17 PERSONNEL, RESPONSIBILITIES AND TRAINING – Food and Drink – Good Manufacturing Practice, 7th Edition

17
PERSONNEL, RESPONSIBILITIES AND TRAINING

Principle

There should be sufficient personnel at all levels with the ability, training, experience and, where necessary, the professional and technical qualifications appropriate to the tasks assigned to them and commensurate with the size and type of the food business. Their duties and responsibilities should be clearly explained and recorded as job descriptions with associated organisation charts or by other suitable means. Training should cover not only key tasks, but also good manufacturing practice (GMP) generally, and the importance of, and factors involved in, personal hygiene. Personal hygiene protocols are a key prerequisite to ensure GMP.

General

17.1 Manufacturing companies vary widely in character, size and structure, whether they are independent or part of a group, and, in the latter case, the extent to which the character of their operations is subject to central control. There are also wide differences in terminology and job titles in different companies. These circumstances make it impossible to adopt rigid generalisations about the titles of key personnel but the principles outlined in this chapter are of importance, and the terms ‘production manager’, ‘quality control manager’ and ‘purchasing manager’ are used here for the sake of convenience, but may equally well be read as ‘general manager’, ‘operations manager’, ‘technical manager’, ‘quality assurance manager’, ‘procurement manager’ rather than the job title, as the responsibilities of the departments concerned.

17.2 Two key personnel are the production manager and the quality control manager, who should be two different people, neither of whom is responsible to the other, but who both have a responsibility to collaborate in achieving product safety, legality and the required product quality. A third key person is the purchasing manager, who has a special responsibility for ensuring that raw materials/ingredients are purchased in compliance with specifications, and for collaborating to that end with the quality control manager. A supplier quality assurance protocol that includes supplier performance monitoring should be developed for the manufacturing company following collaboration between the purchasing manager and the quality control manager (see Chapter 23).

17.3 Persons in responsible positions should have sufficient authority to discharge their responsibilities, which should be clearly defined (see 17.8). In particular, the quality control manager should be able to carry out his/her functions impartially and in accordance with the Institute of Food Science & Technology (IFST) Code of Professional Conduct (http://www.ifst.org).

Qualifications

17.4 The quality control manager should possess appropriate professional and scientific/technological qualifications, and experience in food safety, food legality and food quality control. She/he should also possess interpersonal skills so that she/he can effectively communicate food safety, legality, integrity and quality criteria at all levels within the organisation.

17.5 Key personnel within the manufacturing organisation should be provided with an adequate number and calibre of supporting staff. A formal human resource appraisal should be undertaken with consideration given to the requirements of developing, validating, implementing, monitoring, revalidating and verifying the hazard analysis critical control point (HACCP) plan(s), the food safety management system (FSMS), the food integrity management system (FIMS) and the quality management system (QMS) and associated quality plans. These formalised systems may be separate or may be integrated into one formal documented system. The human resource appraisal review should include the identification of the human resources required to implement these system(s) consistently and effectively. A further review should be undertaken, minimally each year or more frequently when operational circumstances change that impact on the resource requirement needed. These reviews and any associated actions should be documented.

17.6 Key personnel within the manufacturing organisation should be direct employees of the company. Persons contracted, but not employed directly by the company, may be retained to provide advice or to carry out special projects, but should not be regarded as filling key personnel positions. During the approval process for contract personnel, it is important to determine the level of qualifications, current validity of membership of professional bodies and the status of continuous professional development (CPD), and, wherever possible, seek references from previous clients.

17.7 Persons should be designated to take up the duties of key personnel during the absence of the latter. This should be formally documented, and the organisation must be able to demonstrate that deputies are competent to undertake the role when required.

17.8 The ways in which those responsibilities that can influence product safety, legality, integrity and quality and the authority to discharge them are distributed among key personnel may vary with different manufacturers. What is essential in all organisational arrangements is that responsibilities should be clearly defined and allocated and areas of authority delineated. These arrangements should be properly understood and respected by all concerned. This may be documented in job descriptions/specifications, organisation charts or alternative documents.

