Dairy Establishment Inspection Manual – Chapter 10 Prerequisite Programs
1.10.04 - Personnel Program

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The objective of the personnel program is to ensure safe food handling practices. The personnel program is to provide, on an ongoing basis, the necessary training to production personnel.

This documented program, as well as its effective implementation, will help control operational conditions within an establishment allowing for environmental conditions that are favourable to the production of safe food. It serves as a prerequisite program or universal-type CCP for a HACPP based program.

1.10.04.01 General

Every dairy establishment and importer must have a written training program for employees, providing adequate training in personal hygiene and the hygienic handling of food to all food handlers at the beginning of their employment. This training is to be reinforced and updated at appropriate intervals. An adequate personnel program monitors and controls all elements in this section and maintains the appropriate records.

Adherence to the criteria is verified by examining the establishment's written program that outlines the procedures that will be undertaken to ensure adequate training is maintained. The program must specify:

  • areas to be inspected (what is done),
  • tasks to be performed (how it is done),
  • person responsible (who does it),
  • inspection frequencies (how often or when it is done),
  • records to be kept
  • parameters of acceptability/unacceptability (tolerances)
  • results of monitoring,
  • verification procedures (both on-site and record review)
  • action to be taken for deviant situations.

The monitoring and verification procedures clearly define the preventative measures taken to prevent the re-occurrence of deviations. The person responsible for verifying the program must be different from the person performing the task. This program must also be updated as required when changes occur.

Training must be adequate and suitable to the complexity of the manufacturing process and the tasks assigned. For example:

  1. Personnel must be trained to understand the importance of the critical control points for which they are responsible, the critical limits, the procedures for monitoring, the action to be taken if the limits are not met, and the records to be kept.
  2. Personnel responsible for maintenance of equipment impacting on food safety, are to be properly trained to identify deficiencies that could affect product safety and to take the appropriate corrective action i.e., in house repairs, contract repairs. Individuals performing maintenance on specific equipment must also be appropriately trained, e.g. closing machines, recorders. Personnel responsible for critical process test procedures are properly trained.
  3. Personnel and supervisors responsible for the sanitation program must understand the principles and methods required for effective cleaning and sanitizing. Employees handling hazardous chemicals should be instructed in safe handling techniques.
  4. Additional training needs to be provided as necessary to ensure current knowledge of equipment and process technology, e.g. specific technical training, apprenticeship programs, etc.

In order to minimize the risk that dairy products could be subject to while under control of the establishment, it is recommended that management provide training in food security awareness to encourage all staff to be alert to any signs of tampering or other malicious or terrorist actions or areas that may be vulnerable to such actions. Employees should be encouraged to be alert to the presence of unidentified or unknown individuals that are in areas to which they do not have designated access and report them to management.

This task will assess the written program and the records kept. The assessment of other inspection tasks will provide on-site verification of the effectiveness of the plant's training program.

1.10.04.02 Flow and Practices

This task will assess the movement or flow of both people and equipment throughout the establishment as well as the processing practices (good manufacturing practices) utilized.

To reduce the risk of contamination in processing and packaging areas the movement of personnel and equipment between areas must be restricted and well controlled. This applies to lab personnel, delivery and maintenance personnel as well as staff performing various processing activities. Generally speaking, personnel (including maintenance staff) may move freely from microbiologically clean areas to less clean ones but their movement back to a cleaner area must be restricted or very well controlled. Personnel in raw receiving areas should not move into any other areas of the plant unless strict procedures are followed (e.g. foot baths, hand dips, etc.). Employees responsible for the receiving of raw milk must not move throughout the plant as their clothing and shoes may be a source of contamination in clean areas. This also applies to all visitors to the plant such as farmers, salespersons and field personnel. The colour coding of clothing facilitates the monitoring of personnel flow.

With respect to equipment layout, a process flow that is straight and simple is preferable from a sanitation point of view. The movement of portable equipment (e.g. pallets, carts, etc.) from one area to another must also be restricted and controlled to minimize the potential for cross contamination. The same principle applies to equipment as to personnel flow; equipment should not move to or back from cleaner areas after being in less clean areas without appropriate controls.

