Establishing a Policy: Head to Toe A clear uniform policy that is adhered to by employees not only prevents product contamination, but also is critical to passing an audit.

10 November/December 2010 AIB UPDATE Policies & Procedures

n today’s world of documentation and written policies, it is not uncommon to find food plant managers covered in paperworkI and overwhelmed by the amount of work required to actually develop effective plant policies that meet their specific needs. One problem that managers face is the lack of guidance and resources available to write effective food plant policies that not By Kerry Beach and only meet regulatory and customer requirements, but also meet their plant’s unique challenges. Stephanie Lopez One important plant policy that applies to every employee and may be difficult to design is the uniform policy. The GMPs and many food industry standards require that food plant personnel wear clean or work clothing that are not decorated with items that could easily fall into the product. But, aside from very general requirements (i.e. suitable footwear, clean uniforms, effective restraints, no shirt pockets, etc.) there is not a lot of specific direction provided for developing a more detailed policy. This article provides a head-to-toe look at the items that should be considered in a uniform policy that not only meet industry require- ments, but go above and beyond the basics to ensure that employee uniforms are not a source of food product contamination. The focus is food safety. Employee safety implications must also be considered, but are not fully examined here. Consider these suggestions as they apply to your food facility and examine your uniform policy to determine if any updates are needed. And keep in mind that a good uniform policy will address all plant personnel, not just production.

HEAD Hard /Bump What’s the first thought that comes to mind when you see someone wearing a hard hat or bump cap? If it’s out of context, then you probably assume that person works in construction or a job where safety is an issue. Many food plant workers, especially maintenance employees, wear hard as part of their daily job. When consider- ing whether or not to include this item as part of your employee uniform, answer a few questions: • Is it needed for safety? • What positions or departments should wear the hats for protection? Although hard hats are a safety device used to offer head protec- tion, they can also be a hindrance because they can limit vision. This should be considered when selecting the size and style of hard hat to issue employees. Another thing to consider when selecting hard hats is to order a variety of colors. Some plants use a color-coded hat system to identify departments or employee seniority levels. Others may color-code hats by area, such as pre-kill step (red), post-kill step (blue) allergens used (green), and non-allergen area (white). One excellent idea is to have a designated color of hard hat that visitors or contractors wear to easily identify them as non-employees. In addition to employee safety concerns, food safety consider- ations should also be made. The uniform policy should clearly state the predetermined frequency and necessary procedures as part of

