Internal Audit Checklist - Hygiene and GMP - Personal Practices, Food Handling

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People Movement: WSEP V2 Section 12.5.1; CFMSR V2 9.1

Any potential risks due to people movement around the site must be identified with a procedure implemented for control of staff movement in and out of the facility based on risk appropriate to the operation. Access to the site must be restricted to authorised persons. Records of access for staff, contractors and visitors must be maintained. The permitted people movement traffic routes must be defined on a map of the site. The plan must show emergency routes e.g. fire exits. Procedures for the re-entry to production areas after an evacuation exit must be developed, documented and implemented. These must include: • A fire drill / emergency evacuation procedure • Procedures for the change of protective clothing after evacuation. • Procedures for the protection of product and packaging left in process and/ or on the line at the time of evacuation. Personnel shall not enter production areas without first changing into protective clothing designated for that area.

Protective Clothing - Hair Coverings: CFMSR V2 9.2.1 – 9.2.3; WSEP V2 Section 12.3.4; BRC V8 7.4.2 AA 5.6.6 Personnel Hygiene

Hair covering must be captive to the site. Hair and ears must be fully enclosed by the hair covering. Beard snoods must be worn to cover beards and moustaches. Hair covering must be replaced if removed or changed daily as a minimum. Where personnel are allowed to wear hair covering for religious reasons, a hairnet must fully cover any religious headdress. Where knitted caps are worn for warmth in refrigerated environments, these caps must be fully covered by a hairnet. Baseball style caps are not permitted.

Protective Clothing - uniforms: CFMSR V2 9.3.0 – 9.3.3 Protective Clothing (Base); WSEP V2 12.3.1 – 12.3.5; BRC V8 7.4.1 – 7.4.6 Protective Clothing; Approved Arrangement 5.6.6 Personal Practices

Protective clothing, including disposable clothing, must be visually distinctive for staff in specific areas /roles where appropriate (i.e. maintenance and cleaning personnel). Protective clothing must cover all personal clothing down to knee height and fasten to the top. Arms must be covered by protective clothing, cuffs tight at the wrists. Protective clothing must not be fitted with pockets (internal and external), free from buttons, and not allow access to the wearer’s own pockets. Laundered coats must be changed daily or more frequently if soiled. Maintenance must have instruction for when clothing has become soiled due to a maintenance activity. Maintenance must not wear their workshop coats in Medium areas during production. Cover all personal clothing e.g. hoods must be worn inside coat not hanging at back. Sufficient garments should be provided to allow for when a department or site-wide change is required e.g. in the case of a contamination issue or evacuation. Coats must not be worn without hair coverings The site shall include policies relating to the wearing of protective clothing away from the production environment ( e.g. removal before entering toilets, use of canteen and smoking areas).
Protective Clothing - High and Medium Areas: CFMSR V2 9.4.4 -9.4.5; CFMSR V2 9.4.6; CFMSR V2 9.6.1; BRC V8 7.4.5 -- High Area protective coats must be visually distinctive from Base and Medium area coats and be at least knee length and close fitting at the neck and cuffs. Medium area protective clothing worn above the knee must be removed in non‐production areas (excluding hairnets). Where knee length coats are not worn, staff must change out of company issue trousers. Suitable site issued protective clothing shall be worn by employees, contractors, visitors working in or entering production areas. Protective clothing including aprons, coats, jackets, and gloves (excluding hairnets) must be removed before entering toilets, canteen, smoking areas, and offices (outside production areas) Laundered coats must be changed daily or more frequently if soiled.

