Personal Hygiene: A Basic Prerequisite Program for Ensuring Food Safety
By Richard F. Stier
Personal hygiene is (or should be) an integral part of the food quality and safety for each and every food processor. In the United States, Current Good Manufacturing Practices in Manufacturing, Packing or Holding Human Food (better known as cGMPs) found in 21 CFR Part 110:10 includes a section entitled “Personnel.” The elements within this section may be found in “Personnel,”, and include disease control, cleanliness, training and supervision. The Codex Alimentarius Food Hygiene document includes similar guidelines (see “Section 7 — Establishment: Personal Hygiene”). All third-party audits, both those approved by the Global Food Safety Initiative (GFSI) and private audit schemes, also include personal hygiene requirements. One of the things that many food safety professionals like about the U.S. GMPs is that this is an interpretative regulation—it allows the food processor leeway to meet the spirit of the law. In other words, there are different ways to comply with the regulation. On the other hand, there are those who feel that the GFSI-approved audit schemes, with the exception of FSSC 22000, are too prescriptive. The company must do it GFSI’s way or they are in violation.
Let’s take a look at what makes up a company’s personal hygiene program using the GMPs as a guideline and the steps that food processors should take to protect their products. Operators must understand that personal hygiene is more than just rules for the workers. Plant management must develop, document and implement the necessary procedures, provide the necessary tools and equipment, set an example and provide the workforce with necessary training so that they understand what is expected of them.
The object of this is clearly defined in the GMPs. Food processors should not allow any worker who is sick or has open wounds in a food-handling environment, especially if “there is a reasonable possibility of food, food-contact surfaces or food packaging materials becoming contaminated; [that worker] shall be excluded from any operations that may be expected to result in such contamination until the condition is corrected.” In other words, food plant workers themselves should not pose a risk of contamination of food. In the U.S., enforcement of this falls on both management and line workers. Training programs must address this issue. Workers should be instructed to notify management if they are sick or injured, and cannot handle foods. Managers should also have the training and observation skills to notice whether someone is injured or ill. This is one area where plant management can go far toward ensuring enforcement. Many food plant workers are hourly wage earners, so being sick or injured could cost hours and money. If plant management creates a program whereby someone who is ill can be assigned to a task where he or she is not handling food, they will be more prone to notify management rather than try to hide their illness.
Worker health is handled differently in other parts of the world. In many countries, especially in Asia, food handlers are often given a battery of tests every year. These tests may include, but need not be limited to, blood tests, stool samples for intestinal parasites and pathogenic bacteria, and chest X-rays for tuberculosis. Workers who fail the tests are not allowed to work until they test clean. Publicly available standard (PAS) 220, published by the British Standards Institute, contains the following language in Part 13.5:
“Employees shall undergo a medical examination prior to employment in food contact operations (including site catering), unless documented hazard or medical assessment indicates otherwise.
“Additional medicals shall be carried out at intervals defined by the organization, subject to legal restrictions in the country of operation.”
PAS 220 is utilized with ISO 22000 as part of the FSSC 22000 scheme. Note the language in paragraph 2, that is, “subject to legal restrictions in the country of operation.” This kind of testing is not allowed in the U.S. and parts of Europe, as it is deemed a violation of privacy.
On the subject of clothing, the GMPs state that among the methods for maintaining cleanliness are the following: “Wearing outer garments suitable to the operation in a manner that protects against the contamination of food, food-contact surfaces or food-packaging materials” and “Wearing, where appropriate, in an effective manner, hairnets, headbands, caps, beard covers or other effective hair restraints.”
Suitable garments will depend upon the type of processing operation and management’s commitment not only to food safety and quality, but also to worker safety.
Food plant workers should wear hairnets that contain and cover all the hair and ears. Many operations also mandate that workers wear bump caps. Baseball caps should be discouraged as they not only do not properly contain a worker’s hair, but they are often filthy. Workers who have beards and/or mustaches should ensure that they are fully covered. Some operations waive this requirement for workers with neat mustaches and go on to define what constitutes a “neat moustache.” It is much easier to define a requirement than to create a system where something must be interpreted. Management should also consider the type and color of hair restraints that they buy. Workers often feel that hairnets with wider mesh are more comfortable. Many operations also purchase hairnets that are white in color, which allows them to easily see whether workers are not only wearing their hairnets but also wearing them properly.
