Module 06

Employee Health, Hygiene and Hand WashingSo far in this course you have learned why pest con-trol, building maintenance, sanitary facilities and the type of equipment and utensils you use are important to make sure that the food you are processing does not get contaminated. Now let’s talk about you. Yes, you and the people who work with you! In this module you will learn about the GMP’s that relate to employees and employee practices which can ultimately contaminate the food that you are processing.

This Module will help you understand:

• Whyemployees with certain types of illnesses should not work directly with food.

• Howgood personal hygiene can help make sure that food does not become contami-nated.

• What practices are not allowed in food handling areas because they could contami-nate food.

• Why proper hand washing is essential.

• How and when to wash your hands or change your gloves.

There are 38 pages, 13 GMP TVs, and 6 questions in this Module. You will see many differ-ent GMP TV examples of both good and bad practices and some fun activities.

Let’s get started!

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Overview of MicrobiologyTo understand how employee health and hygiene can con-tribute to food contamination you need to know some basic microbiology.

Microbiology is a broad term that covers the study of organisms that you can’t see without a microscope. For our purposes in this course, microorganism means bacteria, yeast, mold, viruses and some parasites.

Foodborne illness takes quite a toll. More than 200 known diseases can be transmitted by food. In the United States, foodborne diseases have been estimated to cause 76 million illnesses and up to 5,000 deaths each year.

The primary microorganisms that cause foodborne illness are bacteria, viruses, and parasites. The symptoms of food-borne illness range from nausea, headaches and cramps to more severe complications that can lead to death.

Common Mistakes That Cause Illness: Studies have shown that the two most common causes of foodborne illness in the U.S. are: 1. holding food at the wrong temperature, 2. and poor personal hygiene of food workers

Food workers typically transmit disease causing organisms to food from their hands by:

• touchingcontaminatedsurfacesandthentouchingfood.

• touchingcontaminatedfoodandthentouchingotherfood.

• touchingaportionoftheirownbodyandthentouchingfood.

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Microscopic Organisms and FoodNot all microorganisms are alike. Some can cause disease. These microorganisms are called pathogens. Others only cause spoilage, which results in objectionable taste, tex-tures and odors in a food. Although the food will look, taste, and smell bad, these organ-ismsdon’tcausepeopletogetsick.Someorganismsareactuallybeneficialandareusedto make products like blue cheese (mold), bread, beer, and wine (yeast), and yogurt (bacteria).

Types of Microorganisms

Molds: While some molds are used in food processing to manufacture food products like specialty cheeses they can also be involved in food spoilage and even produce a toxin called “mycotoxin” that is a poisonous substance that can have serious health conse-quences.

Yeasts: Yeasts can also cause food spoilage problems in foods such as fruit juices, meats, and wine but fortunately they are not associated with foodborne illness.

Bacteria: Bacteria can be divided into two groups, the spore formers and the non-spore formers. In general the spore forming bacteria are extremely resistant to heat, cold and chemical agents. But what is most important about bacteria is that some of them can cause foodborne illness. These types of bacteria are called “pathogens” which means disease-causing. With pathogens there is typically no obvious visual signs or odors that would indicate the food was unsafe or “bad.” That is what makes them even more danger-ous.

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Some Common Microbial PathogensBacteria: Some of the more common foodborne bacterial pathogens include: Salmonella, E. coli, Shigella, Listeria, Vibrio, Campylobacter and Staphylococcus. All of these organ-isms can cause illness if they are present in food. These “bad” bacteria or “pathogens” can come into the plant on raw or processed food products or on the people that work in the plant or from pests or other sources in the plant environment. When you are sick, these organisms can be spread to food and other persons.

Viruses are much smaller than bacteria. Some of the common food viruses include: Hep-atitis A, Norovirus, and Rotavirus. Some diseases, like Hepatitis A, can be caused when an infected food worker directly contaminates the food they are handling with their hands.

Parasites can be transmitted to people by water, food, or from another person. Some of the common food parasites are Cryptosporidium, Cyclospora, Giardia, Trichinella, and vari-ous worms.

GMP TV: The GMP TV below shows microscopic photographs of two of the common dis-ease causing organisms, viruses and bacteria, that can be transmitted to people by food. Click on each picture to learn more.

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How Disease Causing Organisms Are Transmitted by FoodPeople can be a source of disease causing organisms. When you are sick, these organisms can be released when you sneeze, cough, or go to the bathroom. Some people may carry these organisms and release them into their environment without ever getting sick them-selves. Some pathogens may also be present in an open wound, cut or other sore that is infected.

Lets review some possible routes that disease causing organisms can take from workers to food and then cause the person who eats the food to get sick.