17.9 The quality control manager should have the authority to establish, validate, implement and verify all food safety, legality, integrity and quality control procedures, to approve materials and products, and to withhold approval from any material or product that does not comply with the relevant specification. In some organisations, withholding of approval amounts to absolute rejection; in others, it amounts to provisional rejection subject to confirmation by the general management or the managing director; in yet others, it may be absolute rejection in certain defined serious cases, and provisional rejection in others. In exercising authority in the foregoing ways, the quality control manager, subject to the proper discharge of responsibilities, is under obligation to do everything possible to minimise and preferably prevent any disruption of production and/or distribution arrangements and schedules, and to provide prompt information and advice to production personnel to help maximise conformance with specification, and, in the case of non‐conformance, to provide advice on rectification or reworking if possible. The quality control manager should, where required, identify whether the rejection is on the grounds of legislative, food safety or quality criteria to ensure suitable advice to production staff and to enable appropriate corrective action. The quality control manager has a leading role in defining preventive action where weaknesses in the QMS/FSMS/FIMS and/or compliance in practice with the QMS/FSMS/FIMS have been identified and non‐conforming product has not yet been produced. The production manager should fully support such initiatives and enable preventive action to be implemented and effective.

17.10 The production manager should have responsibility for manufacturing resources, including processing areas, personnel, equipment, operations and records, and for using these resources to produce, in accordance with the master manufacturing instructions or equivalent, the programmed quantities of products conforming to the relevant quality specifications and within the budgeted cost. In addition, the production manager usually has some responsibilities that are shared, or exercised in liaison with, the quality control manager and other personnel. The production manager should be a member of the HACCP team and should participate in the development and acceptance of specifications, particularly the master manufacturing instructions and the finished product specifications, and in the training of production personnel. She/he should liaise with the quality control manager in ensuring an optimum manufacturing environment, in particular in relation to controlling and minimising extrinsic hazards (food safety hazards arising from the processing area, personnel, equipment and operations), hygiene and for quarantining and rectification of any non‐conforming product. The production manager should not have authority to use any raw materials or intermediates that have not been approved for use, unless a concession has been formally agreed with the quality control manager or designate.

Supplier Quality Assurance

17.11 The quality control manager should have an advisory role in the choice of suppliers of raw materials, packaging and services (see Chapter 23).

Recruitment and Selection

17.12 In the recruitment and selection of staff, due regard should be given to the required prerequisite skills and the potential suitability of the candidate for the task in hand. For example, persons of clean and tidy and methodical nature may be more likely to appreciate the principles required in the hygienic handling and storage of food and the implementation of the FSMS, FIMS and the QMS, than those who are not. Similarly, potential employees should be appropriately qualified for the requirements of the task as defined in the job description/specification.

Training

17.13 Training is necessary to enable personnel at all levels within the organisation to understand their responsibilities and improve their knowledge and skills. Effective training will also improve individual performance and reduce the level of supervision required. Training will only be effective when the provision of knowledge develops thorough understanding and is relevant to the individual’s tasks and responsibilities. The implementation of the knowledge acquired by individuals requires management support, including appropriate opportunity to practise skills, ensure motivation and provide effective supervision. It should be noted that while a certificate of attendance at an internal/external training course is of value, that value is limited if it cannot be verified that the person(s) attending such training can effectively implement the skills and knowledge gained in practice in the manufacturing environment. Similarly signatures on a training record demonstrate training has taken place, but do not in themselves provide evidence of ongoing staff competence. Therefore the internal audit programme needs to include in its scope the verification of personnel competence at all levels of the organisation as well as the presence of training certificates, especially where their work activities can affect food safety, legality, integrity and quality.

Training records should be maintained and they should provide as a minimum details of the nature and content of the training undertaken, the date and duration of the training activity, the identity of the trainer and the signatures of the trainee to verify training has taken place and the trainer to confirm that the training was effective and the individual is competent. Individuals should only be signed off subsequent to the training course or activity when they have demonstrated this competence in all aspects of the job role to the satisfaction of the trainer or designate. Some job roles will require specific training, for example individuals involved in chemical handling, machine operating and pest control, and this must be documented and signed off again by the relevant person to demonstrate that the individual has attained a minimum level of competence. The initial and ongoing level of competence of the trainers should also be identified and documented by the manufacturing organisation in order to verify that they can provide appropriate training and knowledge transfer to staff. If agency staff are used, then their training and the competence of the agency trainers must be verified as suitable before they commence work. Additional site‐specific training will be required in addition to familiarise agency staff with the specific aspects of the manufacturing process and the food safety, legislative and quality controls in place on the site. Full consideration should be given to the risk of using agency staff at critical control points (CCPs), critical quality points (CQPs) and critical legislative points in the manufacturing process with respect to their suitability and degree of competence for the role. Use of agency staff should form a component of the risk assessment process in ensuring the FIMS system is appropriate and effective.

