GUIDELINES FOR IMPLEMTING GMP IN FOOD PROCESSING
Personnel Standards
4.1 Staff training programme including records
4.1.1 All employees should be informed in writing of their legal obligations and the company’s policy on personal
hygiene prior to commencing work,with periodic updates as necessary,It is recommended that a standard
induction course explaining the relevant legislation is designed and used by all QA managers for new staff,
Auditor’s Recommendations,
Look At,Look For,
Company Training Policy Training Records
Identification of Roles and Responsibility
Training Frequency (Refresher courses)
4.1.2 It is recommended that all personnel be appropriately trained in food hygiene disciplines,relevant to the job
they do,This training should encompass the requirements of personal hygiene,the reasons why they are
so important and an explanation that they are a requirement,
Auditor’s Recommendations,
Look At,Look For,
Hygiene Training Records of training
4.1.3 Additionally ‘on the job’ training should be given to staff in order that they fully understand their
responsibilities and the need to follow written instructions and procedures,Particular attention should be
given here to overcoming language barriers and illiteracy problems,
Auditor’s Recommendations,
Look At,Look For,
Hygiene Training Responsibilities and roles
Awareness and Understanding of Operational Teams
4.1.4 All Production and Quality Assurance personnel must be fully trained in the principles of Good
Manufacturing Practice and comprehend the tasks assigned to them,All other personnel,including
engineers,service and cleaning staff whose duties take them into the factory should also receive
appropriate training,
Auditor’s Recommendations,
Look At,Look For,
Hygiene Programme
HACCP System
Training and awareness of staff to understand the principles with relevant
training linked to the degree of responsibility and their role
4.1.5 Training records should be kept on each individual member of staff and the effectiveness of training
monitored to confirm that designated procedures are being followed,
Auditor’s Recommendations,
Look At,Look For,
Training Records Training Schedule
Level of experience and/or qualification
4.1.6 In the event of termination of employment,due consideration should be given to potential risk to the
product and demonstrations of other operatives,Having earlier defined the employees legal obligations,
any appropriate precaution should be taken as necessary,
Auditor’s Recommendations,
Look At,Look For,
4.2 Head coverings,earrings,jewellery,and watches
4.2.1 Suitable hair retaining wear,must be worn by all personnel in open food areas,including production staff,
engineers,management and other casual site visitors,
Auditor’s Recommendations,
Look At,Look For,
Personal Hygiene Compliance with basic food safety principles
4.2.2 Whatever style of hat is chosen,it is best,especially for long hair,if hairnets are used first,These should
be brightly coloured,not brown,so that they can be easily seen,Blue is usually the colour chosen
because it is not a food colour,
Auditor’s Recommendations,
Look At,Look For,
Personal Hygiene Compliance with basic food safety principles
4.2.3 The headwear provided must retain all hair,however,hairgrips or metal clips to hold headgear in position
must not be allowed,Headwear must be of generous size and comfortable,
Auditor’s Recommendations,
Look At,Look For,
Foreign Body
Contamination
Personal Hygiene
Compliance with basic food safety principles
Records of foreign body contamination,non-conformance and corrective
action
Records and details of preventative measures
4.2.4 Personnel working in,or entering food processing or packing areas must not wear any jewellery,Wrist
watches,ear rings,necklaces and bangles are not permissible,
Auditor’s Recommendations,
Look At,Look For,
Foreign Body
Contamination
Personal Hygiene
Compliance with basic food safety principles
Records of foreign body contamination,non-conformance and corrective
action
Records and details of preventative measures
4.2.5 Nail varnish must not be worn since it presents a potential foreign body risk to the product and strong
perfumes are not allowed because of the possibility of taint,
Auditor’s Recommendations,
Look At,Look For,
Foreign Body
Contamination
Personal Hygiene
Compliance with basic food safety principles
Records of foreign body contamination,non-conformance and corrective
action
Records and details of preventative measures
4.2.6 It is essential that management set a good example and also abide by these personal hygiene
