High Hygiene Category BRC internal audit (Section 6) - Version 6

6 Personnel handling,preparation,processing, packing and storage areas <br> The company shall ensure that all personnel performing work that affects product safety, legality and quality are adequately trained, instructed and supervised commensurate with their activity and that they are competent to undertake their job role.

6.1.1 All personnel, including temporary personnel and contractors, shall be appropriately trained prior to commencing work and adequately supervised throughout the working period. Induction training shall include the company hygiene rules.

6.1.2 Where personnel are engaged in activities relating to product safety,quality, and legality, relevant training and competency assessment shall be in place. This may include, but is not limited to:<br>1) product inspection, testing, and measuring<br>2) calibration<br>3) printed packaging controls<br>4) operatives at manufacturing process control points. 5) laboratory testing 6) product defense.

6.1.3 The site shall define and document how new or changed procedures, working methods and practices related to product safety or quality are communicated to relevant personnel.

6.1.4 The company shall routinely review and document the competencies of all staff and provide relevant training as appropriate. This may be in the formof training, refresher training, coaching, mentoring, or on-the-job experience.

6.1.5 Records of training shall be available. These shall include:<br>1) The name of the trainee and confirmation of attendance<br>2) The date and duration of the training<br>3) The title or course contents, as appropriate<br>4) The training provider (external or internal provider).<br>Where training is undertaken by agencies on behalf of the company, records of the training shall be available.

6.1.6 The site shall put in place documented programs covering the training needs of relevant personnel. These shall include as a minimum:<br>1) identifying the necessary competencies for specific roles<br>2) Providing training or other action to ensure staff have the necessary competencies<br>3) Reviewing the effectiveness of training and trainers<br>4) The delivery of training in the appropriate language of trainees.

6.1 Personal Hygiene:<br>Raw materials handling, preparation,processing, packing and storage areas<br>The site's personal hygiene standards shall be developed to minimize the risk of product contamination from personnel. These standards shall be appropriate to the products produced and be adopted by all personnel, including agency-supplied staff, contractors, and visitors to the production facility.

6.2.1 The requirements for personal hygiene at sites producing materials for direct contact with food or other hygiene-sensitive products shall be documented and communicated to all personnel. These shall include, as a minimum, the following instructions:<br>• wrist bands, wrist-worn devices or watches shall not be worn<br>• jeweler including piercings shall not be worn on exposed parts of the body, <br> with the exception of a plain wedding ring, wedding wristband or medical alert <br> jeweler<br>• fingernails shall be kept short and clean and free from nail varnish<br>• false fingernails and nail art shall not be worn<br>• excessive perfume or aftershave shall not be worn.<br>Requirements at sites producing materials not for contact with food shall be based on risk assessment.<br>Compliance with the site’s requirements shall be checked routinely.<br>

6.2.2 Hand washing shall be performed on entry to the production areas and at a frequency that is appropriate to minimize the risk of product contamination.

6.2.3 Personal items and belongings, including personal mobile phones, shall not be taken into production areas without the permission of the management.

6.2.4 The site shall use risk assessment to determine the procedures and written instructions necessary to control the use and storage of personal medicines in production and storage areas, to minimize the risk of product contamination.<br>

6.2.5 Where visitors cannot comply with site hygiene rules, suitable control procedures shall be in place (e.g. non-handling of product, use of gloves).

6.2.6 All cuts and grazes on exposed skill shall be covered by an appropriately colored plaster that is different from the product color (preferably blue). These shall be site issued and monitored when involved in work with materials intended to come into direct contact with food or other hygiene-sensitive products. Where appropriate, in addition to the plaster, a finger stall or glove shall be worn.

6.3 Staff facilities<br>Staff facilities shall be sufficient to accommodate the required number of personnel and shall be designed and operated to minimize the risk of product contamination. Such facilities shall be kept in a good and clean condition.

6.3.1 Locker rooms shall be accessed without the need to enter production areas unless appropriately segregated walkways are in place.

6.3.2 Lockers shall be provided for all personnel who work in raw material handling, processing, preparation, packing, and storage areas. Lockers shall be of sufficient size to accommodate all reasonable personal items and any protective clothing required.

6.3.3 Site issued protective clothing and personal clothing shall not be stored in the same locker or shall be effectively segregated within the locker.

6.3.4 Eating (including the eating of confectionery and chewing of gum or tobacco), drinking, and smoking shall not be allowed in locker and changing rooms.

6.3.5 Suitable and sufficient hand-washing facilities shall be available to enable cleaning of hands before commencing work, after breaks, and as necessary during the course of work. Such hand-washing facilities shall provide, as a minimum:<br>1) Sufficient quantity of water at a suitable temperature to encourage hand washing<br>2) Unscented liquid soap or foam<br>3) Adequate hand-drying facilities<br>4) Advisory signs to prompt use (including signs in appropriate languages).<br>Where materials are handled that will be in direct contact with food or other hygiene-sensitive products, hand-washing facilities shall be sited at the entrance to the production area.

