Elements of an Approved Arrangement

Handwashing stations should be located at the entry, or adjacent to the entry of food manufacturing areas. These handwashing stations should be separate to the toilets and must operate hands free, and be supplied with warm water, soap, and paper towels. Handwashing should be conducted by rinsing the hands with water, followed by vigorous lathering with soap, rinsed with water and thoroughly dried with paper towel or air hand drier (or similar). Sanitiser should only be applied after hands have been dried.

Where the hand washing water temperature is not regulated, mixer taps are preferred, which allow the employees to adjust the temperature of the water and encourage proper hand washing, as opposed to separate hot and cold-water outlets.

A person’s behaviour can also have the potential to cause contamination, so you need to define which behaviours are unacceptable in certain parts of your premises. For example, spitting and smoking around food can cause contamination of products. You should clarify in your procedure where staff are permitted to eat, drink, smoke or chew gum. When considering these factors, you also need to consider if any uniform changes are required before and after these activities.

Staff should report certain illnesses to their supervisors and may be asked not to handle food until they have fully recovered, with no symptoms for 48 hours. If a worker is suffering from vomiting, diarrhoea, gastro (gastroenteritis including viral gastroenteritis such as norovirus or rotavirus), hepatitis A and hepatitis E, sore throat with fever, and fever with jaundice, they should not work in the food handling areas as these are illnesses likely to be transmitted through food. This could indicate that they may have a food-borne illness and could spread it to the products they handle.

Any cuts or wounds must be cleaned and covered with an appropriate dressing (e.g. food industry adhesive plasters that are water proof, metal detectable and of a contrasting distinctive colour) to prevent contamination from both the wound and the dressing.

All staff (including contractors, visitors) must be advised of personnel hygiene requirements before entering premises. Training records should be kept to verify that all personnel are trained and refresher training was provided at appropriate intervals.

Food Standards Australia New Zealand (FSANZ) standard 3.2.2 - Technical fact sheet for food handlers and The Department of Health - personal hygiene tips for food handlers both summarise the personnel hygiene expectations and is a useful guidance document for the industry.

You must conduct regular internal audits which assess if personnel are adhering to hygiene policies. Hand swabs or contact plates may be taken at random from food handlers to verify your sites hand washing is thorough and effective.

When documenting your personnel hygiene procedures and reviewing your site’s current practice for compliance, please consider the following;

• Are hand washing stations available at key areas (such as production entry points, near staff amenities) to ensure proper hand washing practices can be followed?
• Do all hand washing stations have warm water, soap, hand drying and sanitising readily available?
• Do staff wash their hands after eating, using the toilet, coughing or sneezing, touching their face or nose, smoking or handling unsuitable materials?
• Does your company have a designated area for smoking and do personnel only smoke in this area?
• Are handkerchiefs allowed in production?
• Are your staff aware of your jewellery policy? Do you provide storage areas for personal items which are not allowed into your plant (example, medications or hazardous materials)?
• Are staff aware that they must report any suspected or diagnosed notifiable communicable disease to their supervisor and must not work in food handling areas until advised?
• Do you have a corrective action process and escalation process to manage any non-compliance sighted on site? Do you keep records of corrective actions taken, including any re-training, if personnel are not complying?