be kept on when leaving the area. However the rule I would apply is where there are people not wearing hair nets then they should be removed. Because if you think about it, if you’re wearing a hair net and go into a room with 2 other people who aren’t then you have a chance of thier hair getting on your hair net. Which defeats the object of wearing it.
I hope that helps.
Kassy
As always, spot on article.
We actually having a debate here on wearing facemask (Covid) and a beard snood. Are you have to wear both?
interested in your opinions.
Hi Michael,
Thank you!
Regarding your question – the facemask isn’t a requirements for BRCGS. So really what you’re asking is do you have to wear a snood (I’m presuming if you have facial hair)? The answer of course is yes.
The facemask with beardsnood is the old issue of health and safety versus food safety. Same as hairnet and ear defenders (hairnet over ears or not?). Some of the rules contridict each other.
So yes, both is needed and ideally to provide the seal for the facemask to the face, the snood should go over the top.
Kassy