Food handlers carry disease organism with or without symptoms

These organisms can be transferred from people to food

From the respiratory tract by coughing or

sneezing

From open sores. cuts and boils

From the intesti-nal tract by hands, gloves, or clothes soiled with feces

Contaminated food is eaten by customers

Foodborne illness occurs and customers get sick

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GMP TVThe photos in the GMP TV below show how bacteria, viruses or other disease causing organisms from various sources can contaminate food in the plant. Click on each photo to learn more.

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GMPs For Plant PersonnelNow that you have a basic understanding of microbiology and how it relates to foodborne illness, it is easier to understand why employee health and hygiene are essential to mini-mize the risk of foodborne illness.

Let’s now take a look at that part of the GMP that covers the people that work in your facility. It describes what you need to do to reduce the chance that employees could con-taminate your food products with bacteria, viruses or other microorganisms.

This section of the GMP begins with a statement directed to food facility managers.

GMP Requirement: The plant management shall take all reasonable measures and precautions to ensure the following:

The regulation then lists all of the requirements that, at minimum, describe the controls that a food processor would be expected to have in place in order to reduce the likelihood that employees could contaminate food.

These requirements include employee disease control, cleanliness, hygiene, and hand washing. We will discuss each of these requirements in this Module, starting with employ-ee health.

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Employee HealthGMP Requirement: Disease Control - Any person who is shown to have or ap-pears to have an illness, open lesion, including boils, sores or infected wounds or any other abnormal source of microbial contamination by which there is a reasonable possibility of food, food contact surfaces or food packaging materials becoming contami-nated shall be excluded from any operations which may be expected to result in contamination until the condition is corrected. Personnel shall be instructed to re-port such health conditions to their supervisors.

This GMP requirement contains a lot of words, but simply put it means employees must not work with food if they are sick or have open sores.

Do Not Work With Food When You Are Sick: Employees must not work with food if they are sick with an illness that could be transmitted to food. In a review of 81 foodborne illness outbreaks that infected almost 15,000 people in the U.S. from 1975 to 1998, 93% of these outbreaks involved food workers who were ill either prior to or at the time of the outbreak.

Symptoms To Report: Employees need to know that the illness they have could be transferred to others by handling food that someone else will eat. Some of the more common symptoms that must be reported to the supervisor are:

•Diarrhea •Vomiting

•Fever •Dark urine

•Jaundice (yellow color in skin or eyes)

•Open or infected sores, cuts or boils

In most cases, the organisms that cause these symptoms can easily be transmitted from employees to food from their hands, clothes and other items that may have become con-taminated.

Take Action to Reduce Risk: If employees are required to report these illnesses to a su-pervisor, it will give the supervisor the opportunity to assess the situation and either send the employee home or assign them to other work or a work area that does not involve direct handling of food, food contact surfaces, or food packaging materials. Either action helps to reduce the possibility of food contamination that could make someone else sick.

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What You Can Do

The GMP regulation requires plant management to take all reasonable measures and precautions to prevent food contamination by employees who appear to have an illness or sores that could transmit harmful bacteria or other microorganisms to food, food contact surfacesorpackagingmaterials.TocomplywiththisGMPrequirementyourfirmneedsto:

Develop company policies and procedures that describe the symptoms, illnesses, or conditions that employees must report to their supervisor. Policies should identify what action will be taken to prevent food contamination, such as reassigning employ-ees to tasks that do not involve food handling or taking sick leave. Procedures should describehowthefirmwilldeterminethattheemployees’conditionhasbeenresolvedand they can resume their normal work activities.

Train supervisors or managers to ensure that they understand company policies and procedures and can recognize symptoms or signs of illness that could represent a potential risk for food contamination.

Train employees to ensure that they understand company policies and procedures and the symptoms or conditions that must be reported and their potential impact on food safety.

Monitor employees and their behavior daily to ensure that employees who are ill or who have open sores or wounds do not contaminate food.

How To Monitor

Supervisors should monitor employee health conditions daily. Although the current GMP does not require monitoring records, you may want to keep a record of the results of your observations for your own use. If any actions are necessary to correct problems, these actions should also be noted on a written record. Records should also be kept to demon-strate that all employees have been properly trained.

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Employee HygieneThe next part of the GMP regulation describes the hygienic practices that food workers must follow to protect the food they are handling from contamination.

GMP Requirement: Cleanliness. All persons working in direct contact with food, food-contact surfaces, and food-packaging materials shall conform to hygienic practices while on duty to the extent necessary to protect against contamination of food.

As you can see, this GMP requirement states that food, food contact surfaces, and food packaging material must be protected from contamination by workers. It then goes on to outlineninespecifichygienicrequirementsforfoodworkers.

Hygiene Requirements for Food Workers1. Wearing suitable garments.

2. Maintaining adequate personal cleanliness.

3. Protecting food from jewelry or foreign objects.

4.Wearingproperhair covering or restraints.

5. Proper storage of clothing and personal items.

6.Confiningeating, drinking, and smoking to appropriate areas.

