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

BRCGS Food Safety Issue 87.4 Protective clothing: employees or visitors to production areas
BRCGS Packaging Issue 66.5 Protective clothing
BRCGS Agents & Brokers Issue 3Not applicable.
BRCGS Storage & Distribution Issue 49.6 Protective clothing (Handling of open product)
FSSC22000 Version 5.1No 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 73.2.1, 3.2.2 Personal hygiene
3.2.8 Protective clothing
SQF Edition 911.3.3.1 – 11.3.3.7 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.

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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.

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Have your say…

6 thoughts on “Personal protective clothing (PPC)

  1. 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.

    1. 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

  2. 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.

    1. 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

  3. 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.

    1. 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.

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