Special attention must be made to control frequent personnel and equipment flow between wet areas of the plant to minimize the risk of spreading contamination. The use of strategically located and well maintained foot baths or sprays may be one method to minimize the risk of spreading contamination.

To evaluate the flow aspect uniformly:

  1. observe if personnel/equipment move between activity areas.
  2. observe if controls are in place (required if movement occurs from less clean to cleaner areas).
  3. if controls are not adequate, assess the task as not satisfactory.

The manufacturer ensures good personal hygiene and hygienic behaviour and work procedures are followed to prevent contamination of food products.

1.10.04.03 Hygiene & Health

This task assesses the employee's hygiene as well as their personal behaviour and habits in areas where food is processed. Practices related to food handling are evaluated under task 1.10.04.02 Flow and Practices.

Clean and appropriate clothing, good grooming and habits as well as employee health monitoring reduce the possibility of milk, milk products, containers and equipment from becoming contaminated. Although no jewellery, including facial adornments is preferred, jewellery worn for religious, marital or health reasons must be properly secured and covered. These items have the potential to fall into or otherwise contaminate the dairy product and as such pose a food safety hazard. Clothing cleaned by a private service should be delivered clean and protected and stored separately from street clothes.

It is recommended that employee clothing should be white or light coloured or colour coded to distinguish work areas (e.g. red in raw receiving areas and white in the packaging room). It is recommended that hair nets that are used be obvious and shower type.

Poor hygiene and all unhygienic behaviours that would contaminate food must be prohibited. Personnel engaged in food handling activities should refrain from behaviour which could result in contamination of food, for example smoking, spitting, chewing or eating, and sneezing or coughing over unprotected food. Personal effects and street clothing must not be kept in food handling areas and must be stored in a manner to prevent contamination. In-plant footwear and clothing is to worn only within the plant. Wearing in-plant footwear and clothing outside the plant and then returning to the plant could result in a source of contamination to the product or processing area. The establishment would develop policies and procedures to mitigate this requirement.

It is important that employees with obvious health conditions are not in direct contact with food products. Plant management must have a policy to prevent personnel known to be suffering from, or known to be carriers of a disease transmissible through food, from working in food handling areas. This policy could be part of the company's written training program directed to all new employees. Proper training and education of employees in food safety, maintenance of hand washing facilities and sanitary waste handling are measures that can be included in the preventing the spread of foodborne disease.

The manufacturer must require that employees advise management when they are suffering from a communicable disease likely to be transmitted through food. Employees should be encouraged to report to their supervisors whenever they have diarrhoea, sore throat, fever, a cold, or open skin lesions, or are jaundiced. Employees with cuts or wounds must be assigned to non-product work areas or their cut or wound must be protected by a secure, waterproof covering. Latex gloves are not recommended for use in a food establishment. There is evidence to suggest that for some individuals there is a potential allergy concern with the transfer of latex to food products. This is not a mandatory requirement, but only a recommendation that when establishments use sanitary gloves they choose a non-latex type.

The Health Surveillance and Management Procedures For Food-Handling Personnel Technical Report from the World Health Organization, dated 1989 is a good reference document on the hygienic approach to food handling. According to this document infections and intoxications potentially transmissible by food handlers include: Staphylococcus aureus infection, typhoid and paratyphoid fevers, non-typhi salmonellosis, Escherichia coli enteritis, Shigellosis, Cholera and Viral hepatitis A. Some other illnesses to be concerned with include those due to Campylobacter jejuni, Rotovirus, E. coli 0157:H7, Norwalk and Norwalk-type viruses, Streptococcus pyogenes, Yerisinia enterocolitica and Giardia lambia. Since health examinations of food-handling personnel are not effective in preventing the spread of foodborne diseases, alternative measures might include surveillance of outbreaks of foodborne diseases, the use of a HACPP system within the food establishment, education and training of managers and food handlers in food safety and provision and maintenance of hand-washing facilities and the sanitary collection and disposal of wastes.

