Tip Sheet 22 - Personal Hygiene Plan

In most countries, personnel requirements in food manufacturing plants are covered by food safety legislation.

Where this applies, the legislative requirements underpin the requirements of SQF Fundamentals elements 11.3.1 and 11.4.1. Personal hygiene and personnel practices legislation are generally based on the “Recommended International Code of Practice, General Principles of Food Hygiene,” from the Codex Alimentarius Commission (WHO, FAO). The SQF Fundamentals requirements reflect the Codex personnel food hygiene principles.

The Codex general hygiene principles cover five distinct areas:

7.1 Health status

7.2 Illness and injuries

7.3 Personal cleanliness

7.4 Personal behavior

7.5 Visitors

Personal hygiene requirements within a food manufacturing site are always risk based. They are dependent on the type of food involved and the exposure of food handlers to open product or food contact surfaces.

Learning Objectives

• Identify the risks posed by handling of exposed products
• Determine the hygiene and behavior requirements for food handlers in food manufacturing facilities
• Develop an employee hygiene plan

Applicable Code Elements

• 11.3.1
• 11.3.4

Key Terms

Codex Alimentarius Commission

The internationally recognized entity whose purpose is to guide and promote the elaboration and establishment of definitions, standards and requirements for foods, and to assist in their harmonization and, in doing so, to facilitate international trade. The Commission Secretariat comprises staff from the Food and Agriculture Organization and the World Health Organization. The Codex Alimentarius Commission adopted the principles of the Hazard Analysis and Critical Control Point (HACCP) system in 1997.

Bodily Fluids

Liquids that are excreted or secreted from the body and include blood, semen, vomitus and saliva. They are commonly considered as vehicles for the transmission of human disease.

High Risk Food

Food or food product with known attributes for microbiological growth, physical or chemical contamination, or which due to a process type may allow for the survival of pathogenic microbial flora or other contamination which, if not controlled, may contribute to illness of the consumer. It may also apply to a food that is deemed high risk by a customer, declared high risk by the relevant food regulation or has caused a major foodborne illness outbreak.

Infectious Diseases

Diseases caused by pathogenic microorganisms, such as bacteria, viruses, parasites or fungi. Infectious diseases may spread throughout a community by direct contact, or indirectly via vehicles of contamination such as food or food contact surfaces.

What to do

HEALTH STATUS

Medical screening of staff and contractors must be undertaken to detect carriers of infectious diseases. Staff identified as carriers of infectious diseases are not to be permitted to handle raw materials, work in progress, or finished product. Food handlers must be aware of risks to the food products from the potential transmission of pathogens from ill employees.

The site’s employee hygiene plan will address both the prevention and control of product exposed to ill employees and bodily fluids. An example of a control program could be the removal of an employee from direct food contact to non-food contact activities when the employee reports potential illness or injury. Ideally, an employee will not be penalized for reporting illness to the site. This should be supported by introductory training of all employees on reporting illnesses and injury and a questionnaire on illnesses for visitors. Procedures and training will outline how to address exposure and contact of ingredients, packaging and product.

ILLNESS AND INJURIES

Conditions which should be reported to management so that possible exclusion from food handling can be considered, include jaundice, diarrhea, vomiting, fever, skin lesions (boils, cuts, etc.), and discharges from the ear, eye or nose.

Food handlers with exposed cuts, sores or lesions are not permitted to handle products unless suitable protective coverings are applied. These coverings must be monitored regularly by responsible personnel to ensure they remain effective. Bandages are to be brightly colored to ensure they can be easily seen and include a metal strip for ease of detection, if the site uses metal detection. Dressings on hands and fingers are required to be covered with a suitable glove.

PERSONAL CLEANLINESS

In all food manufacturing facilities, employees, contractors and visitors must have clean hands upon entering food handling or processing areas; after each visit to a toilet; after using a handkerchief; after smoking, eating or drinking; and after handling wash down hoses, dropped product or contaminated material. Hand wash stations must therefore be correctly equipped and available at convenient locations for use.

Food handlers shall maintain a high degree of personal cleanliness and, where appropriate, wear suitable protective clothing, head covering, and footwear.

PERSONAL BEHAVIOR

Smoking, eating, chewing and drinking are not permitted in production areas. A risk analysis for drinking water must be conducted and controls must be developed by the site to minimize the risk to the safety of the product if it is provided in a production area. If water is consumed in the processing area, it is recommended that employees wash hands before returning to their station, or, at a minimum, hand sanitizer needs to be applied prior to returning to their work station, if permitted by regulation.

VISITORS

Visitors to food manufacturing, processing or handling areas mean anyone who has access to the facility and may come into contact with exposed product or food contact surfaces but is not normally employed at that site. Visitors may include contractors, management, inspectors, transport drivers, and/or sales personnel. All visitors should, where appropriate, wear protective clothing and adhere to the other personal hygiene provisions covered in the SQF Fundamentals.

All visitors must be authorized before accessing the site.

Hand wash basins and hand drying. Hand wash basins must be provided in close proximity to pedestrian entry points at each area of the site, with instructions for all staff, contractors and visitors to wash hands immediately before entering the processing area. Additional hand basins are required where hands could become contaminated prior to working with product.

Potable water at a suitable temperature, liquid soap, single-use paper towels and a means of disposing of used paper towels need to be provided at each station. Hands-free operated taps and hand sanitizers are also required for high risk operations. Hands-free operated taps can include foot, knee or elbow operated handles, auto-sensing devices or any other method that does not require the user to touch the handle with their washed hands to turn it off.

Hand sanitizers for low risk processes are optional.

Where alternative methods of hand-drying are preferred (e.g., high-speed air dryers), their use must be justified and their effectiveness validated (refer to SQF Fundamentals element 2.4.2.1).

Hand-wash basins are to be constructed of stainless steel or similar non-corrodible material. Hand-wash basins constructed of porcelain or similar materials must be located at a distance from food handling areas.

Relevant Resources

• Recommended International Code of Practice, General Principles of Food Hygiene, CAC/RCP 1-1969, Rev. 4-2003, Codex Alimentarius Commission (WHO, FAO), www.fao.org/docrep/005/y1579e/y1579e02.htm