17.14 All production and quality control personnel should be trained in the principles of GMP, and in the practice and underlying principles of the tasks assigned to them. Similarly, all other personnel (e.g. those concerned with maintenance or services or cleaning) whose duties take them into manufacturing areas or have a bearing on manufacturing activities should receive appropriate training. Records should be kept of the training of each individual. Where individuals are working at CCPs as defined in the HACCP plan and/or have responsibility for the effective implementation of prerequisite programmes (PRPs) or food integrity countermeasures, the manufacturing organisation must develop and implement training programmes to ensure that these individuals have appropriate levels of competence, skills and knowledge to support the effective adoption of the HACCP plan, QMS, FSMS and FIMS. Similarly, those individuals working at CQP and critical legislative points such as label printing, quantity control (weight, volume, count) and points of control of provenance, assured status and identity control should have appropriate training and supervision to ensure that they are competent, they understand their job role and its importance, and that legislative requirements are consistently met.

17.15 Training should be in accordance with programmes approved by the production manager and the quality control manager. Training should be given at recruitment (usually termed induction training) and repeated, augmented and revised as necessary. The degree of an individual’s knowledge and understanding of the content and application in the workplace of the information contained in the induction training should be tested and verified before individuals can commence work unsupervised. It is essential to consider developing a ‘buddy system’ for new employees during induction so they can receive on‐the‐job training and support. In the event of non‐conformance by staff with procedures and work instruction then retraining should be undertaken as required. Records of induction training should be retained for all personnel, and with returning seasonal workers induction training should be undertaken each season, with particular emphasis on changes in legislation, customer requirements and emerging food safety, legality, integrity and quality issues. Both in training itself and with regard to the need for personnel to be able to understand and follow written instructions and procedures, notices and so on, particular attention should be given to overcoming language, numeracy or literacy difficulties. Recommendations for the content of induction and supplementary hygiene training programmes are contained within the Industry Guides to Good Hygienic Practice.1 These guides were initially developed in accordance with Article 5 of the EC Directive on the Hygiene of Foodstuffs (93/43/EEC) Regulation (EC) No. 852/2004 and continue to apply after 1 January 2006, and continue to remain compatible with the objectives of the new legislation. Many older guides may not necessarily cover all of the revised requirements, and to date they have not all been reissued as revised guides. Ten guides have been subsequently published that address the following sectors: mail order food, wholesale distribution, sandwich bars and similar food outlets, flour milling, vending and dispensing, bottled water, sandwich manufacturing, whitefish processors, spirit drinks and retail. While not all the guides are in sectors defined as a manufacturing process, manufacturing organisations need to be aware of the requirements of subsequent sectors in the supply chain that they supply in order to ensure supply chain compliance.

17.16 Periodic assessments of the effectiveness of training programmes should be made, and checks should be carried out to confirm that designated procedures are being followed. Training programmes can be evaluated by a number of techniques, including:

  • pre‐ and post‐training observation and questioning to assess if knowledge has been gained, practices or standards have improved or attitudes have changed;
  • post‐training assessment to determine the individual’s competence to produce safe food, which may involve written tests, observation or questioning, microbiological swabbing of hands and/or food contact surfaces or bacterial food sampling; and
  • trend analysis of the frequency of customer complaints, quality incidents or level of waste or rework or the frequency of failures at CCPs and CQPs.