Disposable Clothing: CFMSR V2 9.7; BRC V8 7.4.6 ; WSEP V2 Section 12.3.4

Where disposable gloves and other disposable protective clothing items are in use, these must be in a contrasting colour to the ingredients. Ideally, disposable gloves should be made of “latex free” material. Document and implement; • When disposable clothing items are to be changed and disposed of - frequently or when contaminated. • Areas the items must be used are clearly identified • Actions to be taken if an item is found to be damaged • Disposable protective clothing is of a visibly contrast colour to aid in its detection. • All scalp hair must be fully enclosed in a disposable contrast colour or detectable hair covering.
WSEP V2 Section 12 - The procedures and policies regarding protective clothing must be developed, documented and implemented: • Protective clothing worn in production areas must not be worn outside. • Protective clothing required for outdoor jobs must be specific to that use and not be worn in open product handling areas. • The use of safety clothing e.g. High visibility jackets must not be a risk to product and their use must be controlled such that there is no cross contamination risk to product. • Food handler’s protective clothing must not be worn in toilet areas. • Protective clothing must be in available for short-term visitors. • Procedures for correct order of dress-up (donning of protective clothing) and dress-own (removal of protective clothing) to prevent product contamination must be defined.

Laundry: CFMSR V2 9.10, 9.11; BRC V8 7.4.3; WSEP V2 Section 12.4.1; CFMSR V2 9.11.1 High Areas Only;

Protective clothing for maintenance, cleaning /hygiene, laboratory, and where applicable allergen handling must be laundered separately to general food production work wear to prevent possible contamination. Where external laundry providers are utilised, these must be approved and a specification held for the garments including laundering temperatures and detergent type. Effective laundering by visual assessment of clothing. Must be adequate segregation between dirty and cleaned clothes High area coats must be laundered separately from coats used in other areas. Coats used in non‐allergen handling areas are laundered separately from coats used in other areas The external laundry shall be audited ( frequency based on risk) either directly or by a third party. Darwin Only: In certain circumstances home laundry programs may be permitted provided a documented risk assessment can demonstrate that there is no product contamination risk and the methods for home laundering is documented in a procedure for staff to take home. Staff must not wear protective clothing to and from work and it must be transported in a clean bag. Source HACCP Certificate from Alsco or relevant contracted laundry service provider.

Footwear Base WSEP Section 12.3.5; CFMSR V2 9.12. Foootwear Medium CFMSR V2 9.12.1; 9.12.2; Footwear High Areas CFMSR V2 9.12.3. Boot Washing CFMSR V2 9.12.4. Footbaths and Pass Through Boot Washers CFMSR V2 9.12.5; WSEP Section 12.3.5; CFMSR V2 9.12.6 Medium Areas;

Base Areas - Suitable footwear must be provided and remain clean, captive to the interior of the site with no open toes or high heels. Toilets must be maintained to a high standard (i.e. clean floors) to prevent contamination of the production area if shoes are worn in toilets. Scheduled footwear cleaning must be in place.
Medium Areas - For Medium areas, short external walkways may be acceptable if they are: • Well maintained e.g. smooth (non‐slip) hard surface • Clean with no debris / pooling water (daily cleaning) • Not connected to smoking areas.
High Areas: Footwear must remain captive to the area and be visually distinctive. Disposable shoe coverings shall not be used. Shoes with laces and shoe covers must not be permitted. Scheduled footwear cleaning must be in place (minimum daily). Cleaning effectiveness and frequency must be verified through swabbing and visual assessment.
Boot washing and Foot Baths: Where automated boot washing systems are employed, these must not be positioned in production areas and must be cleaned at a defined frequency or additionally if needed. Boot washers and footbaths do not negate the need for scheduled cleaning. Where footbaths and pass through boot washers are in place due to legislative requirements, these shall be documented on a schedule. The water and chemicals used must be emptied and cleaned at defined frequencies throughout the day to remain effective / active. If chemical is incorporated, concentration must be regularly monitored. Footbaths shall not be used at or inside entrances to High area production.
Medium Areas: Personnel must enter Medium areas following the below changing and hand washing procedure. The procedure must follow the order below: 1. Put in ear plugs and put on a clean hair covering and beard snood(if not already worn from Base area) 3. Remove street shoes and put on site captive shoes (if captive shoes are not already worn from Base area) 4. Wash, dry, and sanitise hands 5. Put on knee‐length coat and enter Medium area 7. Wash, dry, and sanitise hands 8. Put on disposable clothing at work station is required. Hands must be washed, dried, and sanitised following any adjustment to hair or beard snoods. On exit from the Medium area the Medium area coat must be removed. The risk of splashing and production of aerosols landing on protective clothing must be assessed. Footbaths do not negate the need for scheduled cleaning of footwear.

