Regulation R638: Requirements for protective clothing

Personal Protective Equipment (PPE) in the food industry primarily protects food from possible contamination by the food handler.  Protective clothing may include:

• hair nets
• jackets and trousers
• safety shoes
• overall or dust coats

PPE may also be designed to protect food handler from possible injury and environmental conditions that could be detrimental to their health and well-being. It is important that the PPE remains clean and is not worn outside the processing or food handling area. Improper use of PPE could result in food contamination, which consequently could result in consumers getting sick or injured. PPE, therefore, protects food from being contaminated and protect the consumer from foodborne illnesses. The first thing a food handler should do before commencing a day’s shift is to wear clean PPE then wash their hands effectively.

What does the regulation R638 of 2018 say about PPE?

Below is a summary of the standard and requirements for protective clothing as per Regulation R638 of 2018. This regulation gives guidance on what the basic requirements of PPE are in relation to food handling facilities.

9(1) A person may not handle or be allowed to handle food without wearing suitable protective clothing as specified in sub-regulation 2.

Depending on the nature of handling, high risk, high care or ambient temperature, applicable PPE can range from wearing of hairnets, bear nets, disposable gloves, sleeves, aprons and other suitable PPE. The facility should determine which PPE is most suitable based on the nature of the process, the risk of product contamination and the impact of the food handling process on the food handler.

9(2) PPE of a person handling food that is not packed must:

(a) Be clean and neat when the person begins to handle the food;

• Preferably, PPE should be of a bright colour to ensure a person can easily spot it when it becomes soiled or dirty. Unhygienic PPE can potentially contaminate food products with harmful bacterial rending food unsafe for consumption.

(b) At all times during the handling of the food, be in such a clean condition and be of such design and material that it cannot contaminate the food;

• PPE must not have button above the waist since the button may be a physical hazard that could fall into food. PPE should not have any exposed zippers because food residue could stick in between leading to microbial contamination. Imagine a sticky zipper because of rotten food! Yuck !!

(c) Be so designed that the food cannot come into direct contact with any part of the body, excluding the hands:

• Human being provide ideal conditions for microorganisms such as Staphylococcus aureus to thrive. It is therefore critical to ensure that all parts of our bodies are adequately covered by applicable PPE to prevent bacterial food contamination. If your food manufacturing process requires you to use exposed body parts e.g. in a small artisan cheese factory, cheese makers would sometimes use their hands to mix ingredients with milk in a cheese vat, ensure that your arms are thoroughly washed.

9(3) Visitors to food premises must, where applicable wear suitable protective clothing.

• Contractors, suppliers and visitors also need to adhere to food safety requirements of wearing applicable clean PPE. They also need to be free from contagious or infectious diseases like jaundice, diarrhoea, fever, nausea, discharge from nose, eyes and ears.

Apart from keeping PPE under hygienic conditions, food handlers should ensure they do not have exposed body parts that may have cut or grazes.  PPE from high risk or high care areas must be separated from PPE in low risk areas to avoid cross contamination. PPE must never leave the food handling facility, old and torn PPE must be replaced. The facility should ensure there are strict controls in place to prevent contamination of PPE. It is the responsibility of the facility to ensure employees were clean, and contamination free PPE.

Rules for Protective Clothing

• Collect clean protective clothing prior to starting work
• All persons must wear hairnets or an approved headgear in the Factory
• No sitting anywhere in protective clothing
• Avoid using strong perfumes or scented chemicals on PPE
• No protective clothing may be worn outside borders of the premises
• Protective clothing must be stored in lockers dedicated for protective clothing and should not be stored with food or personal items
• Plastic protective wear to be disposed of after use in the waste bins provided on leaving the production area
• Personnel protective equipment must be changed or cleaned when it becomes contaminated by obnoxious matter or becomes dirty
• Personnel may only change into protective clothing in allocated areas
• Replacement of damaged clothing must be done immediately to prevent any risk of contamination
• Protective clothing is laundered on site and issued to the workers every week
• Plaster inspections will be done twice a day, before production commences and after lunch time
• It is the responsibility of all employees to ensure that the plaster does not go into the cartons
• Gloves, if worn, must not be chipped, and must be regularly monitored to ensure they are not chipped at any point