17.17 Training should be reinforced by adequate supervision, mentoring and support, regular performance reviews, refresher training at designated intervals, posters and notices, reviewing the results of routine microbiological monitoring and quality performance with personnel and recognising good practice. Refresher training is required where any element of the QMS, FIMS or FSMS changes, especially the induction programme, so that all staff are consistently trained to the same level. The time period as to when a person is deemed competent and thus needs less supervision is dependent on the individual and requires ongoing review by the relevant member of management. The organisation should develop an electronic training database, or a paper‐based or electronic training matrix, to control the training requirements for the organisation. The training matrix, or equivalent, should state the current level of training for all staff. It should identify for a specific job role what level of training and competence is required in terms of internal and external training and the current level of training of all staff in that job role. This will assist the organisation in undertaking a training needs analysis to identify those who require further training for the first time or in the form of refresher training. The training matrix should therefore identify those staff currently in the induction phase and receiving training, those individuals who are signed off as competent, but may need refresher training and those who are deemed able to train others. The training matrix should be reviewed at designated intervals. If as a result of review and/or other audit activities inconsistencies in training and competence are identified, appropriate preventive or corrective action needs to be determined and then implemented. The details of the training matrix review and any subsequent preventive or corrective action should be recorded and records retained as a demonstration of due diligence. Formal employee appraisals should also be undertaken. These employee appraisals should include ongoing performance monitoring and should determine if there are any areas where the individual concerned requires further development support and/or training.

Cessation of Employment

17.18 Where employment is terminated for any reason, consideration should be given to any possible risks arising through disaffection or simple lack of continuing interest and commitment from the employees concerned, and appropriate precautions taken as necessary.

Food Hygiene and Personal Hygiene

17.19 Many important aspects of hygiene are also dealt with in Chapters 10 and 19. It is essential that all personnel are appropriately trained in relevant aspects of food hygiene. Regulation (EC) No. 852/2004 of 29 April 2004 on the hygiene of foodstuffs, as amended, came into automatic force in all Member States on 1 January 2006, and continued the requirement of earlier legislation that food business operators should ensure:

  1. that food handlers are supervised and instructed and/or trained in food hygiene matters commensurate with their work activity;
  2. that those responsible for the development and maintenance of the procedure referred to in Article 5(1) of this Regulation or for the operation of relevant guides have received adequate training in the application of the HACCP principles; and
  3. compliance with any requirements of national law concerning training programmes for persons working in certain food sectors.

Sections 17.20–17.22 refer particularly to ensuring high standards of personal hygiene of all concerned with the production processes and all persons entering production areas, including quality control personnel, product development personnel, engineers and maintenance personnel, inspectors, senior management, contractors and visitors.

17.20 Instruction should not be regarded as an adequate substitute for training, which provides not only information on what should be done, but an understanding of why it is important. Training should embody the requirements of personal hygiene, the reasons why they are important and the fact that they are legal requirements. Adequate facilities and resources must be provided to enable personnel to comply fully with those requirements.

17.21 In the UK, the manufacturer must comply with the requirements of EU Regulation (EC) No. 852/2004 and EU Regulation No. 853/2004, which are also tabulated in Schedule 2, Specified Community Provisions, in the Food Hygiene (England) Regulations 2006 and in the equivalent Scotland, Wales and Northern Ireland Regulations (or with any regulations that may at any future time supersede these regulations). EU Regulation (EC) No. 852/2004 states that every person working in a food‐handling area is to maintain a high degree of personal cleanliness and is to wear suitable, clean and, where necessary, protective clothing but does not specify the detail of personal hygiene requirements. However, the following should be regarded as essential:

  1. Every person working in a food‐handling area shall maintain a high degree of personal cleanliness and shall wear suitable, clean and, where appropriate, protective clothing. It should be noted that the term ‘protective’ designates protection of the food from contamination and should not be seen in the context of personnel protection and safety.
  2. No person known or suspected to be suffering from, or to be a carrier of, a disease likely to be transmitted through food or while afflicted, for example with infected wounds, skin infections, sores or with diarrhoea, shall be permitted to work in any food‐handling area in any capacity in which there is any likelihood of directly or indirectly contaminating food with pathogenic microorganisms, and a person who suspects that there is any such likelihood on his/her part must report it to the appropriate person within the food business. Further guidance is available from the Food Standards Agency (FSA) publication Food handlers: Fitness to work regulatory guidance and best practice advice for food business operators (2009).2
  3. An adequate number of hand‐washing stations must be available, suitably located and designated for cleaning and effective drying of hands. All sanitary conveniences within food premises must be provided with adequate natural or mechanical ventilation. An adequate number of flush lavatories must be available and be connected to an effective drainage system. If toilets other than non‐flush‐type lavatories are used, then a documented risk assessment must be in place to state that the use of alternative designs does not present a contamination risk to food handlers. This risk assessment must be validated and routinely verified to demonstrate that the levels of personal hygiene required in a food manufacturing operation are consistently achieved. Lavatories must not lead directly into rooms in which food is handled, that is, there should be a minimum of two doors with an intervening ventilated space. Signs must be displayed in all toilet areas in a range of languages as required to inform people that they must wash and sanitise their hands before leaving the area. Hand‐washing stations with adequate resources must be provided within the toilet areas as well as on entry to production areas. There must be adequate training and ongoing supervision to ensure that protective clothing is removed and suitably protected from contamination prior to entry into toilet areas. If showers are provided, consideration should be given to the potential contamination of shower heads with Legionella bacteria. A procedure should be established, implemented and verified to control the potential for Legionella.
  4. Hand‐washing stations must be provided with hot and cold running water, materials for cleaning and, if required, sanitising of hands, and for hygienic drying. The provisions for washing food and washing equipment must be separate from the hand‐washing facility. Taps should not be present. Instead the water flow should be knee, foot or magic eye operated. The turning off of the water must be automatic. Signage should be at the entrance to all production areas requesting that hand washing is undertaken before entry. Signage on best practice for hand‐washing should also be in place, including schematics for how to wash, clean and disinfect hands, especially in manufacturing environments where high‐risk foods are prepared. Minimum contact times for chemical products on hands should also be identified. Instruction on effective hand‐washing techniques should be given during induction and refresher training given as required. Hand‐washing procedures should be documented, and personnel should wash hands on return to the production area and before commencing work, after handling waste or undertaking cleaning tasks, after visiting the toilet and after all break periods. Where required, hand sanitiser should be used. The FSA publication E. coli O157 – Control of cross‐contamination: Guidance for food business operators and enforcement authorities (2014), section 4, recommends that for extra protection against cross‐contamination a liquid hand wash that has disinfectant properties conforming to the European standard BS EN 1499:2013 is used. Hand‐sanitising gels, if used, should comply with BS EN 1500:2013. Hand‐sanitising gels are of limited value on dirty hands as they will not remove dirt and they should not be used as a substitute for effective hand washing first before sanitisation. Consideration should be given to cultural barriers to the use of alcohol‐based products and suitable alternatives sought where required. Routine hand swabbing could be used to determine the effectiveness of hand‐washing techniques. The temperature of the water used for hand washing should be routinely checked and recorded. The Campden Guideline G62: Hand hygiene: Guidelines for best practice (2009)3 recommends a water temperature of between 35 and 45 °C. Signage should be in place to identify areas designated for hand washing only. The provisions for washing food and also washing equipment must be distinct from hand‐washing areas and signed as such. Practice should be routinely verified to ensure that the correct activities are being undertaken at each specific designated sink/washing station and there is no risk of cross‐contamination with mixed use of a specific facility. The FSA has produced a series of food hygiene training videos, including information on effective hand washing.4
  5. The wearing of wrist watches and jewellery except for plain wedding rings or wedding wrist bands should be prohibited in food production and storage areas. The company should have a defined policy on the type of jewellery allowed to be worn for medical, ethnic or religious reasons and the controls in place to ensure personnel health and safety as well as minimising the risk of product contamination, especially if wedding rings and plain sleeper earrings are worn. Piercings, including rings and studs in exposed parts of the body such as ears, noses, tongues and eyebrows, should not be permitted.