Changing Procedure High Areas Only: CFMSR V2 9.13, 9.13.1

Personnel must enter High areas via a designated changing area and follow the below changing and hand washing procedure. The procedure must follow the order below: 1. Put in ear plugs and beard snood (where required) 2. Put on a clean High area hair covering 3. Remove shoes 4. Put pants on at this step only where longer coats are used as protective clothing 5. Step over barrier or separation between Base / Medium and High area 6. Put on clean High area footwear 7. Wash, dry, and sanitise hands 8. Put on coat 9. Enter High area 10. Wash, dry, and sanitise hands 11. Don disposable clothing at work station Hands must be washed, dried, and sanitised following any adjustment to hair or beard snood. On exit from the High area the procedure must follow the order below: 1. Remove High area coat 2. Remove High area footwear 3. Step over barrier or separation between High and Base / Medium areas 4. Put on Base / Medium area captive shoes 5. Wash, dry, and sanitise hands. 6. Put on Base / Medium area coat 7.Wash, dry, and sanitise hands.

Hand Washing CFMSR V2 9.16; BRC V8 4.8.4; 7.2.2

Hand washing and sanitising must be completed on entry to Production areas and after the following; • Eating • Smoking • Using the toilet • Coughing /sneezing into hands • Touching the face / nose or adjusting hair coverings, ear plugs, or beard snoods. • Touching or picking up items from the floor or using ladders • *Handling unsuitable materials Method: 1. Wet hands 2. Apply soap 3. Rub palms and back of hands / thumbs and between fingers – repeat each area 5 times 4. Rinse with water 5. Dry hands 6. Sanitise hands *Unsuitable materials include allergens, pallets, chemicals, inedible product.
Hand washing Medium Area CFMSR V2 9.16.1 - Effectiveness of hand hygiene procedures must be checked regularly. If gloves are worn, hygiene procedures (including frequency of changing) must be in place to ensure that these do not present a risk to product. Hand swabs or contact plates are taken and assessed following an unannounced but planned program

Staff Hygiene and Facilities: CFMSR V2 9.17, 9.8 Hygiene Procedures; BRC V8 4.8.7 Staff Facilities ; WSEP V2 Section 12.1.2, 12.1.3

The procedures and policies regarding personal hygiene must be developed, documented and implemented including; • Rules for hand washing/sanitising frequency, plus methods. • Hand wash signage with instructions and photographs showing how to wash hands. • Unperfumed bactericidal hand soap and hand sanitiser. • Hand hot water (35-40 o C) with nonhand operated taps e.g. knee operated or with nondirect hand (infra red) operated sensors. • Disposable paper towels and a waste bin must be in use. • If the waste bin has a lid it must not be hand operated.
Personnel must not cough or sneeze over raw materials, packaging, equipment, or finished product. Spitting must be prohibited in all areas. Eating, drinking and smoking whilst wearing food handling protective clothing must not be allowed. Food and drink must not be consumed in production, maintenance, laboratories, storage, or office areas (except water when provided by site). Where drinking water is required, enclosed sports ‘sipper’ type bottles shall be used so that loose tops and tamper rings cannot come loose. Bottles must contain only water. Where water fountains (bubblers) or drinking receptacles are provided they must be controlled and must present no risk to product.
Personal Medicines CFMSR V2 9.9; WSEP V2 12.1.3; BRC V8 7.2.5 - Procedures must be in place to control the use of personal medicines (i.e. personnel must not carry these into work areas). Emergency prescription medication where required must be registered and a risk assessment undertaken to determine the necessity for the employee to carry it on their person. If required these must be checked in and out of the site daily and recorded.
Personal Hygiene Base CFMSR V2 9.21, 9.22, 9.23, 9.24; WSEP V2 12.1.3; BRC V8 7.2.1 - Fingernails must be kept short, clean, and unvarnished. False fingernails (acrylic or other) must not be permitted. Appropriate controls must be in place for short term visitors e.g. the use of gloves and non handling of product or equipment. Excessive perfume or aftershave must not be worn. False eye lashes or excessive facial make‐up must not be worn. Personal items (e.g. keys, personal mobile phones, medications, and coins) must not be carried on the person and be taken into production, maintenance, and storage areas. Rules and appropriate controls for acceptable wearing of jewellery; which must be specified and must include rules for plain wedding bands, body jewellery, religious jewellery, and medical aler tags. The exception being locker keys and ID cards, where provided. Keys used within the site (e.g. metal detector reject boxes) are not treated as a personal item. These are best issued daily as part of the QA kit. Combination locks prevent the need for keys attached to key rings or taken home.