7. Preventing contamination from perspiration, cosmetics, tobacco, and chemicals or medicine applied to the skin.

8. Washing hands properly at the proper times.

9. Sanitizing hands and using gloves appropriately.

We will review each of these requirements starting with employee garments.

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Outer GarmentsGMP Requirement: All persons shall wear outer garments suitable to the opera-tion in a manner that protects against the contamination of food, food-contact surfaces or food-packaging materials.

Bacterial pathogens and viruses exist everywhere in our environment. This includes your street clothes, shoes, and hands. So it makes sense that you would not want to wear these clothes or shoes into processing areas where you might contaminate the food you are handling. It may be necessary to change clothes or put on protective outer garments such as aprons, coats, uniforms, smocks, or boots to prevent food contamination.

GMP TV: Click on the pictures in the GMP TV below for some examples of how some food processors have or have not complied with this part of the GMP regulation:


Personal CleanlinessGMP Requirement: Workers shall maintain adequate personal cleanliness.

The human body itself can be a source of microbial contamination if it is not kept clean. People who do not bathe can smell bad. This is because body odor is often caused by bac-terial growth.

Skin Can Harbor Bacteria: The average adult has a skin area of about 19 to 20 square feet. From healthy skin, approximately 10 million particles are released into the air each day, and 10% of these skin particles contain living bacteria. The chemical composition and moisture of skin varies and dictates what type of bacteria will grow on it and how much.

The surface of skin (epidermis) is not a favorable place for microbial growth because it is often dry, salty, and acidic. Most microorganisms are located in sweat glands and hair fol-licles because of the moist and nutritious environment in those places.


Jewelry and Personal ItemsSo far we have covered two areas of personal hygiene including cleanliness of outer gar-ments that come in contact with food and personal cleanliness. The next part of the GMP outlines hygienic requirements for jewelry, hair coverings, storage of personal items, and employee practices. Let’s take a brief look at each one starting with jewelry.

GMP Requirement: Remove all unsecured jewelry and other objects that might fall into food, equipment or containers, and remove hand jewelry that cannot be adequately sanitized during periods in which food is manipulated by hand. If such hand jewelry cannot be removed, it may be covered by material which can be main-tained in an intact clean and sanitary condition that protects these objects from con-taminating food, food contact surfaces, or food packaging materials.

Food Hazards:Jewelry,likeringsandearrings,orevenartificialnails,canbeasourceof food contamination. If any of these items fall into the food it can become a physical hazard - and the person who might bite into the article can get hurt (and probably would feeldisgusted).Itemslikejewelryorartificialnailsprovide an excellent place for food residues to collect and pathogens to grow because they interfere with proper hand washing and sanitizing.

Prevention Options: In order to comply with this portion of the GMP you have two choices:

• Thebestsolutionistohaveemployeesremoveallunsecured jewelry or other objects that could fall into or otherwise contaminate food, or

• Ifthejewelryorotherobjectscannotberemoved,the other option is to cover the jewelry with gloves or other material that can be kept intact, clean, and sanitary to protect food from contami-nation.


Hair RestraintGMP Requirement: Wear hair nets, headbands, caps, beard covering or other ef-fective hair restraints when appropriate and in an effective manner.

Hair and Hair Covering: To comply with this portion of the GMP, em-ployees working in food processing areas must wear hair covering or restraints.Thisisbecausehairisfilthyandcancontributetocontami-nation as well as the fact that no one wants your hair in their food! The type of hair covering that you would need to comply with this portion of the regulation can vary depending on where you are working.

Examples: Employees in loading docks or warehouses where there is no exposed food may not need hair coverings. Typically these workers wearbaseball-typecapswhichisfine,buttheyshouldnotbethesameones that are worn at home. In contrast, workers in areas where food is exposed must wear hair coverings that completely cover their hair, including beards and moustaches.

GMP TV: Click on the photos in the GMP TV below to see both accept-able and unacceptable hair covering practices.


Personal BelongingsGMP Requirement: Clothing or other personal belongings should not be kept in areas where food is exposed or where equipment or utensils are washed.

So far in our discussion of hygienic practices we have covered outer garments, personal cleanliness, jewelry, and hair coverings. The next three topics under hygienic practices deal with what you do with your clothing, personal items, where you eat, smoke and drink andfinallywhatyouwearonyourskin-allofwhichcancontributetofoodcontaminationif they are not managed properly.

Clothing and Personal Items: Coats, shoes, and other clothing or personal items should never be stored in areas where food is being processed or stored. This is because your personal items cannot be cleaned and sanitized and could potentially contaminate food, food contact surfaces, or food packaging material. Ideally your personal items will be stored in a locker room or at least an area that is dedicated to storing your items and is separate from food processing areas.

GMP TV: Click on the photos in the GMP TV below to see examples of items that should not be in areas where exposed food is handled or stored.