  6. Adequate changing facilities for personnel must be provided where necessary. The changing facilities must be designed for effective cleaning. They must provide adequate space for the number of permanent, agency and temporary staff and be designed to separate outside and inside workwear and provide secure storage for personal belongings, including clothing. There must be provision for designated storage for clean and dirty protective clothing to prevent cross‐contamination. Staff should enter the production facility direct from the changing room and not go outside in their protective clothing before entry into the production facility. Visitors and contractors may use the same changing facility or a designated facility; again they must enter the production areas directly from that facility. Lockers must not be used to store food items. A separate provision must be made on‐site for storage of food brought onto site. The cleaning of lockers should be addressed in the cleaning schedule and their maintenance should be undertaken as required. Lockers should be so designed that dirt, rubbish and waste material cannot accumulate either on top of or underneath the lockers. Internal protective clothing should not be worn outside and should be removed on leaving a food production area and be suitably stored. Designated separate lockers may need to be provided as necessary to the job role, for both internal workwear (protective clothing) and external workwear, such as high‐visibility jackets, as well as personal belongings or clothing that must not be taken into the production and storage areas. In high‐care food manufacture, a protocol area is recommended, which requires formal separation of personal clothing, external workwear and internal workwear, including the adoption of separate lockers as well as a barrier in the room to formally segregate high‐ and low‐care areas.
  7. There should be an adequate provision of safety footwear and suitable protective clothing and the laundering thereof. There should be sufficient protective clothing per person to ensure that appropriate changing of clothing can be undertaken. The frequency of changing of protective clothing must be determined by risk assessment. Laundering of protective clothing could be undertaken on‐site or by a third‐party contract laundry service. The contractor supplying laundry services must be subject to the supplier approval and monitoring procedures (see Chapter 23). Designated internal footwear such as shoes or boots should be segregated from external footwear. In high‐care environments, personnel should understand why disinfection of internal footwear is important and follow the designated barrier procedures at all times.
  8. Laundry procedures must provide for the appropriate degree of cleaning of protective clothing. There should be adequate segregation during storage and after laundry of clean and dirty workwear so clean workwear is protected from recontamination. The temperature of the wash/dry cycle should be determined as to whether the items need to be cleaned or in the case of high care, cleaned and disinfected through the temperatures achieved in the washing/drying cycle. Temperatures should be monitored on a routine basis to ensure they meet minimum requirements. The results of monitoring should be recorded. High‐risk and low‐risk area clothing must be laundered separately. Consideration should be given, based on risk assessment, as to whether home laundry is appropriate. If home laundry is permitted, specific procedures must be put in place and staff should not be allowed to travel to work in their protective clothing or other associated workwear. If company‐issued clothing/uniforms are used that are permitted to be worn to and from work, a risk assessment must be undertaken to determine what additional protective clothing is required to protect food and materials from contamination. This is especially important in low‐risk businesses that allow home laundry and the wearing of workwear/uniform from home to work, for example in despatch areas. Suitable provision must be made for smoking and eating of food to prevent contamination. Verification activities to determine the effectiveness of the laundry procedures must be implemented and action taken to address non‐conformance if required.
  9. Clean protective overclothing, including headgear and, where appropriate, neck covering, must be worn by food handlers and any persons visiting food rooms. Protective clothing must be designed with no external pockets and fastened with press studs rather than buttons as well as falling to below the knee. Specific cleaning and/or disposal procedures must be developed for items of protective clothing, for example plastic disposable clothing, chain mail aprons and gloves, and liner and outer gloves and coats used in chilled despatch and freezer stores. The cleaning of high‐visibility clothing and hard hats where they could come into contact with the product must also be determined and procedures implemented. Hoods on underclothing must be contained within the protective clothing at all times as well as any fastenings on underclothing that could pose a food contamination risk if dislodged. Scarves should not be worn in chilled and frozen temperature‐controlled areas as there is a personal health and safety risk. Where disposable protective clothing is used, procedures for adequate control should be developed based on risk assessment.
  10. There should be pre‐employment medical checks so that no person suffering from, or who is a carrier of, any of the specified kinds of infection is employed as a food handler. Personnel should be actively encouraged to report infections and skin lesions, and supervisory personnel should be encouraged to look out for signs and symptoms of such conditions. Return‐to‐work procedures following illness or holidays abroad should be developed. Medical screening requirements will vary according to the types of product being manufactured and whether they are high or low risk. Pre‐employment medical checks can include stool sampling to verify that individuals are not carriers of harmful pathogens before they commence work or be a simple structured series of questions. Examples of such pre‐employment questionnaires are included in the FSA Food Handlers: Fitness to Work—Regulatory Guidance and Best Practice Advice for Food Business Operators 2009, published in May 2009. The quality control manager, or designate, should verify that the person is fit to work as a food handler, both on pre‐employment checks and in the case of illness or holidays abroad. The individual should be competent to check the questionnaires and as a minimum hold a current Level 2 food safety certificate.