The garments that food plant workers wear vary widely. Some plants allow their workers to wear street clothes, whereas others provide complete uniforms. Street clothes are not a good idea, as one can never tell where employees were before coming to work. A description of the garments to be worn in a food plant might be as follows: Uniforms shall be tight fitting and be equipped with snaps or Velcro closures. There shall be no pockets located above the waist. Sleeves shall be manufactured with elastic bands at the wrist to protect the arms. When purchasing uniforms, plant management should seriously consider the materials from which they are manufactured. Ideally, the uniforms should not “shed,” and they should be manufactured from breathable materials, especially if a plant is located where there are high temperatures or where workers must work in a hot area.
Many operations color-code uniforms, especially if the plant produces sensitive products. In plants producing ready-to-eat foods, workers on the raw side might wear white uniforms, whereas those on the cooked or finished product side will wear blue. In operations such as these, when moving between these areas, workers must not only change their uniforms but also their shoes or boots.
Shoes are an area that management needs to address. For safety purposes, shoes must be close toed and preferably have steel toes and shank. However, since food plant workers are on their feet for a large part of each day, it behooves management to make a commitment to identifying a supplier that produces a comfortable safety shoe. Many plants bring the manufacturer of safety shoes into the plant several times a year to allow their crews to select a shoe with which they are comfortable. When developing a policy for shoes, management must consider what they are manufacturing, their workforce and where they live. For example, many food processing plants are located in a country with a workforce that lives on farms or raises livestock or poultry. The last thing an operation needs is to have them tracking chicken or turkey manure into a facility that produces a ready-to-eat product. This is why some facilities are designed in such a way to oblige workers to change shoes immediately before going into the processing area or to utilize foot baths or boot washers.
Jewelry and Other Objects
Anyone entering a food processing area must remove all jewelry, including rings, brooches, watches, pins, earrings, necklaces and visible piercings. In addition, false nails, nail polish, false eyelashes and any other object that may possibly contaminate food should not be allowed in the plant. Piercings have become an issue in recent years, which is why operators utilize the term “visible,” which, for most operations, includes tongue piercings. Another issue that processors must look for if they do not supply uniforms is clothing that has spangles or rhinestones sewn into it. This can be an issue in Islamic countries where women often wear decorative head scarves.
Only two types of jewelry are allowed in some plants. These are plain wedding bands and medical emergency bracelets or necklaces. The plain wedding bands are allowed for two reasons; some simply cannot be removed and have no stone that can come loose. Notice that the term “some plants” was used. Some operations say no jewelry whatsoever. If an employee has an emergency bracelet or necklace, it must be covered so it will not pose a safety risk. There are operations that have addressed the emergency bracelet issue by having those employees wear a special patch on their uniforms. The use of special patches is more common than many would suspect. Some operations use patches to designate employees who are first responders, know CPR or are safety committee members.
Additionally, processors must develop a cellphone policy. This should be quite simple. No cellphones in the processing area. Given that almost all phones have cameras, this makes it easier to establish such a policy.
Employee Facilities and Support Services
One area where management plays a major role in employee hygiene is providing funding for employee facilities and support services. These include lockers and locker rooms, toilets, handwashing facilities, medical and first aid facilities, lunchrooms and break areas and access points to the plant.
Lockers and locker rooms are an often-ignored area. Employees need a place where they can change clothes and feel that their valuables are safe and secure. Having safe and secure lockers is one means of discouraging employees from bringing personal items into the plant. Ideally, the plant should provide employees with lockers that are at least six inches off the ground to allow for cleaning. The tops of lockers should be slanted to preclude storing anything on top. Employees should also be informed that lockers may be inspected at any time and that no food may be stored in the lockers.
The plant must provide their employees with an adequate number of toilets and handwashing facilities, and make sure these are kept both clean and well supplied. Having had the opportunity to do a great deal of work in Asia, I can personally testify that clean facilities are a necessity. The rule of thumb is one toilet and handwash station for every 10 employees. Handwashing facilities should include hands-free sinks (knee or foot operated, or an electric eye), soap, a constant supply of warm water and a means to dry hands. Some operations use towel dispensers and others hot air blowers. More and more processors are adopting hands-free towel dispensers. These not only provide towels automatically when the user passes his or her hand in front of an electric eye, many operators also report a cost savings on towels.
There is a need to create policies for how people enter the processing area and establish support facilities. Different methods can help ensure compliance. It is very common to set up a vestibule that includes items such as hairnets and snoods. Many companies also post pictures of both the proper way and the wrong way to wear garments. Applying the old adage “A picture is worth a thousand words” is a great idea in food plants, especially since many operations have a multilingual workforce.