November/December 2010 AIB UPDATE 11 Policies & Procedures

1 the bump cap/hard hat cleaning program. covers.” (Stnd 1.30.1.3) However, it is up to • More than ⁄8 inch. The policy should also make it clear that each facility to determine any more specific Like hair covers, beard nets must be hard hats are not to be taken off-site, but policy inclusions. clean or new at the start of each shift. must remain in employee lockers or other It may not seem as if employee safety on-site storage area. would be a consideration when determin- Eyewear Stickers and other adornments should ing the type of hairnet to provide employ- Eyewear worn in food facilities may include be prohibited, but there is an excellent op- ees, however the material is important to corrective vision , safety goggles/ portunity to attach tethered earplugs to the consider, especially for those who work in glasses and face shields. Special activities hats, if used at the facility. This will prevent areas where welding takes place. Certain may require safety devices to be worn the loss of earplugs in the facility and help materials may cause a spark hazard. The to protect the eyes. The uniform policy your facility avoid instances of product hairnet material selected is also important should address the use of safety glasses contamination. to food safety. Some food facilities require or face shields, including whether or not Finally, the policy must clearly establish fine-mesh hairnets, while others use the they are required to be tethered to other that bump /hard hats are not a substi- bouffant style. Regardless, it is important to parts of the uniform (i.e. the hard hat). tute for hair nets. Effective hair restraint is realize that wide-mesh hairnets are ineffec- Another eyewear concern to address in required beneath the caps/hats. tive at preventing hair from contaminating the uniform policy is employee eyeglasses the food product. worn to correct vision. Does your facility (Head coverings for warmth) One hair cover requirement that all allow employees to wear their own eye- Employees that work in cold areas of the fa- plants agree on is that the items are clean glasses? Can they be worn in lieu of safety cility where frozen or refrigerated products at the beginning of each shift. However, glasses, where applicable? Many designer are handled or stored will often wear ad- a not-so-clear area of debate is whether eyeglasses are decorated with rhinestones or ditional items with the standard employee employees with shaved heads are required other such adornments. Your policy should uniform, such as knit caps, to keep warm. to wear hairnets. This is up to each plant address whether these are acceptable. Sometimes these are company-issued caps; to determine requirements. A shaved head Either the Glass & Brittle Plastics Policy other times facilities may allow employees is “effective hair restraint” and meets AIB or the uniform policy should clearly state to wear personal caps. Either way, there and government requirements; however for how employees are to report missing or are certain food safety considerations to enforcement purposes, it may be easier to broken eyeglasses or contact lenses and to include in the uniform policy. require that all personnel wear hairnets. whom they report. Each food company should determine Surprising to some, a “one size fits all” if it will require hairnets to be worn in approach is not acceptable for hairnets. Hearing Protection conjunction with these items. Most head If the net is too large it won’t be tight or In the world of OSHA and other employee coverings for warmth will fully contain hair contain hair. Conversely, if it is too small, safety regulations, it is important, not and therefore hairnets are not required. hair will stick out, making it ineffective. only as an employee service but also as a However, some companies decide that Each plant should ensure that the correct requirement, to provide hearing protection “everyone wears a hairnet” and require the sizes are available for all employees. and conservation devices. First determine hairnet to be worn over the knit cap. One Hair cover color is another consider- if hearing protection is required at your thing to consider is that if the knit cap is ation to address in the uniform policy. facility. If so, is it area or position depen- covered with a hairnet, it is more difficult On most people, dark colored hairnets, dent? Your facility’s expectations on when to identify dirty caps. On that note, the such as brown and black, make it difficult and where to wear hearing protection policy should also include that knit caps to determine if they are wearing a hairnet devices will need to be clearly defined in must be regularly laundered and specify without looking closely. As with the hard the uniform policy. Also, it is important to if it will be done by employees, in-house hats suggestion, some plants assign dif- determine if employees encounter a safety laundry, or a contracted service. The policy ferent colors of hair covers for various conflict when driving a forklift while wear- should also state that knit caps must be departments (high-risk vs. low-risk areas) ing hearing protection. If it is determined in good condition. Loose threads are an or assign a certain color to identify visitors that there is a conflict, another method of adulteration concern. or contractors. protection should be provided. Facial hair is not exempt from the hair Although hearing protection is primar- Hair Covers restraint standard. It is up to each plant to ily an employee safety issue, it also needs to The AIB Consolidated Standards for Inspec- define which type of facial hair requires be addressed in the uniform policy from a tion, which are based on the GMPs and a beard net. Some common approaches food safety perspective. If custom-molded common industry expectations, requires include: earplugs or ear muffs are used, the facility that “Personnel wear effective hair restraints • Any facial hair below the corner of the should have a cleaning program in place to fully contain hair, if applicable. Hair mouth. that addresses the frequency of cleaning and restraints include head, beard or moustache • More than a day’s growth. the procedure used to prevent contamina-