requirements,
Auditor’s Recommendations,
Look At,Look For,
Foreign Body
Contamination
Personal Hygiene
Compliance with basic food safety principles
Records of foreign body contamination,non-conformance and corrective
action
Records and details of preventative measures
4.3 State of overalls,design and frequency of cleaning
4.3.1 All food handling operatives and persons who enter production areas for any reason,must be provided with
clean protective clothing which must be worn at all times,This includes engineers,management and other
casual visitors,
Auditor’s Recommendations,
Look At,Look For,
Personnel Hygiene Provision of clean clothing suitable for that persons tasks
Records of laundry
Records of non-conformance and corrective actions
4.3.2 It is recommended that protective clothing be free of loose fastenings,such as buttons,and top pockets,
Any internal pockets provided in the garment must be at hip level,When deciding which style to adopt,
attention should be given to how staff will dress and undress,
Auditor’s Recommendations,
Look At,Look For,
Protective Clothing
Personnel Hygiene
Use of appropriate food safety clothing
Records of clothing and replacement
Changing Procedure issued to staff
4.3.3 Boiler suits are not recommended for use in food production areas since during the changing regime,a
large proportion falls onto the floor creating a potential contamination risk,
Auditor’s Recommendations,
Look At,Look For,
Protective Clothing
Personnel Hygiene
Use of appropriate food safety clothing
Records of clothing and replacement
Changing Procedure issued to staff
4.3.4 Items of personal clothing (such as bodywarmers) must not be worn over protective clothing,and
undergarments must not protrude below sleeves and cuffs,
Auditor’s Recommendations,
Look At,Look For,
Protective Clothing
Personnel Hygiene
Use of appropriate food safety clothing
Records of clothing and replacement
Changing Procedure issued to staff
Protective clothing only worn in factory
4.3.5 Protective foot wear must be provided and a suitable facility to clean it,
Auditor’s Recommendations,
Look At,Look For,
Protective Clothing Use of appropriate footwear to meet safety requirements
Provision of suitable boot cleaning facilities to reduce contamination
4.3.6 Unless authorised,protective clothing and designated foot wear must not be worn by staff outside the
factory,going to or from work or taking breaks outside,(exceptions,forklift truck drivers and external
process workers ),Additionally,staff must not be allowed to take protective clothing from the premises,
Auditor’s Recommendations,
Look At,Look For,
Protective Clothing Use of appropriate clothing to meet safety requirements
Provision of suitable boot cleaning facilities to reduce likelihood of cross-
contamination
4.3.7 Where ear plugs or ear muffs are provided because of production noise levels,all such issues must be
accounted for at the end of each shift,
Auditor’s Recommendations,
Look At,Look For,
Protective Clothing Use of appropriate equipment to meet safety requirements
4.3.8 It is a management responsibility to ensure that an adequate supply of laundered protective clothing is
available,and that the laundry standards are high,Fraying edges and tears must be professionally
repaired,or the garment replaced to minimise the potential foreign body risk,
Auditor’s Recommendations,
Look At,Look For,
Protective Clothing Laundry procedure
Repair of non-conforming protective clothing
4.3.9 The changing frequency of newly laundered work wear,will ultimately be dependent on the type of products
being manufactured,A twice-weekly change of overalls/hats is recommended unless the job in hand is a
particularly dirty operation,when a more frequent change will be needed,
Auditor’s Recommendations,
Look At,Look For,
Protective Clothing Frequency of new clothing / change
Records of non-conformance and corrective actions
4.3.10 Colour coding of protective work wear is essential in high risk or multi-disciplinary sites,to identify
operatives and to ensure correct changing regimes,Additionally,service operatives with a specific role e.g,
engineers,cleaners,distribution personnel,should be easily recognisable,
Auditor’s Recommendations,
Look At,Look For,
Protective Clothing
Identification and
Traceability
Access to suitable protective clothing for process discipline
Colour coding and identification of significant staff members for segregation
or responsibility
4.3.11 Where the services of a contract laundry are commissioned their premises must be vetted to ensure that