All workers must wash their hands before starting work, after using the toilet, after eating or smoking or whenever their hands become soiled. To ensure that all employees wash before beginning work, management must install an adequate number of sinks to allow all employees to wash without having to line up. If people have to wait, they may not do what is required.
Management must make a decision as to whether they feel boot washers, boot baths or sanitizing foams are needed at the entrance to the plant. If the answer is yes, then programs to monitor concentrations of sanitizer and/or foamer performance are necessary. Some companies have taken out their foamers, deeming them to be potential safety hazards. Other processors have determined that boot washers or baths can create potential environmental problems. One company removed their boot bath when environmental monitoring indicated that the bath raised aerosol counts. Whatever direction is taken, make sure that the program is effective and necessary. As an example, boot baths may not be necessary when entering an aseptic processing and packaging area, given that the systems are all closed.
If a company provides their employees with uniforms, they need to either contract with a laundry service or install in-house laundry facilities. The laundry facilities, whether they are contracted or done in-house, must be able to properly document their operations. In fact, the same procedures used for selecting vendors should be employed when selecting a laundry service. Uniforms must be inspected for damage and washed at high temperatures. If the uniforms are damaged, they must be fixed or taken out of service. As part of the laundry program, there should be facilities to place dirty laundry and a means of getting the cleaned uniforms back to the workforce. Never rely on workers to properly wash their uniforms. There is simply no way to verify that it is being done properly.
Lastly, the company must establish policies and programs that address eating, drinking and smoking. There must be dedicated areas for these activities. In many states within the U.S. and in more and more countries, employees are not allowed to smoke within the workplace and, in fact, may only smoke out-of-doors and away from the building. You can always tell the dedicated smokers if you visit a plant in the dead of winter and see people outside in the cold. Remember, when people smoke, they must wash their hands, so handwash sinks need to be provided near the smoking area. Lunch or break rooms must be designed with food storage facilities. One element of the locker policy is that food may not be stored in lockers, so food storage must be part of the lunch or break rooms. These must include cages or some other place for storing food or lunchboxes, plus refrigerated storage. Many companies also provide microwave and/or conventional ovens to allow workers to cook or warm their food.
There are also processors that have lunch services or provide vending machines. When one travels to Asia, Central or South America, lunch is often provided to the workforce for a minimal fee or free of charge. Another trend that is seen in some plants is that they have banned nuts and other allergens from vending machines and discourage their employees from bringing such items in their own lunches. Some feel this is overkill; others believe it to be a legitimate preventive control.
One common theme that has run through this discussion has been the role of management. With a standard like ISO 22000 and the different audit schemes that have been approved by GFSI, there is a considerable emphasis on the role of management. Management’s role is much, much more than signing and dating a mission statement and a quality policy. ISO 22000 provides an excellent road map for management’s role in ensuring food safety and quality. Perhaps the most important element is management commitment and leadership. Managers must set an example and encourage communication. The standard includes the following elements:
• Management commitment
• Development, communication and implementation of the food safety policy
• Management of the planning of the food safety system
• Clear responsibilities for managing the food safety system
• Assignment of leadership responsibilities for managing the system that ensures that procedures are developed, implemented and maintained, and that persons responsible for the different elements of the system are properly trained
• Monitoring and maintenance of records that procedures are being followed and verification that procedures are not only being followed, but also are effective. This is where the internal audits come in.
• Establishment and maintenance of protocols for internal and external communication
• Conducting management reviews to evaluate all elements of the food safety management system on a regular basis
• Use of the management reviews as a tool for improvement
Management commitment and involvement are essential for successful implementation of all prerequisite programs, such as personal hygiene, and the food safety management system. The best managers are those who are visible. They participate in training sessions, get to know their workforce and encourage communication. They are also not afraid of change and, in fact, understand that acceptance of the status quo is a sure road to long-term decay. There is a reason that ISO 22000 emphasizes continual improvement and that part of Hazard Analysis and Critical Control Points includes regular reassessments of the program. Food safety, food quality and sanitation should not be stagnant, but continually evolve to better ensure safe, high-quality food. Good management and leadership are what make this happen.
Richard F. Stier is a consulting food scientist with international experience in food safety (HACCP), plant sanitation, quality systems, process optimization, GMP compliance and microbiology. Among his many affiliations, he is a member of the Institute of Food Technologists and an editorial adviser to Food Safety Magazine. He can be reached at firstname.lastname@example.org.