Control of Band Aids: BRC V8 7.2.3; CFMSR V2 9.20, 9.20.1; CFMSR V2 9.20.2 Control of Bandaids High Area; WSEP V2 Section 13.4; Staff Hygiene CFMSR V2 9.20.3 First Aid Kits Base

All cuts and grazes on exposed skin must be covered by a waterproof metal detectable blue Bandaid plaster provided by the site and issued by an authorised person. A log must be kept. Where metal detection equipment is used, a sample from each batch of plasters shall be successfully tested through the equipment and records shall be kept. Procedures must be in place to report if a Bandaid plaster is lost and prompt an investigation to ensure that it has not contaminated product. Records must be maintained. In addition to the metal detectable Bandaid plaster, a waterproof finger stall or waterproof glove must be worn (when applicable). There must be a Bandaid plaster reconciliation at the end of the day or shift. (High Areas Only) First aid kits contain an inventory of contents, which is checked at defined intervals. Note: Where metal detection is not used on site, the first aid dressing strip does not need to be metal detectable, however it must be blue and must be reconciled at the end of the shift. Refer to ; MO-028 Personal Health and Hygiene Policy MO-028-A Register of Injuries and Bandaids

Glasses /Contact Lenses/ Hearing Aids CFMSR V2 9.25

Procedures must be in place for the breakage / loss of glasses, contact lenses, or hearing aids. Glasses shall not incorporate fashion accessories that may pose a potential foreign body risk (e.g. diamante settings in glasses frames). Glasses that are not always worn (such as reading glasses) shall be securely stored when not in use.

Jewellery CFMSR V2 9.26; WSEP V2 12.1.3; BRC V8 7.2.1

Jewellery must not be worn or brought into production, maintenance, and storage areas, including: • Rings, with the exception of a single plain band (i.e. no stone ) • Cufflinks and tie pins • Watches • Rings, earrings, and studs in exposed parts of the body (including the tongue) • Personal clothing and fashion accessories must not pose a potential foreign body risk (e.g. decorative items such as sequins, diamantes, etc. must not be visible on garments). Additional jewellery may be permitted if it is worn for medical or religious reasons. In these circumstances a risk assessment must be completed and the permitted jewellery must be strictly controlled and suitably covered by the protective clothing (coat, sleeves, and / or gloves). Must be able to be cleaned and sanitised.

Personal Practices Approved Arrangement 5.6.6 Schedule 4, Clause 19-24; Approved Arrangement 5.6 Schedule 4, Clause 22, Schedule 3 Clause 13

The Approved Arrangement must detail adequate staff training practices and procedures to ensure that hygienic practices required by the Export Control (Milk and Milk Products) Orders 2005 are complied with. The procedures must also indicate how the occupier will ensure that no persons with an infectious disease or suspected of carrying an infectious disease will come into contact with milk and milk products either directly or indirectly. Are there documented procedures in place that ensure protective clothing and footwear at the establishment is: • Suitable? Does not present a risk of contamination? • Maintained in good repair? Clean and sanitary? Stored appropriately? Is worn in all food handling areas? Does the procedure include visitors?
Are there documented procedures in place at the establishment that ensures the personal hygiene of staff in food handling areas meet the requirements of the orders? and do the procedures include: • Storage of personal items • Sickness and conditions • Contamination from jewellery, clothing, behaviour etc. • Hand washing with warm water? • Sanitising? Training in personnel hygiene? It is expected the auditor will; • Ensure that records are checked to ensure staff are trained in all aspects of food safety, including a documented procedure for ongoing training i.e. refresher training. • Interview various staff at random to gauge effectiveness of the personal hygiene program (including notification of diseases etc) • Observe to ensure staff abide by the jewellery policies, hair coverings etc • Ensure that hand wash facilities are supplied with hot water, soap and hand drying equipment and located in suitable areas in or adjacent to work. Amenities are available and they are not a source of contamination to food.