  11. The carrying of loose items in the production areas, especially mobile phones, should be prohibited. Where deemed necessary, pen control policies, as with any other loose items, for example keys, should be in place to prevent loss or contamination of food.
  12. Eating, drinking and smoking should only be undertaken in a designated area. Protective clothing should be removed before breaks periods. Smoking while wearing protective clothing should be prohibited. If canteen/restaurant or food service facilities are provided either directly or via a catering supplier, there must be a HACCP plan in place that addresses the provision of this food. In the UK the Safer Food Better Business (SFBB) manual may be adopted within the kitchen and food service facility. The FSMS and the associated records for food that is provided for staff should be reviewed on a routine basis by the quality control manager or designate. The personnel hygiene requirements identified in this chapter should apply to the canteen/catering staff as equally as food production staff. If canteen/restaurant facilities are not provided on‐site, and staff bring in their own food, they should be provided with adequate designated refrigerated storage facilities that are clean, hygienic and capable of maintaining appropriate temperatures. Fridge air temperature should be checked on a routine basis to ensure compliance. If cooking facilities are provided, including microwaves, they, as well as the fridge, should be identified on a cleaning schedule and a cleaning programme developed, implemented and verified. Particular attention should be given to the cleaning and disinfection of food contact surfaces, which could be vehicles for food contamination.
  13. Perfume, scented deodorant or aftershave should not be worn as this could potentially taint the product. For this reason perfumed disinfectants or hand soaps should also not be used.
  14. All hair should be fully contained to prevent product contamination. This will entail the use of head coverings, hairnets and snoods as appropriate. Consideration should be given to the containment of body hair on arms, torso and so on, and to this end protective clothing should come down to the wrist and fasten to the neck. The Campden BRI Guideline G48: Guidelines for preventing hair contamination of food (2006; ISBN 0905942779) provides further information on the protocols that should be in place.
  15. Glove wearing should be controlled to prevent them from being a source of foreign body contamination. A glove issue and control procedure should be in place and awareness training undertaken so that personnel are instructed that the gloves are worn to protect the food from contamination not to keep their hands clean and that a gloved hand is as capable of causing cross‐contamination as a bare hand. Latex gloves should not be used due to the risk of allergenic reaction by individuals allergic to latex. If a part of a glove, or indeed the glove itself, is lost, then the quality control manager, or designate, should be notified immediately so that appropriate corrective action can be implemented (see 17.21q for corrective action procedure in the event of the loss of a glove or plaster).
  16. Fingernails should be kept clean, short and unvarnished. False fingernails or nail varnish should not be worn as they could prove a source of foreign body contamination. False eye lashes and/or excessive make‐up should not be worn. Consideration should be given, depending on the food products being manufactured, to formal checks being undertaken before work commences to prevent contamination.
  17. All cuts and grazes on exposed skin should be covered with a company‐issued detectable coloured metal strip plaster. These must be issued and signed out and checked at the end of production to ensure they are still in place. The batches of plasters, where appropriate, should be regularly tested through a metal detector. Wounds obtained out of working hours (in particular, those to the hands, arms and face) should be reported to the relevant manager at the start of work. Normal plasters must then be removed and replaced with company‐issued dressings. First‐aid kits must be under formal control and be monitored to ensure that all items stored within the first‐aid kit and when they are used can be fully accounted for. The stock in the first‐aid kits must be routinely verified to ensure effective control. It is accepted practice to determine at the end of the shift, or day’s production as appropriate, that any plasters issued are accounted for. The loss of a plaster, or a piece of or a whole glove must be reported immediately to the relevant manager and the following actions taken:
    • production should be stopped;
    • a search must be undertaken of the immediate location, general workplace and waste containers for the plaster as appropriate;
    • if the plaster cannot be found, then packed product must be re‐inspected;
    • if the plaster is still not found and there is the potential for the item to be in a consignment that has already been despatched, the quality control manager or designate must be notified immediately and appropriate corrective action implemented.
  18. Staff should inform managers or supervisors if they are required to take personal medicines, especially for long‐term conditions such as for allergies, diabetes or asthma. A personal medication procedure should be in place to control all medication brought onto site in order to prevent inadvertent contamination of the product and the procedure must be routinely audited to determine its effectiveness.
  19. Visitors and contractors should undergo medical screening before being allowed entry to production areas. Where pre‐entry medical questionnaires are completed by visitors and contractors, they should be formally reviewed and signed off by an appropriate member of staff before the individuals are allowed to enter a production facility. Visitors and contractors should be accompanied by staff, or otherwise controlled, at all times to ensure that personal hygiene requirements and product protection controls are fully complied with and security arrangements are fully met.
  20. Verification activities should be undertaken on a prescribed time interval basis to ensure that personnel are fully complying with all the above requirements. Programmes of refresher training for employees should be undertaken at regular intervals and as required if issues of poor personal hygiene practices are identified.

