Personnel Practices

What are Personnel Practices?

Personnel practices are a set of conditions and measures followed by employees (especially front line production personnel) to prevent contamination to food products.¹

Relevance

Personnel are a key element in a food facility. They work with sensitive materials: bulk dry and liquid ingredients, food equipment, utensils, and food contact surfaces, etc. Given their normal activities, they may represent a potential source of microbiological, chemical, and physical contamination to the products if proper food safety procedures and practices are not followed.¹ The following are the most important concerns regarding food contamination due to poor personnel practices:

Biological contamination

• When bacteria infect an individual and cause gastrointestinal illness (food poisoning), they live and multiply in the gut and are excreted in feces or in vomit. The risk of bacterial spread is highest when the infected person has diarrhea or is vomiting, as it is  more likely that the individual may contaminate other surfaces with their unsanitized hands.
• Food may be contaminated with harmful bacteria, either directly by an infected food handler, or indirectly by a contact surface that has been contaminated by an infected food handler. Foods that will not be cooked before being eaten are of greater risk because cooking is a kill step.
• Some viruses can be transmitted through food and spread in the same way as bacteria, with similar pathogenic effects. The main difference is that viruses cannot multiply on food but can survive on food for long periods. Viruses can spread via contaminated hands and some can also spread through the air, especially when an infected person vomits.²

Physical contamination

• Objects such as jewelry, utensil elements, and body parts such as hair may fall and contaminate foods being processed. Customers would reject any product that is contaminated because it contains foreign materials.
• Depending on the material dimensions and nature, foreign objects may pose a physical hazard to consumers. According to Section 555.425 of the FDA’s Compliance Policy Guide, hard or sharp foreign objects that measure 7 mm to 25 mm in length are considered a physical hazard.
• Such objects may cause traumatic injury, including laceration and perforation of tissues of the mouth, tongue, throat, stomach and intestine, as well as damage to the teeth and gums.³

Regulatory compliance

Personnel practices are thoroughly addressed in 21 CFR Part 117.10 (Current Good Manufacturing Practice, Hazard Analysis, and Risk–based Preventive Controls for Human Food). Under this rule, requirements have been established for personnel, and the management of the food processing establishment must take reasonable measures and precautions to ensure disease control and cleanliness.⁴

Application

• As a responsible and regulation-compliant entity, a food company must document and implement appropriate personnel practices to minimize the risk of product contamination.
• Such risk can be managed by implementing and adhering to a personnel practices program. This program establishes a set of standards and procedures of minimum hygiene that people must observe in order to ensure that they do not become sources of product contamination.

Components of a personnel practices program¹

Procedures and policies related to the following issues, where relevant, should be in place:

1. Employee health (illness) control
2. Hand-washing and hand-sanitizing
3. Cleanliness of uniforms/outer garments
4. Hair restraint (hair nets, headbands, caps, beard covers, etc.)
5. Use of gloves (if needed)
6. Unsecured jewelry
7. Personal items (segregation and storage of personal belongings)
8. Food, drink, and tobacco use
9. Cosmetics restrictions (skin lotions, nail polish, perfumes, makeup, etc.)

References

1.  AIB International. “Food Safety and Sanitation.” Food Safety and Sanitation Distance Learning Course, Chapter 2.
2.  United Kingdom Food Standards Agency. “Food Handlers: Fitness to Work – Regulatory Guidance and Best Practice Advice for Food Business Operators.”, 2009, https://www.food.gov.uk/sites/default/files/multimedia/pdfs/publication/fitnesstoworkguide09v3.pdf
3. U.S. Food and Drug Administration. “Compliance Policy Guide – Section 555.425, Update No. 12.”  Division of Compliance Policy/Office of Enforcement, 23 March 1999, https://www.fda.gov/ohrms/dockets/98fr/990463gd.pdf
4. U.S. Food and Drug Administration. “21 CFR 117.10 – Current Good Manufacturing Practice, Hazard Analysis, And Risk–based Preventive Controls For Human Food.” 1 Apr, 2017, https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?fr=117.10