Medical Screening, Illness and injury: BRC V8 7.3; WSEP V2 12.2

The site shall have a procedure which enables notification by employees of any relevant symptoms, infection, disease or condition with which they may have been in contact or be suffering from. Where permitted by law, visitors shall be required to complete a Health Questionnaire before entering the raw material, processing, packaging and storage areas. This must be included in the induction of new employees The Supplier must identify and document how it handles any employee, contractor or person visiting a production area who is affected by a virus or an infectious or communicable disease. This procedure must also include: • Corrective action for potentially affected raw materials, packaging, product or equipment. • Management strategies for potentially affected personnel The Supplier must implement procedures detailing the action to be taken where illness or injury results in a contamination incident. The incident must be documented. A return to work policy must be documented and implemented for staff returning to work after illness.

Control of Visitors and Contractors WSEP V2 12.6; BRC V8 7.4.1; CFMSR V2 9.15 Personal Hygiene; Approved Arrangement 5.6.6 Hygiene

Access to the premises by Visitors and Contractors must be documented with records of entry and arrival and departure times. The Supplier must document and implement a procedure for control of visitor and contractor movement. The procedure must include, at a minimum: • Visitors and Contractors must be identified and supervised. Alternative methods may be employed where practicable e.g. long term contractors. • Visitors and Contractors must be made aware of relevant company policies including staff hygiene, movement, clothing and medical rules before access is granted to production or storage areas. This communication must be documented. • Access to the premises by contractors must be limited to those areas required. Where Contractors require access to specific areas e.g. roof spaces this access must be controlled to prevent risk to product. • Procedures for the use of personal items by visitors or contractors e.g. mobile phones must be documented and implemented such that these are no risk to product safety or security. Visitors and contractors must be required to read, understand, and accept health, hygiene, and safety rules prior to entering production, maintenance, and storage areas. Access to the premises by Visitors and Contractors must be documented with records of entry and arrival and departure times. Visitors and Contractors must be identified and be supervised. Alternative methods may be employed where practicable e.g. long-term contractors.

Internal Audit Checklist - Hygiene and GMP - Personal Practices, Food Handling

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People Movement: WSEP V2 Section 12.5.1; CFMSR V2 9.1

Protective Clothing - Hair Coverings: CFMSR V2 9.2.1 – 9.2.3; WSEP V2 Section 12.3.4; BRC V8 7.4.2 AA 5.6.6 Personnel Hygiene

Protective Clothing - uniforms: CFMSR V2 9.3.0 – 9.3.3 Protective Clothing (Base); WSEP V2 12.3.1 – 12.3.5; BRC V8 7.4.1 – 7.4.6 Protective Clothing; Approved Arrangement 5.6.6 Personal Practices

Disposable Clothing: CFMSR V2 9.7; BRC V8 7.4.6 ; WSEP V2 Section 12.3.4

Laundry: CFMSR V2 9.10, 9.11; BRC V8 7.4.3; WSEP V2 Section 12.4.1; CFMSR V2 9.11.1 High Areas Only;

Footwear Base WSEP Section 12.3.5; CFMSR V2 9.12. Foootwear Medium CFMSR V2 9.12.1; 9.12.2; Footwear High Areas CFMSR V2 9.12.3. Boot Washing CFMSR V2 9.12.4. Footbaths and Pass Through Boot Washers CFMSR V2 9.12.5; WSEP Section 12.3.5; CFMSR V2 9.12.6 Medium Areas;