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tant role in employee safety facility should consider the various tasks and product safety. Some undertaken in every department to deter- facilities, especially those mine if aprons are necessary for employee in cold climates or where safety and include these instances of use in employees will be working the uniform policy. in refrigerated or freezer areas, When aprons are used, there are certain allow long sleeves to be worn at food safety considerations to keep in mind work. In these instances, it is important related to each type of material. For ex- to consider the potential for long sleeves ample, disposable aprons tend to tear easily getting caught in equipment. This is an and metal mesh aprons could pose a metal important employee safety issue. contamination risk. Cloth aprons are often tion. If disposable earplugs are Sleeves, pockets and buttons are prob- used in food plants, but are not appropriate used, the policy should define the frequency ably the three most important items to for micro-sensitive products or around vari- of replacement. inspect on employee shirts. At a minimum, ous powdered allergens because they can It is best to use earplugs that are brightly the sleeves should cover armpits to prevent easily cause cross contamination. If cloth colored and even better if they are a differ- hair and sweat contamination. Shirts aprons are part of the standard uniform, the ent color than the product being produced should not have any pockets. If a uniform policy should address who will launder the so that they can be detected easily. As company provides the shirts and they come items: the employees, an on-site laundry previously mentioned, a suggested practice with pockets that cannot be removed, they service or a contracted provider. If aprons to include in your uniform policy is the should be sewn shut to prevent items from are only needed during particular opera- requirement for earplugs to be tethered to being carried in them and falling onto the tions, such as while weighing allergens, this hard hats to prevent them from being lost product line. Additionally, shirts should should be specified in the policy. or misplaced. either be pull-over style (i.e. t-shirts) or Aprons should never be worn in rest- fasten with snaps, not buttons. If street rooms or employee break areas. There Other Head Gear clothes may be worn, the uniform policy should be designated hooks for storage Any other type of head gear that is allowed should specifically address that no adorn- when employees leave their work areas. Ad- to be worn while on the job should be ad- ments (buttons, beads, etc.) be worn. ditionally, separate hooks for different risks dressed in the facility’s uniform policy. For Some plants choose to provide color- (i.e. pre-kill and post-kill stages, allergen example, sweat bands or “do-rags” are com- coded uniform shirts by department or by segregation, etc.) are needed to prevent monly used in hot environments to contain plant area, as with hard hats and hairnets. cross-contamination from occurring when sweat. These should be clean at the begin- If a color-code system is used, it should aprons are placed next to other aprons from ning of each shift and are typically provided be included in the uniform policy so that different areas. by and laundered by the employees. everyone knows which color of shirt is worn Although they are allowed by some food by which department or area. Smocks/Lab Coats facilities, baseball style caps are not recom- Additionally, facilities should include Similar to apron usage, some food plant mended as a standard part of the employee provisions for shirts for new or temporary departments or activities may require uniform. There is a high risk of personal employees who do not have company- employees to wear smocks or lab coats as caps being brought in, which could be in issued uniforms. part of the uniform. In addition to sleeve unsanitary condition. Some companies length, the length of the smock or lab coat may decide to make an exception for Aprons should be short to reduce the likelihood of company-issued caps that are only worn Aprons may be worn over clothing as an the item from getting caught in equipment. in the plant. If this type of cap is permit- additional protective measure. From a Lab jackets, which are shorter in length, ted, the facility should decide if it will be safety perspective, plants should consider are a good alternative to smocks or coats. worn over or under a hairnet. It should be the likelihood of the aprons getting caught The sleeve end is another important safety noted that these caps often interfere with in equipment and harming the employee. consideration. Plants should determine if the effectiveness of hairnets. In areas where this danger is likely or pos- open-ended or elastic-cuff sleeves are to sible, aprons should be prohibited. Certain be used. TORSO plant activities, especially maintenance Like the shirt requirement, no exterior Shirts tasks, may require that vinyl aprons be pockets above the waist should be present We’ve all seen the restaurant signs saying worn as part of the required Personnel on outer garments. Pockets on the inside “No shoes. No shirt. No service.” However, Protective Equipment (PPE). Metal mesh of coats are acceptable, because items for the food industry the requirements are aprons are also sometimes worn for cutting will not fall out if personnel bend over, a little more specific than just wearing a operations (i.e. butcher) to protect the and pockets below the waist are typically shirt! The type of shirt plays a very impor- employee’s body from harm. Each food okay because they are not generally above