1.10.04.04 Handling of Materials

This task assesses how personnel handle the ingredients (e.g. fruits, nuts, powders, starter cultures, etc.) and packaging materials (glass containers, foil and plastic wrap, powder bags, etc.) during processing. It also assesses the manual formation of packaging containers such as ice cream cartons.

The materials must not pose a contamination risk as they are received into the processing area and when they are in use. If these materials are not properly handled they can be contaminated by dust, foreign materials, moisture and personnel; subsequently they can affect the safety of the product. Prior to filling, containers should be cleaned by air, suction or water.

Task 1.10.02.03, Incoming Material, evaluates the initial receipt of incoming ingredients and packaging material.

Personnel Program Summary Table
Table description

This table shows the tasks, ratings and inspection criteria for Personnel Program general, flow and practices, hygiene & health, handling of materials.

Task Inspection Criteria
1.10.04.01 General (HS=3) (A) Documented Training Program
  1. Policy
    • Adequate and suitable training for all production personnel covering the following areas:
      • flow/controlled access of personnel and visitors
      • hygienic food handling
      • responsibilities for food safety controls (e.g. Hazard Analysis Critical Control Point (HACCP))
      • maintenance of equipment impacting on food safety
      • sanitation
      • technical training, where necessary
    • System to monitor the health, hygiene and habits of employees involved in food handling
    • System to assess adherence to policies
    • Specifies person responsible, inspection frequencies
    • Specifies parameters of acceptability/tolerances
    • Specifies preventative measures to prevent re-occurrence of deviations
    • Updated as required

(B) Records

A representative sampling of the plant's historical records must be assessed.

  1. Records must be:
    • Accessible and complete
    • Clear, legible and permanent
  2. Information must indicate:
    • All training, monitoring and verification (both on-site and record review) results
      • training has occurred
      • frequency and type of training
      • re-training activity
    • Satisfactory follow-up when deviations found and documentation of actions taken
1.10.04.02 Flow and Practices (HS=2) (A) Policy
  • Controls movement of personnel and equipment

(B) Flow

  • No unauthorized personnel/equipment in areas
  • Well controlled movement between areas
  • Straight and simple process flow

(C) Practices

  • Operational Practices
    • food
    • cleaning
    • wastes
  • Duties to maintain food safety controls (e.g. HACCP)
1.10.04.03 Hygiene & Health (HS=2) (A) Hygiene
  1. Clothing
    • Clean
    • Washable or disposable
    • Cleaned on-site or by private service only
    • No buttons or pockets above waist
    • Hair coverings and beard-coverings; properly worn so as to completely cover the hair
    • Footwear and clothing for in-plant use, where required
    • If required, sanitary disposable gloves
  2. Grooming
    • Clean nails; no polish
    • No jewelry; wedding bands/medic alerts covered by appropriate glove or covering
  3. Health Condition
    • No cuts or wounds exposed
    • Program that prevents an employee from being in contact with food while:
      • inflicted with skin infections, sores, diarrhoea, colds, etc.
    • Employees advise management when suffering from a communicable disease that could be transmitted through food

(B) Behaviour and Habits

  • Hand washing/Sanitizing
    • starting and returning to work
    • after using toilet facilities
    • after hands soiled or contaminated
    • employees use hand dips, where required
  • No eating; gum chewing
  • No use of tobacco, no smoking
  • No spitting
  • No sneezing or coughing over unprotected food
  • Personal effects and street clothing not stored in food handling areas
1.10.04.04 Handling of Materials (ingredients, packaging materials) (HS=2) (A) Receiving into processing area
  • No evidence of pest contamination
  • No dust, rust, etc.
  • Outer wrappings cleaned and/or removed

(B) During processing

  • Materials protected from aerosols, moisture, contamination
    • formed containers inverted
    • lids or protective coverings
  • Sanitary handling
  • Contaminated materials not re-used
  • Unused portions resealed and returned to storage
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