6.3.6 Toilets shall not open directly into storage, processing, or production areas in order to prevent the risk of contamination to product. Toilets shall be provided with suitable and sufficient hand-washing facilities.

6.3.7 Facilities for visitors and contractors shall enable compliance with the site's hygiene policy.

6.3.8 All food brought into manufacturing premises shall be stored in a clean and hygienic state. No food shall be taken into storage, processing, or production areas.

6.3.9 Eating (including the eating of confectionery and chewing of gum or tobacco), drinking, and smoking shall not be allowed in the production or storage areas. If it is impractical for personnel to leave their work area, local controlled facilities( such as a fully walled area with hand-washing facilities) shall be provided.

6.3.10 Drinking of water from purpose-made dispensers and /or by using conical cups or spill-proof lidded containers may be allowed, provided it is confined to a designated area away from equipment.

6.3.11 Where smoking is allowed under national law, it shall only be permitted in designated controlled smoking areas which shall be isolated from production and storage areas and fitted with extraction to the exterior of the building. Adequate arrangements for dealing with smokers' waste shall also be provided at smoking facilities, both inside buildings and at external locations.<br>The use of electronic cigarettes and associated materials shall not be permitted in locker rooms, or in production or storage areas, and shall only be permitted in designated smoking areas.

6.4 Medical Screening<br>Sites that manufacture packaging for direct contact with food or other hygiene-sensitive products shall ensure that documented procedures are in place to ensure that health conditions likely to adversely affect product safety are monitored and controlled.

6.4.1 Where there is handling of materials intended for direct contact with food or other hygiene-sensitive products, the site shall make employees aware of the symptoms of infection, disease, or condition which would prevent a person working. The site shall have a procedure for the notification by personnel, including temporary personnel, of any relevant infections, diseases, or conditions which they may have been in contact or be suffering from.<br>Employees, contractors, and visitors suffering from any of the above shall be excluded from work involving the handling of direct-food contact or other hygiene-sensitive product packaging for as long as the symptoms persist.

6.4.2 Where permitted by law, visitors and contractors shall be required to fill in a health questionnaire or otherwise confirm that they are not suffering from any symptoms which may put product safety at risk, prior to being allowed into production, packing or storage areas.

6.4.3 Medical screening for sites producing materials that will not come into direct contact with food or other hygiene-sensitive products shall be implemented on the basis of risk.

6.5 Protective clothing<br>Appropriate protective clothing shall be worn in production and storage areas to minimize the risk of product contamination.

6.5.1 Hair coverings and/or beard snoods, where appropriate, shall be worn in production areas at sites manufacturing materials for direct contact with food or other hygiene-sensitive products.<br>Hazard and risk principles shall be used to determine the need for any other protective clothing, including garments and footwear in areas handling raw materials, and in preparation, production and storage areas.<br>Where risk assessment has determined that protective clothing is not required in a particular area, it shall be fully justified and not pose a contamination risk to the product.<br>

6.5.2 The company shall use risk assessment to determine, document and communicate to all employees, including temporary personnel and contractors, the rules regarding the wearing of protective clothing in all situations, including:<br>• during the journey to work<br>• in raw materials handling, preparation, production and storage areas<br>• when away from the production environment (e.g. removal before entering toilets, canteen or smoking areas).<br>

6.5.3 Where protective clothing is required, appropriate clean protective clothing that cannot contaminate the product shall be worn. Sufficient sets of clothing appropriate to the activities being carried out shall be provided.

6.5.4 Protective clothing worn in production areas shall provide adequate coverage. Where there is handling of materials intended for direct contact with food or other hygiene-sensitive products, the clothing shall have no external pockets on the upper body garments or sewn- on buttons. Changes of such clothing shall be available at all times as required.

6.5.5 Based on the assessment of risk to the product, suitable footwear shall be worn within the factory environment.

6.5.6 If gloves are used they shall be replaced regularly, be distinctive, intact and not cause a contamination risk to the product.

6.5.7 Protective clothing shall be kept clean and laundered. Laundering shall be carried out by one of the following methods:<br>1) Professional laundry service<br>2) In-house<br>3) Controlled laundering facilities<br>4) home laundry.

6.5.8 Where home laundry is permitted, it shall be ensured that:<br>1) Employees have received written instructions regarding the laundering process to be used and these shall be reinforced as part of an induction or other in-house training program<br>2) Employees shall be provided with suitable means to safely transport washed garments from home to the workplace<br>3) There shall be a defined process within the site for monitoring the effectiveness of the system<br>4) There shall be a procedure and system for dealing with any case where employees are unable to perform self-laundry effectively, through lack of either diligence or inadequate facilities.

6.5.9 clean and dirty clothing shall be segregated and controlled to prevent cross-contamination.

6.5.10 Disposable protective clothing, if used, shall be subject to adequate control to avoid product contamination.