Personal Hygiene Policy

17.22 It is the responsibility of the quality control manager to ensure that personal hygiene policies and protocols have been developed and that good hygienic practice has been explained to, and is fully understood by, employees, visitors and contractors. Managers should communicate the policies and protocols to all personnel and demonstrate full management commitment to the requirements, advise employees, visitors and contractors of their legal obligations under European Union (EU) and UK food hygiene legislation to report any infectious or potentially infectious conditions, and exclude infectious or potentially infectious food handlers as specifically required by EU legislation. Managers should continuously review whether there are any barriers to good personnel hygiene practice and remove them where necessary. These include ensuring that:

  • the design of the premises and positioning of hand‐washing stations allows for adequate hand washing and sanitisation if required;
  • there are adequate supplies of clean protective clothing and hand‐washing sundries at all times;
  • staff have sufficient time available to undertake good hygienic practice;
  • the personal hygiene training given, including the training aids used, is appropriate to the language skills and literacy of the staff; where appropriate, pictorial training should be used; and
  • staff, visitors and contractors have sufficient understanding of the potential effects of poor personal hygiene.

Managers should follow appropriate action, including retraining, with staff who exhibit unhygienic practices.

17.23 The site should develop and implement a sickness reporting procedure, which identifies the actions to be taken should an individual fall ill either before or during his/her period of work. All staff should notify the manufacturing business in the event that they or a person they have been in contact with is suffering from or carrying an illness that could cause a food poisoning or food‐borne illness outbreak before they commence work. The FSA Food Handlers: Fitness to Work – Regulatory Guidance and Best Practice Advice for Food Business Operators 2009, published in May 2009, identifies best practice in this area. Procedures should be in place should an individual fall ill at work in terms of reporting procedures, and these should form part of induction training. Procedures should also be implemented for managing any spillage of bodily fluid spillages, for example vomiting and bleeding, within the production and storage areas. Bodily spill kits are available that can be used and then disposed of in a way that minimises the risk of contamination. All contaminated products should be disposed of, as appropriate.

Agency Staff

17.24 The employment of agency staff should be in compliance with the legal requirements operating in the country where the manufacturing site is situated. In the UK, employment agencies that operate in food processing must hold a valid Gangmaster and Labour Abuse Authority (GLAA) approval. The onus is on the manufacturer to check at routine intervals that the agencies’ approval has not been revoked. In order to manage this effectively, a formal procedure should be in place with responsibilities defined as to who will coordinate and implement the procedure and, if required, appropriate corrective action. The training requirements outlined in this chapter apply as equally to agency staff as they do to employed staff. If training and medical records are held by the agency, they should be routinely verified as appropriate by the quality control manager or designate. If the agency is responsible for the laundering of protective clothing, then they should comply with all necessary controls (see 17.21h for more information).

Ethical Trading Initiative Base Code

17.25 It may be a requirement of retail customers as a prerequisite to supply that the manufacturer complies with the Ethical Trading Initiative (ETI) Base Code, SA 8000 or another third‐party standard. It is best practice for manufacturers where this is a requirement to ensure that their suppliers comply with the relevant ethical trading standard(s) as well. It may also be a supply chain requirement for a manufacturer to be a member of the Supplier Ethical Data Exchange (Sedex) as well as having a formal Sedex Members Ethical Trade Audit (SMETA). For further details see Chapter 18.

Food Integrity Management

17.26 Training in food integrity management and to create awareness of the potential for food crime and illicit behaviour is necessary to enable personnel at all levels within the organisation to understand their personal responsibilities and improve their knowledge and skills in this area of GMP. Training to ensure that there is adequate understanding of organisational whistleblowing procedures should be undertaken and there should be verification activities carried out to measure the degree of understanding at all levels of management. For more details see Chapters 5 to 7.

Notes