standards are acceptable,and that cross contamination of cleaned overalls is not possible,Adequate
separation of food handlers protective clothing from other contracts (e.g,hospitals or pharmaceutical
industries) must be in place,Indeed,laundries with specific food processing units should be sought,
Auditor’s Recommendations,
Look At,Look For,
Contract Review Laundry service complies with minimum factory requirement
4.3.12 The hygienic transfer of overalls from laundry to food premises by distribution vehicles is essential,
Provision must be made to protect the overalls from contamination and the vehicles must be suitably
cleaned,‘Shrouding’ of high risk overalls in plastic film sleeves is very advantageous to ensure clean
handling practices prior to use,
Auditor’s Recommendations,
Look At,Look For,
4.4 Handwashing disciplines,‘hands free sink’,hand swabs
4.4.1 Provision must be made to ensure that hands are kept clean and washed at frequent intervals,preferably in
‘warm’ water,using a non-perfumed bactericidal soap,Hands should be thoroughly dried,nails kept short
and well manicured and cleaned by using a nailbrush,Where appropriate,non-perfumed barrier creams or
alcohol based skin sanitisers should be provided,
Hands must be washed:-
i,immediately before putting on protective clothing,particularly important in the case of high risk
personnel,
ii,immediately before commencing work,or entering production areas,
iii,after handling debris,refuse or food waste,
iv,if they become soiled or visibly contaminated,
v,after visiting the toilet,
vi,after blowing the nose or touching the mouth,
Auditor’s Recommendations,
Look At,Look For,
Personal Hygiene Training Records
Personal Hygiene Policy
4.4.2 Sufficient hand-wash stations must be provided in toilet areas and at each entrance to the production area
for the number of staff employed on site,
Auditor’s Recommendations,
Look At,Look For,
Personal Hygiene Position and cleanliness of hand wash stations
4.4.3 To ensure good handwashing disciplines,operatives should be channelled past the hand-wash stations by
the use of guardrails or other appropriate measures,
Auditor’s Recommendations,
Look At,Look For,
Personal Hygiene
Factory Plan
Position and location of handwash facilities ensure use by all personnel
4.4.4 Similar handwashing facilities should be provided at designated places within the food processing area to
encourage good personal hygiene disciplines,
Auditor’s Recommendations,
Look At,Look For,
Personal Hygiene
Factory Plan
Position and location of handwash facilities ensure use by all personnel
4.4.5,Hands free” knee,elbow or electronically operated sink units are required,with a good supply of potable
running water water,Hand operated taps and ceramic sinks should be avoided because of their potential
contamination risk,
Auditor’s Recommendations,
Look At,Look For,
Handwash System Design Compliance to food safety requirements
4.4.6 Adequate drying facilities must be provided e.g disposable paper towels, Open bins or foot operated
lidded bins must be provided at all hand-wash facilities for the disposal of sanitary waste,
Auditor’s Recommendations,
Look At,Look For,
Handwash System Design Compliance to food safety requirements
4.4.7 Hand-wash sinks and drying facilities must not be used for utensil or general cleaning purposes,
Auditor’s Recommendations,
Look At,Look For,
Handwash System Design Compliance to food safety requirements
Separate utensil washing facilities available,
4.4.8 Notices reminding staff of the handwashing requirements must be posted in each toilet,and by the urinal
area,in break/canteen areas,at the hand wash sinks,and on every entrance door to the production areas,
Auditor’s Recommendations,
Look At,Look For,
Personal Hygiene Training Records
Personal Hygiene Policy
4.4.9 The effectiveness of the handwashing disciplines should be monitored by the random implementation of
hand swabs or contact plates,Suitable growth medium for Total Viable counts,Coliform counts and
Staphylococcus aureus must be readily prepared and the swabs transferred as quickly as possible,For
demonstration purposes during food hygiene training,swabs should be taken before and after the hand
washing regime,
Auditor’s Recommendations,
Look At,Look For,
Personal Hygiene Training Records
Personal Hygiene Policy
Test Records and frequency
4.4.10 Where it is company policy to adopt the use of disposable colour coded gloves,in production areas,these
gloves must be treated as a ‘second skin’,and regularly washed and changed,If they become damaged