November/December 2010 AIB UPDATE 13 Policies & Procedures product and pose less of a risk of product must be designated storage areas for them. • Slip-resistant contamination. If coats come from a uni- Be careful of employees writing their names • Flat form company with upper, exterior pockets on the gloves with a marker that could leach • Closed-toe and closed-heel. that cannot be removed, have them sewn into the product. In addition, some plants adopt a captive shut. Also, no buttons should be present shoe policy, in which shoes worn in work on smocks or lab coats. Instead, Velcro or Sleeves areas do not leave the company premises. snaps can be used as closures. Sleeves are commonly worn in chemical- In this case, a direct area should be provided Like other items previously mentioned, handling and cut-produce operations. If for employees to walk in their street shoes the color-code system can be used with worn, the facility should evaluate the risk to a changing area where the work shoes smocks and lab coats. A great suggestion is of the sleeves getting caught in equipment are provided. If a captive shoe policy is to use color-coded outer garments to iden- and take precautions to prevent this from used, visitor provisions should be included tify visitors, even if these outer garments are occurring. The uniform policy should in the policy. not part of your employee uniforms. state when sleeves are to be worn as PPE, The use of steel-toed shoes should also especially when handling chemicals. be reviewed and determined by the plant’s Coveralls safety team. Coveralls have a unique food safety hazard One important linked to them. When using the restroom, plant policy that WRAP UP a majority of the coverall is lying on the Uniform policies must be risk-based. High- floor unless it is completely removed from applies to every risk products will include provisions for: the employee’s body. This is unsanitary and employee and • No uniform component (including a source of contamination. The uniform may be difficult footwear) may be worn off-site. policy should address how coveralls are to to design is the • Easily removable outer garments are be handled during restroom visits. uniform policy. provided and are removed when per- Coveralls are no exception to the “no sonnel leave processing areas. They are pockets, no buttons” requirement previ- As with reusable gloves, there must also never worn into restrooms or on breaks ously mentioned. There should be no be designated storage areas for reusable (including smoking). exterior pockets above the waist; however sleeves. Furthermore, the same cautions Every food plant should have a uniform pockets inside coveralls are acceptable be- should be taken against employees writing policy defined in writing and enforced. cause items will not fall out if personnel their names on the sleeves with a marker A good uniform policy will address all bend over. Also, pockets below the waist that could leach into product. Washable personnel, not just production personnel. are okay in operations where the product plastic sleeves, such as those worn in cut- Safety considerations are unique to each is at waist level or above. If coveralls come produce operations, should be considered plant. A complete review of all uniform from a uniform company and have upper/ as a food safety element. components by the company’s safety of- exterior pockets that cannot be removed, ficials is imperative. they should be sewn shut. LEGS From the food safety perspective, there Pants is a trend in GFSI-benchmarked audits ARMS/ HANDS Long pants should be worn to protect to include a provision for validating the Gloves against scrapes and hot surfaces. Short cleanliness of uniforms. A clear uniform Gloves are often used in food facilities for pants are often worn in areas with a high policy that is adhered to by employees not warmth, for handling hot surfaces, for heat index. With either length, buttons only prevents product contamination, but cutting operations, and most commonly, pose a greater risk of product contamina- it also helps plants pass that part of their for food handling. In fact, some states and tion than snaps or clasps. If street clothes audits. some customers require gloves to be worn can be worn, the policy should state that It is so important that a good policy is by food handlers. they must be clean at the start of each shift. not only developed, but also implemented It should be clear to employees that Cargo-style pants with exterior pockets in a way that educates employees about the gloves are never a substitute for hand- located on the lower thigh area are often ac- importance of the “rules.” When the why washing. Gloves should not be taken out of ceptable for storage of tools (thermometers, is just as important as the how or when, a processing areas when an employee takes a stopwatch, pens, etc.). practice is necessary so the policy’s mes- break or uses the restroom. Gloves should sage will be more easily understood and be changed as often as hand washing is FEET followed. AIB required. Disposable latex gloves are not Shoes recommended because of a growing allergy There are a few safety requirements that The authors are Publications Coordinator and risk. Nitrile is an appropriate alternate shoes worn in food facilities must meet. Director, Food Safety Education respectively, for material. If reusable gloves are used, there They should be: AIB International.

14 November/December 2010 AIB UPDATE