Activities That Involve Hand To Mouth ContactGMP Requirement: Eating food, chewing gum, drinking beverages, or using tobacco is not allowed in any areas where food may be exposed or where equipment or utensils are washed.

This section of the GMP regulation requires that any worker activity that involves hand-to-mouth contact never be allowed in areas where food is handled.

Restricted Activities: Activities in which the hands touch the mouth can lead to the transfer of harmful microorganisms from the mouth or face to the hands, which could then contaminate food, food contact surfaces, or food packaging material. Items like food, gum, or tobacco prod-ucts could also fall into food and contaminate it. For this reason, the following activities should be restricted to non-work areas such as break or lunch rooms, locker rooms or designated ar-eas where no food is handled.

• Eating any kind of food or snack.• Chewing gum.• Drinking any kind of beverage in a container other than from a water fountain.• Smoking cigarettes or cigars or chewing tobacco products.

Posting Signs: State and local health authorities may have requirements related to the post-ing of signs that remind workers that they cannot smoke, drink or eat in food handling areas. Even if these signs are not required, they can be an effective way to remind workers that these activitiesarenotallowedinspecificareas.

GMP TV: Click on the photos in the GMP TV below to see examples of unacceptable and accept-able practices related to the GMP requirement that prohibits eating, chewing gum or tobacco, drinking and smoking in food handling areas.


Personal Care ProductsGMP Requirement: Take any necessary precautions to protect food, food contact surfaces or food packaging materials from contamination with microorganisms or foreign substances including but not limited to perspiration, hair, cosmetics, tobacco, chemicals and medicines applied to the skin.

This part of the GMP regulation is included to make sure that other things related to worker hygiene and behavior do not become a source of contami-nation for food.

Body Hair and Sweat: You learned earlier that microorganisms are likely to live in the areas of the skin near hair follicles or sweat glands. Body hair from arms and perspiration or sweat can be a source of contamination if it falls onto food or food contact surfaces. Individuals with excessive body hair may need to wear protective sleeves or other covering to prevent food con-tamination. Steps must also be taken to keep workers from dripping sweat onto food or food contact surfaces. The temperature of the air in food han-dling areas should be adjusted to keep workers from sweating. Some indi-viduals who may have a problem with excessive sweating may need to wear protection or be re-assigned to another job where they do not work in areas where exposed food is handled.

Skin Products: Many different personal care products such as cosmetics, hand lotions or creams, ointments and other products available to the gen-eral public could have the potential to contaminate food. Workers should be aware of this potential and receive guidance on what products are not acceptable. Workers should also be aware that skin medicines, salves, and ointments can also be a potential source of contamination. This is one rea-son why the GMP requirement described earlier does not allow workers with cuts, sores or boils to handle food. If workers use salves or other skin medi-cine they should be required to wear gloves and another outer garment or disposable sleeves to cover their arms. Other chemicals or medicines should also not be used in food handling areas where they could unintentionally contaminate the food that is being handled.


What You Can Do

To meet GMP requirements for employee cleanliness and hygiene your company needs to:

Develop company policies and procedures for:

1. The garments or other body coverings and shoes that will be worn in areas where food is handled, stored or processed including aprons, sleeve protectors and shoes that will be provided by the company. How workers should use lockers or other facilities away from food handling areas to store street clothes, coats, shoes or other items. Which items are to be laundered or maintained by the company, and what employees are required to do.

2. The hair and beard or moustache restraints that are required for workers in each area of the plant and what employees need to do to meet this requirement.

3. Company standards for personal cleanliness, wearing jewelry, and the use of cosmetics, skin care products or medicines.

4.Company policies that prohibit eating, drinking or smoking in any food handling,storageorprocessingarea.Ifnecessary,specificinstructionsshouldbeprovided to employees describing where these activities can take place if they are allowed during break or other periods away from work areas.

5. Company restrictions for personal items that can be brought into work areas.

Train all employees to ensure that they understand all company policies related tocleanliness,personalhygiene,attire,andpersonalactivities.Mostfirmsprovideemployees with a handbook to make sure that they understand what is expected of them. Training programs can be used to further explain the handbook and help em-ployees understand why these policies and procedures are necessary.

Monitor employees routinely during the day to make sure that they meet require-ments for cleanliness, hygiene, attire, and proper practices.


How To Monitor

Supervisors should observe all employees at the beginning of the shift and peri-odically throughout the day as necessary to make sure that they are:

• clean,andpracticinggoodhygiene,

• wearingappropriateoutergarments,

• notwearingjewelryorotherprohibiteditems,

• wearingappropriatehairandbeardrestraints,

• havenotbroughtpersonalitemsintoworkareas,

• notsmoking,eating,ordrinkinginworkareas,and

• notusingpersonalcareproductsthatcouldcontaminatefood.

If problems are observed, employees should be required to correct their attire or behavior before they start to work. Supervisors should be trained to make sure that they under-stand what is acceptable and how to work with employees to correct problems.