The plant management shall take all reasonable measures and precautions to ensure the following:
Disease control. Any person who, by medical examination or supervisory observation, is shown to have, or appears to have, an illness, open lesion including boils, sores or infected wounds, or any other abnormal source of microbial contamination by which there is a reasonable possibility of food, food-contact surfaces or food-packaging materials becoming contaminated, shall be excluded from any operations that may be expected to result in such contamination until the condition is corrected. Personnel shall be instructed to report such health conditions to their supervisors.
Cleanliness. All persons working in direct contact with food, food-contact surfaces and food-packaging materials shall conform to hygienic practices while on duty to the extent necessary to protect against contamination of food. The methods for maintaining cleanliness include, but are not limited to, the following:
l. Wearing outer garments suitable to the operation in a manner that protects against the contamination of food, food-contact surfaces or food-packaging materials.
2. Maintaining adequate personal cleanliness.
3. Washing hands thoroughly (and sanitizing if necessary to protect against contamination with undesirable microorganisms) in an adequate handwashing facility before starting work, after each absence from the workstation and at any other time when the hands may have become soiled or contaminated.
4. Removing all unsecured jewelry and other objects that might fall into food, equipment or containers, and removing hand jewelry that cannot be adequately sanitized during periods in which food is manipulated by hand. If such hand jewelry cannot be removed, it may be covered by material that can be maintained in an intact, clean and sanitary condition and that effectively protects against the contamination by these objects of the food, food-contact surfaces or food-packaging materials.
5. Maintaining gloves, if they are used in food handling, in an intact, clean and sanitary condition. The gloves should be of an impermeable material.
6. Wearing, where appropriate, in an effective manner, hairnets, headbands, caps, beard covers or other effective hair restraints.
7. Storing clothing or other personal belongings in areas other than where food is exposed or where equipment or utensils are washed.
8. Confining the following to areas other than where food may be exposed or where equipment or utensils are washed: eating food, chewing gum, drinking beverages or using tobacco.
9. Taking any other necessary precautions to protect against contamination of food, food-contact surfaces or food-packaging materials with microorganisms or foreign substances including, but not limited to, perspiration, hair, cosmetics, tobacco, chemicals and medicines applied to the skin.
Education and training. Personnel responsible for identifying sanitation failures or food contamination should have a background of education or experience, or a combination thereof, to provide a level of competence necessary for production of clean and safe food. Food handlers and supervisors should receive appropriate training in proper food-handling techniques and food-protection principles and should be informed of the danger of poor personal hygiene and unsanitary practices.
Supervision. Responsibility for ensuring compliance by all personnel with all requirements of this part shall be clearly assigned to competent supervisory personnel.
Section 7 — Establishment: Personal Hygiene
Personal Hygiene Objectives
To ensure that those who come directly or indirectly into contact with food are not likely to contaminate food by:
• maintaining an appropriate degree of personal cleanliness
• behaving and operating in an appropriate manner
People who do not maintain an appropriate degree of personal cleanliness, who have certain illnesses or conditions or who behave inappropriately can contaminate food and transmit illness to consumers.
7.1 Health Status
People known, or suspected, to be suffering from, or to be a carrier of, a disease or illness likely to be transmitted through food should not be allowed to enter any food-handling area if there is a likelihood of their contaminating food. Any person so affected should immediately report illness or symptoms of illness to the management.
Medical examination of a food handler should be carried out if clinically or epidemiologically indicated.
7.2 Illness and Injuries
Conditions that should be reported to management so that any need for medical examination and/or possible exclusion from food handling can be considered, include the following:
• sore throat with fever
• visibly infected skin lesions (boils, cuts, etc.)
• discharge from the ear, eye or nose
7.3 Personal Cleanliness
Food handlers should maintain a high degree of personal cleanliness and, where appropriate, wear suitable protective clothing, head covering and footwear. Cuts and wounds, where personnel are permitted to continue working, should be covered by suitable waterproof dressings.
Personnel should always wash their hands when personal cleanliness may affect food safety, for example:
• at the start of food-handling activities
• immediately after using the toilet
• after handling raw food or any contaminated material, where this could result in contamination of other food items; they should avoid handling ready-to-eat food, where appropriate
7.4 Personal Behavior
People engaged in food-handling activities should refrain from behavior that could result in contamination of food, for example:
• sneezing or coughing over unprotected food
Personal effects such as jewelry, watches, pins or other items should not be worn or brought into food-handling areas if they pose a threat to the safety and suitability of food.
Visitors to food manufacturing, processing or handling areas should, where appropriate, wear protective clothing and adhere to the other personal hygiene provisions in these areas.