or torn,they must be removed because of the potential foreign body hazard,
Auditor’s Recommendations,
Look At,Look For,
Protective Clothing Use of disposable equipment / gloves / clothing
Ensure cleanliness and replacement upon damage
Records of non-conformance and factory checks
4.5 Dressings/First Aid - blue metal detectable
4.4.1 No person having untreated sores,cuts or grazes should be allowed to work in contact with foods,All
such injuries must be reported and suitably treated (by a trained nurse or first aider),
Auditor’s Recommendations,
Look At,Look For,
Medical Screening Medical Policy
Medical Procedure for illness
Medical Screening policy for infectious / transmitted diseases
4.4.2 Currently all cuts/ abrasions and sores on the hands are covered with a plaster and the hand covered with
disposable glove,It is recommended that all cuts,sores or abrasions on the skin must be covered,after
treatment,with a conspicuously coloured (blue) waterproof dressing,Such dressings must be accounted
for at the end of each shift,and must be renewed before the start of each shift,It is preferable that such
persons affected should not work on open food,
Auditor’s Recommendations,
Look At,Look For,
Medical Screening Medical Policy
Medical Procedure for illness
Medical Screening policy for infectious / transmitted diseases
Accident Log book and first aid equipment
4.6 Pre-employment health checks - annual medical,holiday return
4.6.1 All company employees must be required to complete an appropriate examination and medical
questionnaire,prior to commencing work,This applies to production/quality assurance staff,management,
engineers,cleaners,office staff and any other permanent/temporary,full time or part time staff,
Auditor’s Recommendations,
Look At,Look For,
Medical Screening Records of personal health status with verification by an appointed person
4.6.2 Persons directly involved in food processing or packing should be fit and capable of discharging their duties
effectively,
Auditor’s Recommendations,
Look At,Look For,
Medical Screening Health and fitness of employees ensures safe food practices
4.6.3 Persons suffering from any infectious illness (particularly gastro-intestinal disorders,vomiting,diarrhoea
etc...) must not be permitted to work in contact with food or other food handlers,Additionally,operatives
with skin infections,nasal or ear disorders should not be allowed to handle open food,
Auditor’s Recommendations,
Look At,Look For,
Medical Screening Medical Policy
Medical Procedure for illness
Medical Screening policy for infectious / transmitted diseases
Accident Log book and first aid equipment
4.6.4 Any person suffering from infectious illness must be declared medically fit by their doctor before being
allowed to return to work,Full records must be kept for each individual case,
Auditor’s Recommendations,
Look At,Look For,
Medical Screening Medical Policy
Medical Procedure for illness
Medical Screening policy for infectious / transmitted diseases
Accident Log book and first aid equipment
4.6.5 On returning from holidays all employees must report any food poisoning symptoms they have had during
their holiday and must be medically screened by a doctor prior to returning to work,Screening should
include the faecal testing for pathogenic,food poisoning bacteria e.g,Salmonella,Staphylococcus aureus,
etc,
Auditor’s Recommendations,
Look At,Look For,
Medical Screening Medical Policy
Medical Procedure for illness
Medical Screening policy for infectious / transmitted diseases
Accident Log book and first aid equipment
4.6.6 Bi-annual medical for all employees should be undertaken by the company to ensure that operatives are
healthy and capable of discharging their duties efficiently,
Auditor’s Recommendations,
Look At,Look For,
Medical Screening Medical Policy
Medical Procedure for illness
Medical Screening policy for infectious / transmitted diseases
Accident Log book and first aid equipment
4.7 Screening/questionnaire for visitors
4.7.1 There must be adequate screening of all visitors to the factory must occur,On arrival,they must report to
reception,sign the visitors book and complete a detailed questionnaire,The information required should
include:-
i,Name,company,date of visit,who visiting,
ii,Purpose of visit (which departments,individual),
iii,Other food premises visited within previous 72 hours (high risk factories only),
iv,Whether they have been stool tested for salmonella (high risk factories only),
v,If they have recently be abroad,if so where?