It may be useful to develop a simple check list that covers all of the personal hygiene re-quirements that should be monitored on a daily basis. Although the current GMP does not require monitoring records, you may want to keep a record of the results of your observa-tions for your own use. Records should also be kept of employee training for both super-visors and for other employees to demonstrate that have been informed about company policies and understand them.


Proper Hand WashingNow that you understand what personal hygiene practices need to be followed by food workers, let’s look at the GMP requirement for proper hand washing.

GMP Requirement: All persons working in direct contact with food, food-contact surfaces, or food-packaging material must wash their hands thoroughly (and sani-tize if necessary to protect against contamination with undesirable microorganisms) in an adequate hand-washing facility before starting work, after each absence from the work station, and at any other time when the hands may have become soiled or contaminated.

There are three parts to proper hand washing in this GMP, how to wash your hands, when to wash your hands and where to wash your hands. We will discuss each of these, including why hand washing is so important on the following pages.


Why Hand Washing is ImportantHandwashing is one of the most important things you can do to reduce the likelihood of contaminating food. This is because microorganisms are commonly transferred to food by workers hands.

Hand Washing Behavior: Many different studies have shown that when it comes to washing hands, what people say they do can be very different from their actual behavior. In one study of hand washing behavior done for the American Society for Microbiology, more than 9 in 10 people said that they wash their hands after using a public restroom, but only two thirds of them actually did wash their hands after using the bathroom. The study also found that women were more likely to wash their hands after using the toilet facility than men.High Risk Behavior:Thesefindingsareespeciallyimportantiffoodworkersbehavelikethe rest of the general public. If a food worker does not wash their hands after using the bathroom or after they touch something that is dirty and then touch food, they increase the risk of contaminating the food and even causing the person who eats the food to get sick.


How To Wash Your HandsThe GMP regulation doesn’t just say that you need to wash your hands, it says that you need to wash your hands properly. The skin on your hands has many cracks, wrinkles, crevices, and hardened areas that can harbor dirt and bacteria as well as the areas around andunderneaththefingernails.

Hand Washing Procedure: Although hand washing seems to be a simple and easy task, most people do not know how to wash their hands properly. Let’s look at the steps you should take to wash your hands properly.


How To Wash Your HandsHand Washing Tips: Thoroughly scrubbing all areas of your hands for enough time with soap is the most effective way to loosen any dirt, oils, and microorganisms that might be onyourhands,whichwillthenbewashedawaybyrinsingyourhandsunderwarm,flow-ingwater.Studieshaveshownthatthefingertipsandtheareasaroundandunderyourfingernailscanbethemostdifficultpartofthehandtoclean.Thatiswhyallfoodwork-ersshouldkeeptheirfingernailstrimmedandshort.Handwashingcannotbereliedontoremove bacteria from infections, wounds or sores. That is also why anyone with cuts or sores must either wear gloves or not work in areas where food is handled.

Hand Washing Video: Because proper handwashing is so important, let’s review the right way to do it. Click on the “forward” button on GMP TV to watch our hand washing video.


When To Wash Your HandsIt’s just as important to know when to wash your hands as it is to know how and where to wash them. The GMP requires that food workers wash their hands at any time when their hands may have become dirty or contaminated. At a minimum you need to wash your hands before starting work, after going to the bathroom, and any time you leave your work station.

Click on the start button below to see WHEN you need to wash your hands.


Where to Wash Your HandsNow that you know how and when to wash your hands, let’s discuss where to wash your hands. The GMP says that you have to have an adequate facility to wash them. What does this mean?

Hand Wash Stations: Food workers should wash their hands in sinks or hand wash sta-tions that are only used for this purpose - not in a sink that might be used to wash equip-ment or food. These dedicated hand wash facilities must be located either in the restroom or outside the restroom and in any area where food is handled. It is important that these hand wash facilities be located in an area that is convenient for workers to use. If it is dif-ficultforworkerstogettohandwashsinksorstationstheyarenotlikelytousethem.

Equipment: There are many different types of hand washing facilities that can be used. Although they may be designed differently, it is essential that all hand wash facilities pro-vide the following things:


Hand Washing FacilitiesGMP TV: Click on the photos in the GMP TV below to see some examples of various types of hand wash stations that could be used in a food facility, and both good and bad prac-tices.


What You Can Do

Anyone who works in food plant will need to wash their hands many times each day. To meet the hand washing requirements of the GMP you need to:

Evaluate the location of washing facilities or stations to ensure that it is conve-nient for employees to wash their hands at all times when it is necessary.

Develop company policies that describe when, where and how all employees must wash their hands throughout the workday.

Train all employees to make sure that they understand why hand washing is im-portant and when, where and how to wash their hands properly.

Monitor hand wash stations daily to make sure that they are working and are properly equipped with hot and cold running water, soap, and disposable towels.

