This article is written to meet the following sections of the Standards:
|BRCGS Food Safety Issue 8||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 5.1||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 7||3.2.1, 3.2.2 Personal hygiene|
3.2.8 Protective clothing
|SQF Edition 9||18.104.22.168 – 22.214.171.124 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.
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.
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.
- 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.
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).
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.
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.