Changing Procedure High Areas Only: CFMSR V2 9.13, 9.13.1

Hand Washing CFMSR V2 9.16; BRC V8 4.8.4; 7.2.2

Staff Hygiene and Facilities: CFMSR V2 9.17, 9.8 Hygiene Procedures; BRC V8 4.8.7 Staff Facilities ; WSEP V2 Section 12.1.2, 12.1.3

Control of Band Aids: BRC V8 7.2.3; CFMSR V2 9.20, 9.20.1; CFMSR V2 9.20.2 Control of Bandaids High Area; WSEP V2 Section 13.4; Staff Hygiene CFMSR V2 9.20.3 First Aid Kits Base

Glasses /Contact Lenses/ Hearing Aids CFMSR V2 9.25

Jewellery CFMSR V2 9.26; WSEP V2 12.1.3; BRC V8 7.2.1

Personal Practices Approved Arrangement 5.6.6 Schedule 4, Clause 19-24; Approved Arrangement 5.6 Schedule 4, Clause 22, Schedule 3 Clause 13

Medical Screening, Illness and injury: BRC V8 7.3; WSEP V2 12.2

Control of Visitors and Contractors WSEP V2 12.6; BRC V8 7.4.1; CFMSR V2 9.15 Personal Hygiene; Approved Arrangement 5.6.6 Hygiene

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Internal Audit Checklist - Hygiene and GMP - Personal Practices, Food Handling

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People Movement: WSEP V2 Section 12.5.1; CFMSR V2 9.1

Protective Clothing - Hair Coverings: CFMSR V2 9.2.1 – 9.2.3; WSEP V2 Section 12.3.4; BRC V8 7.4.2 AA 5.6.6 Personnel Hygiene

Protective Clothing - uniforms: CFMSR V2 9.3.0 – 9.3.3 Protective Clothing (Base); WSEP V2 12.3.1 – 12.3.5; BRC V8 7.4.1 – 7.4.6 Protective Clothing; Approved Arrangement 5.6.6 Personal Practices

Disposable Clothing: CFMSR V2 9.7; BRC V8 7.4.6 ; WSEP V2 Section 12.3.4

Laundry: CFMSR V2 9.10, 9.11; BRC V8 7.4.3; WSEP V2 Section 12.4.1; CFMSR V2 9.11.1 High Areas Only;

Footwear Base WSEP Section 12.3.5; CFMSR V2 9.12. Foootwear Medium CFMSR V2 9.12.1; 9.12.2; Footwear High Areas CFMSR V2 9.12.3. Boot Washing CFMSR V2 9.12.4. Footbaths and Pass Through Boot Washers CFMSR V2 9.12.5; WSEP Section 12.3.5; CFMSR V2 9.12.6 Medium Areas;

Changing Procedure High Areas Only: CFMSR V2 9.13, 9.13.1

Hand Washing CFMSR V2 9.16; BRC V8 4.8.4; 7.2.2

Staff Hygiene and Facilities: CFMSR V2 9.17, 9.8 Hygiene Procedures; BRC V8 4.8.7 Staff Facilities ; WSEP V2 Section 12.1.2, 12.1.3

Control of Band Aids: BRC V8 7.2.3; CFMSR V2 9.20, 9.20.1; CFMSR V2 9.20.2 Control of Bandaids High Area; WSEP V2 Section 13.4; Staff Hygiene CFMSR V2 9.20.3 First Aid Kits Base

Glasses /Contact Lenses/ Hearing Aids CFMSR V2 9.25

Jewellery CFMSR V2 9.26; WSEP V2 12.1.3; BRC V8 7.2.1

Personal Practices Approved Arrangement 5.6.6 Schedule 4, Clause 19-24; Approved Arrangement 5.6 Schedule 4, Clause 22, Schedule 3 Clause 13

Medical Screening, Illness and injury: BRC V8 7.3; WSEP V2 12.2

Control of Visitors and Contractors WSEP V2 12.6; BRC V8 7.4.1; CFMSR V2 9.15 Personal Hygiene; Approved Arrangement 5.6.6 Hygiene

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