Monitor employee hand washing practices routinely to make sure that all em-ployees follow company policies on how and when hands must be washed.

How To Monitor

Supervisors should monitor employee hand washing practices daily to ensure that ex-pected practices are followed. Hand wash facilities should also be monitored daily to be sure that they are operating properly and have the proper supplies including soap, dispos-able towels, and other items that are needed. Although the current GMP does not require monitoring records, you may want to keep a record of the results of your observations for your own use. If any actions are necessary to correct problems, these actions should also be noted on a written record. Records should also be kept to demonstrate that all employ-ees have been properly trained.


Using GlovesGMP Requirement: Maintain gloves, if they are used in food handling, in an intact, clean and sanitary condition. Gloves should be of an impermeable material.

Follow Local Regulations: For some tasks, such as the handling of foods that will not be cooked before they are eaten, workers may need to wear gloves to protect food from contamination. In fact, some states and many local regulatory agencies do not al-low any direct hand contact with food. These authorities believe that wearing gloves provides an extra barrier to protect food from potential fecal contamination from workers who have not properly washed their hands. But remember, even if you wear gloves you will still need to wash your hands before putting on your gloves! If you don’t, you will contaminate the gloves.

Gloves and Hand Washing: Workers who wear gloves must still wash their hands properly at the proper time and place as we discussed earlier. Gloves can be as easily contaminated as bare hands, and workers should follow the procedures described earlier in when to wash. Workers should change their gloves after all of the activities described earlier for hand washing. For example, if a worker wearing gloves coughs or sneezes, they should wash their hands and change their gloves. If a worker leaves the work station to go on break, they should throw their gloves away when they leave and wash their hands and put on a new pair of gloves before they start handling food again.


GlovesTypes of Gloves: The GMP also requires that gloves be impermeable. This means that water, oils or other materials in the food must not be able to be ab-sorbed by or pass through the glove. Two general types of gloves, vinyl and latex, can provide an ef-fective barrier. Since some people may have or de-velopanallergytolatexgloves,mostfirmsusesometype of vinyl or plastic gloves. Cloth gloves are not impermeable, and therefore are not acceptable when handling food products.

Glove Durability: You should also consider how strong the gloves need to be for the work that is be-ing done. Inexpensive gloves can be very thin, not fitwell,andtearorpunctureeasily.Youmayneedtoevaluateseveraldifferenttypesofglovestofindonesthat are suited and durable enough for the job, but not so expensive that workers would be discouraged to change and throw them away as often as necessary.

Sanitizing Gloves: Gloves (or hands for that matter) should be washed and sanitized if the food you are working with will not be cooked by the consumer before it is eaten. Food plants typically set up “hand dips” with a sanitizer solution so that after hand wash-ing, employees can dip their hands, or gloves. These hand dips should contain a sanitizing solution whose strength is equivalent to 100 ppm (parts per million) of chlorine or 12.5 to 25 ppm iodine or other suitable hand sanitizer. It’s important to keep in mind that these hand dip solutions will lose their effectiveness if gloves or hands are dirty. Hand dips must also be consistently checked and maintained throughout the work day to be sure that the proper sanitizer strength is maintained. Remember that “hand-dips” never take the place of hand washing.


GlovesGMP TV: Click on the photos in the GMP TV below to review information on the proper use of gloves and hand sanitizer dips.



What You Can Do

To meet the GMP requirement that gloves be maintained in an intact, clean and sanitary condition and should be made of impermeable material you need to:

Determine if there are any state or local regulations related to the use of gloves when handling food, and adjust procedures or policies as necessary to meet these requirements.

Evaluate the type of gloves that are used to make sure that they are imperme-able, durable for their intended use, can be cleaned and sanitized, and do not create employee skin allergy or other problems.

Evaluate company procedures or policies that describe when and where em-ployees will wear gloves and hand washing and sanitizing procedures that must be followed before and after employees put on their gloves. Make and implement any changes that are necessary.

Monitor employees daily to make sure that they are using gloves properly and fol-lowing hand washing and glove sanitizing procedures.

Monitor glove sanitizing solutions daily to make sure that the proper sanitizer concentration is used.

How To Monitor

Supervisors should monitor employees daily to ensure that expected glove use and prac-tices are followed. Hand sanitizing stations or dips should also be monitored daily to be sure that they are clean and have the proper sanitizer concentration. Although the current GMP does not require monitoring records, you may want to keep a record of the results of your observations for your own use. If any actions are necessary to correct problems, these actions should also be noted on a written record. Records should also be kept to demonstrate that all employees have been properly trained.

Education and TrainingThroughout this Module, we have emphasized the need for employee training to make sure that employees understand what they need to do in terms of personal hygiene and hand washing to make sure that they do not contaminate food, food contact surfaces, or food packaging material. Recognizing the importance of training, this section of the GMP includesarequirementthatspecificallyaddressesemployeeeducationandtraining.Thereare two parts in this section of the GMP. Let’s look at the education requirement for super-visorypersonnelfirst.