If the information provided gives cause for alarm,then following further investigation,accesses to the
factory should be declined,and an alternative appointment made,
Auditor’s Recommendations,
Look At,Look For,
Medical Screening Medical Policy
Medical Procedure for illness
Medical Screening policy for infectious / transmitted diseases
Accident Log book and first aid equipment
4.8 Adequate medical facilities
4.8.1 The company must provide the services of a fully trained nurse or first aider and a medical room with
adequate equipment for the first aid treatment of illness or injury,
Auditor’s Recommendations,
Look At,Look For,
Medical Screening Medical Policy
Medical Procedure for illness
Medical Screening policy for infectious / transmitted diseases
Accident Log book and first aid equipment
Provision of suitably trained staff
4.8.2 First aid equipment must be kept securely and issued only by trained staff,
Auditor’s Recommendations,
Look At,Look For,
Medical Screening Medical Policy
Medical Procedure for illness
Medical Screening policy for infectious / transmitted diseases
Accident Log book and first aid equipment
Provision of suitably trained staff
4.8.3 All treatments must be fully recorded in the medical record book provided,with the patient’s name,date,
disease and the medical supplies issued,
Auditor’s Recommendations,
Look At,Look For,
Medical Screening Medical Policy
Medical Procedure for illness
Medical Screening policy for infectious / transmitted diseases
Accident Log book and first aid equipment
Provision of suitably trained staff
4.9 Control of smoking,food and drink
4.9.1 Smoking and the use of tobacco must only be allowed in properly designated areas e.g,canteen,rest
rooms and offices,It is not permitted in production areas or toilets,Smoking utensils must not be carried
in pockets in production areas,Facilities for the disposal of smoking materials must be provided at exits
from smoking areas,
Auditor’s Recommendations,
Look At,Look For,
Personal / Factory Hygiene No smoking policy
Provision for smoking is given on the factory plan / layout
4.9.2 The company may decide at its own discretion,to make the whole production site a,No Smoking” zone,
This is perfectly acceptable but new employees should be informed at recruitment and established staff
notified of the company’s decision in writing,This would then be incorporated into the Code of Practice for
Personal Hygiene,
Auditor’s Recommendations,
Look At,Look For,
Personal / Factory Hygiene No smoking policy
Personal Hygiene Practice
4.9.3 Eating and drinking must only be allowed in properly designated areas,Eating sweets,chewing gum or
other food stuffs must be strictly forbidden in all production areas and toilet facilities,
Auditor’s Recommendations,
Look At,Look For,
Factory Hygiene / Staff
Facilities
Dining facilities separate from the production areas (Factory Plan)
Personal Hygiene policy
Food Safety Policy
4.9.4 Operatives must not be allowed to take their breaks or meals outside the building,without first removing
their protective clothing,
Auditor’s Recommendations,
Look At,Look For,
Personal Hygiene
Staff Facilities
Provision of dining and rest rooms for staff – Factory Plan
Protective clothing procedures
4.9.5 Hands must be washed after eating,
Auditor’s Recommendations,
Look At,Look For,
Personal Hygiene Use of good personal hygiene practices
4.9.6 Where drinking is permitted,a drinking fountain is the preferred source of supply,as it is easily controlled,
clean and tidy,
Auditor’s Recommendations,
Look At,Look For,
Staff Facilities Provision of suitable drinking water supply for staff separated from
production supply
4.10 Staff facilities - lockers,canteen,toilets,change areas
4.10.1 Adequate lockers must be provided for all personnel for the safe storage of personnel effects such as
outdoor clothing,bags,etc,This will eliminate the risk of them being brought into production areas (which
is forbidden),Lockers should be easily cleaned and,if possible,designed with a sloping top to prevent dust
harbourage and use as a shelf,
Auditor’s Recommendations,
Look At,Look For,
Staff Facilities Factory layout
Separated Changing rooms and toilets and use
4.10.2 A separate canteen or rest room area must be provided for operatives to take their meals and breaks,
Refreshments must not be taken into production areas,It is recommended that overalls be removed prior
to using these areas,
Auditor’s Recommendations,
Look At,Look For,