GMP Requirement: Personnel responsible for identifying sanitation failures or food contamination should have a background of education or experience, or a combination thereof, to provide a level of competency necessary for production of clean and safe food.

Supervisor Skills: This GMP requirement says that managers and/or supervisors who are responsible for monitoring food production and sanitation, and for correcting problems need to have appropri-ate training or experience. It just makes sense that every company should have people who understand food safety to take on the re-sponsibility of making sure that everything that is needed to produce safe food under sanitary conditions is done each day. These same people should be the ones to make the decisions necessary to solve or correct problems when they occur and to determine if food safety has been compromised.

Training Programs: There are many different types of education, training, and experience that might be appropriate for different situ-ations. Formal education in food science or in culinary or food ser-vice courses could provide adequate food safety knowledge. Other training programs, such as this Internet course, may provide the knowledgethatsupervisorsneedtohelpyourfirmcomplywiththeGMPs. There are a variety of other programs that provide training via the Internet, workshops, continuing education courses, or other training experiences.

Work Experience: The GMP also recognizes that on-the-job expe-rience can provide many of the skills necessary to make sure that individuals can adequately supervise employees and make sure that your company can produce clean and safe food products.


SupervisionGMP Requirement: Responsibility for assuring compliance by all personnel with the requirements of this part (of the GMP regulation) shall be clearly assigned to su-pervisory personnel.

The last requirement in this section of the GMP recognizes the need for supervision to make sure that all employees follow the personal hygiene and hand washing practices re-viewed in this Module.

Monitoring Employees: Earlier we discussed the fact that employees don’t always do what they know they should do, or say that they do. It is up to supervisors to continually monitor employee practices to make sure that food is not contaminated. Remember it only takes a single incident, in which an employee is sick with an illness that can be transmit-ted by food or if an employee doesn’t wash their hands properly, to produce contaminated food.

Supervisory Responsibilities: Eachcompanymustclearlydefinewhoisresponsibleforsupervising and monitoring employees’ personal hygiene and hand washing behavior and practices. For example, in a small operation a single person may be responsible for super-vising employees’ behavior and practices. In a larger company, many different individuals may have this responsibility for the employees associated with certain areas of the plant or production activities. These supervisors should also be responsible for the monitoring and record keeping activities described earlier in each section of this Module such as the daily employee hygiene checklist.


Basic Employee TrainingGMP Requirement: Food handlers and supervisors should receive appropriate training in proper food handling techniques and food protection principles and should be informed of the danger of poor personal hygiene and insanitary prac-tices.

The second part of this GMP requirement relates to the basic food handling, personal hy-giene, and sanitary practices that are necessary to produce safe and clean food. This GMP basically says that all employees who handle food should receive training on the basic practices that we have covered in this Module.

Training Programs: Employee training can be conducted in many different ways, and many different training tools have been developed. It is important that you select or de-velop a training program that will be understood by your employees. You may need to consider language, culture, learning skills, and other factors to be sure that employees understand the practices that they are required to follow. There are also many different approaches to training that can include written materials, visual aides such as videos, CDs, posters or even on-site demonstrations.

Employee Handbook:Manyfirmsdevelopahandbookthatdescribesacceptablebehav-ior and practices that employees are required to read and understand. This basic entry-level training should be followed with additional periodic training sessions conducted by plant managers or supervisors that use the materials described above. Training programs for employees that describe the practices covered in this and other Modules that can be delivered in the plant are available upon completion of this Internet course and will be described in Module 12.


What You Can Do

To meet the GMP requirements for proper supervision and training of employees you need to:

Identify what training, experience, or other qualifications are needed for su-pervisors or managers who will be responsible for food safety and basic employee training.

Provide any additional training opportunities for managers and supervisors to ensure that they have all necessary skills.

Develop company policies or written materials that describe how employees will be informed about proper personal hygiene, illnesses, acceptable work practices and hand washing.

Develop and conduct entry-level employee training activities. For example an employee handbook can be developed that describes all company policies and ex-pected practices or behavior. Employees can be required to read the handbook and acknowledge that they have read and understood its contents.

Conduct supplemental employee training programs to make sure that employ-ees understand all hygiene requirements and why they are important. It may be necessary to develop and deliver employee training programs on various topics and conduct on-the-job training activities to correct problems and ensure that proper practices are followed.

Assign responsibilitytospecificsupervisoryemployeesformakingsurethatallemployees meet the GMP requirements for employee health, hygiene, hand washing, and use of gloves each day.

Monitor and keep records of all employee training activities.

Monitor the activities of assigned supervisors to make sure that they are ensur-ing that all employees comply with GMP requirements for employee health, hygiene, hand washing and the use of gloves.

How To Monitor

Supervisors should be assigned to monitor employee behavior and practices on a daily basis to make sure that they meet the employee health, hygiene, hand washing and glove use requirements of the GMP. Although the current GMP does not require monitoring re-cords, you may want to require supervisors to keep track of the observations and any cor-rectionsthataremadeforyourownuse.Recordsofemployeequalificationsandtrainingprograms should be kept to demonstrate that the requirements of this section of the GMP have been met.


Review ExerciseThis completes our review of the sections of the GMP that focus on employee health, hy-giene and hand washing.

To help review what you have learned, we would like you to look at the photograph below andseeifyoucanfindthe4differentwaysthattheseworkersmeetthepersonalrequire-ments of the GMP that we have covered in this Module. You will need to use your comput-er’s mouse to move the cursor over a part of the picture you think is acceptable and click the left button on your mouse. A member of our “Clean Team” will tell you why the part of the photo you selected complies with the GMP regulation.

GMP TV:Useyourmousetofindtheacceptableactivitiesorbehaviorinthispicture.



Checklist Questions for GMP Requirements in Module 6In Module 6 we reviewed the GMP requirements for making sure that employees: do not have an illness that can be transmitted to food; wear the proper garments, foot wear, and hair covering; comply with good personal hygiene practices; wash their hands properly at the proper times; use gloves properly; and are properly supervised and receive the proper training. We have compiled the items from the What You Can Do sections of this Module intoasimplifiedseriesofquestionstohelpyoucreatealistofthingsthatyoumayneedto do to meet these GMP requirements.

Use this list to remind yourself to:

• Evaluatethestatusorconditionofyourexistingfacilitiesorsystems,andtodevelopaplan to make any changes that are needed.

• Createnewproceduresorchangeexistingproceduresifnecessary.

• Developnewmonitoringproceduresorchangeyourexistingprocedures.

TodownloadtheChecklistbelowasaPDFfilethatyoucanprint,clickonthebutton.

Download Module 6 Checklist and Internet Resources

Employee Health

Do you have company policies and procedures that describe the symptoms, illnesses, or conditions that employees must report to their supervisor? Do you need to develop new policies or procedures or modify existing ones?

Do you have an employee handbook and/or conduct training for employees and su-pervisors that explain company policies and procedures for employees who may have an illness that could be transmitted to food? Do you need to develop a handbook or training programs or modify existing ones?

Do you have procedures for routinely monitoring employees and their behavior to detect symptoms of illness? Do you need to develop new monitoring procedures or modify existing ones?


Employee Cleanliness and Hygiene

Do you have policies and procedures that describe company requirements for:

• Garments,bodycoveringandshoesorboots?

• Hairandbeardormoustachecoveringorrestraints?

• Personalcleanliness?

• Useofjewelry,cosmetics,skincareproductsandmedicines?

• Prohibitedactivitiessuchaseating,smoking,anddrinking?

• Personalitemrestrictionsinworkareas?

Do you have an employee handbook and/or conduct training programs to explain these policies and procedures to employees? Do you need to develop new training materials or modify existing ones?

Do you have procedures for routinely monitoring employees’ attire, cleanliness and hygiene? Do you need to develop new monitoring procedures or modify existing ones?

Hand Washing

Do you have the proper hand washing facilities or stations in all of the proper loca-tions where they are needed? Make a list of repairs or installations that are needed.

Do you have a procedure to routinely monitor all hand washing stations to make sure that they are properly equipped with hot water, soap, and disposable towels? Do you need to develop new monitoring procedures or modify existing ones?

Do you have a company procedure that describes how, when, and where employees must wash their hands or use gloves? Do you need to develop these procedures or modify existing ones?

Do you conduct training to make sure that employees understand how, when and where they must wash their hands? Do you need to develop new training programs, modify existing ones, or conduct them more frequently?

Do you have a procedure to routinely monitor employees to make sure that they are washing their hands properly at the proper time or using gloves properly? Do you need to develop new monitoring procedures or modify existing ones?


Training and Supervision

Do the people responsible for identifying sanitation failures and problems related to employee practices and behavior have the training and/or experience that is neces-sary? What additional training is needed and can be provided?

Has responsibility been clearly assigned to one or more individuals for making sure that all employees comply with all hygiene and hand washing requirements? Do these people have the necessary training or skills? If not, what additional training is need-ed?

Check Your KnowledgeThis concludes the study material for Module 6. You now need to review the 6 ques-tionsforthisModule,findthecorrectanswertoeachquestion,andsubmityouranswerswhile you are logged into the course with your Username and Password.

Each of the following pages has a single question that will appear on your screen. Click on the answer you think is correct. You will see a text box that will tell you if this answer iscorrectorwrongandwhy.Whenyoufindthecorrectanswer,besuretowritedownthequestion number and the correct answer. Then move on to the next question.

ClickontheForwardbuttonatthetopofthispagetogotothefirstquestion.


Documents

Module 06