Staff Facilities Factory Plan – provision of separated factory facilities
4.10.3 Canteen facilities,particularly the food preparation areas must be of good design,have adequate storage
and chilling facilities and be well run and maintained by appropriate staff,
Auditor’s Recommendations,
Look At,Look For,
Staff Facilities Factory plan and design specifications
Maintained and operated by suitably trained staff (if applicable)
4.10.4 Automatic drink dispensers can be acceptable,provided that they are suitably located,adequately cleaned
and maintained,Disposal facilities for non-breakable empty drinking containers must be provided,Plastic
beakers or cups must not be taken away from the vicinity of the drinks dispenser,
Auditor’s Recommendations,
Look At,Look For,
Staff Facilities Provision of suitable equipment for the staff is not mandatory,but were it is
installed,ensure suitable facilities exist to ensure maintenance of clean and
maintained environment
4.10.5 Rest areas must be kept in good decorative order,properly maintained and cleaned,and should provide
adequate seating facilities to meet the maximum usage,
Auditor’s Recommendations,
Look At,Look For,
Staff Facilities Factory Layout
Provision of suitable safe and hygienic facilities
4.10.6 Where canteen and rest room facilities are being shared,between high and low risk operatives,all
operatives must remove protective clothing before entering the area,
Auditor’s Recommendations,
Look At,Look For,
Personal Hygiene
Staff Facilities
Staff Hygiene
Removal of protective clothing
4.10.8 Canteen and rest room areas must exercise preventative pest control systems consistent with those
adopted in other areas of the factory,
Auditor’s Recommendations,
Look At,Look For,
Staff Facilities Housekeeping Practices implemented
Records for pest control
4.10.10 Separate male and female toilets must be provided which are adequate for the number of employees on
site and comply at least to the minimum requirements of the Public Health Act,
Auditor’s Recommendations,
Look At,Look For,
Staff Facilities Provision of suitable toilets for male and female staff with washing facilities
and maintenance
Factory layout and design
Separated from the production areas
4.10.10 In high risk processes or sensitive environments,separate facilities may be required for different groups of
operatives,Operatives should remove their overalls prior to using the toilet,
Auditor’s Recommendations,
Look At,Look For,
Staff Facilities
Factory Design
Separate toilet facilities from production facilities
4.10.11 All toilets must be adequately lit and ventilated and separated from production areas by an ante-room
supplied with handwashing facilities,
Auditor’s Recommendations,
Look At,Look For,
Staff Facilities Provision of suitable lighting
Separated from production areas and changing facilities
Supply of handwashing facilities
4.10.12 Toilet areas must be of good hygienic design and the floors,walls,ceiling and sanitary equipment must be
clean and in good decorative order,
Auditor’s Recommendations,
Look At,Look For,
Staff Facilities Provision of suitable lighting
Separated from production areas and changing facilities
Supply of handwashing facilities
Hygienic Design and layout
4.10.13 Adequate changing facilities must be provided for operatives to facilitate changing into protective clothing
prior to entering the processing areas,
Auditor’s Recommendations,
Look At,Look For,
Staff Facilities Suitable facilities to allow high and / or low risk changing
Provision of suitable lighting
Separated from high and low risk production areas
Supply of handwashing facilities
Hygienic Design and layout
4.10.14 Separate storage must be provided for outdoor clothes and foot wear and the storage of protective clothing
to prevent the risk of cross contamination,
Auditor’s Recommendations,
Look At,Look For,
Staff Facilities
Protective Clothing
Factory Layout
Provision of locker rooms for outdoor clothing
Provision of lockers for storage of factory protective clothing
4.10.15 Changing rooms must be kept in good decorative order,maintained to a hygienic standard and exercise
pest control measures,
Auditor’s Recommendations,
Look At,Look For,
Staff Facilities Provision of hygiene cleaning with records
Pest Control Records
4.10.16 Changing facilities must not be used for eating,drinking or smoking,
Auditor’s Recommendations,
Look At,Look For,
Staff Facilities Changing facilities provided only for changing clothing