Protective clothing

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A documented system is required for ensuring that protective clothing and footwear used at a dairy processing establishment will help prevent contamination from a person’s body or anything from their body, such as hair, jewellery and clothing, to a dairy product and any raw materials or ingredients used in dairy products. The protective clothing and footwear should be:

  • Suitable and worn in all relevant food handling areas and worn as per requirements for specific food handling areas,
  • Maintained in good repair, clean, and not pose a contamination risk to the dairy product,
  • Stored appropriately, and
  • Explained in staff induction training, and visitor policies with regard to required procedures.

For the relevant legislative references in the Export Control (Milk and Milk Products) Rules 2021, please refer to the department's, Approved Arrangement Checklist.

Any clothing that is worn in the dairy manufacturing environment, including personal protective clothing and equipment, such as high visibility vests, protective eye goggles, earmuffs, protective boots and gloves, must not pose a contamination hazard to the manufactured product. This includes foreign materials picked up from the external environment and any materials that form part of the uniform (zips, buttons and thread pieces).

Like other production equipment, protective clothing worn in food handling areas should be maintained in good condition and stored in an appropriate location to prevent contamination. This is done so that the protective clothing does not pose a foreign object contamination risk in the manufacturing environment. Consideration should be given as to whether and how protective clothing and footwear should be removed and replaced for meal and toilet breaks.

An appropriate procedure needs to be in place, with clear instructions for use, including ‘donning up/down’ procedures, disposal and/or cleaning requirements, and instructions for what is required in each production and non-production area. Training in the proper use and wearing of protective clothing and footwear must be conducted for all staff and the effectiveness of the training must be assessed, with documented records. Visitors and contractors attending the establishment must also be made aware of protective clothing requirements as part of their site induction.

Appropriate records should be kept, including staff training, the assessment of the effectiveness of the training, disposal of unsuitable protective clothing, purchase and assessment of new protective clothing, repairs and cleaning. Hairnets and beard snoods must be worn properly to control the risk of facial and head hair contamination.

The document should highlight, where applicable, certain clothing/footwear that may only be allowed in certain zones or production areas and excluded in other zones. This is to ensure that the most appropriate clothing/footwear is worn for the task, and to prevent cross-contamination between different areas, especially when moving from a low-risk to a high-risk area.

When documenting and reviewing your protective clothing procedure, you should consider the following points:

  • The design of protective clothing must be practical and, where appropriate, take into account human behavioural aspects in the workplace. Uniform design should be practical as not to hinder the operator from performing their duties.
  • Uniforms should avoid front pockets as they can collect foreign matter and are considered a less than ideal storage location. As an example, if an operator working above a production line leans forward, anything stored in the front pocket can accidentally fall in.
  • White or brightly coloured uniforms are preferred as they show stains/contaminants easily, letting the wearer (or another observant operator) know a clothing change is necessary.
  • Consider the colour of disposable protective clothing and footwear used on site. The use of a brightly coloured uniform which is an opposing colour to the products being manufactured would enable the establishment to identify a damaged piece should one of these items accidentally enter the manufacturing line.
  • Where applicable, a donning up/down procedure should be established for each work area and signage advising requirements should be visibly available and strategically placed in key areas.
  • Considerations should be given to other wearable items such as jewellery, body piercings, beanies or thermal wear, medical bracelets and hearing aids, that pose a risk to dairy products and must be documented in the protective clothing procedure.

Protective clothing, uniforms, PPE and footwear requirements must be communicated to all staff (new and existing), visitors and contractors to the site. Induction training on protective clothing requirements is relevant for all staff, visitors and contractors, and ongoing staff should also be refreshed on the requirements as part of an ongoing training program.

Your site protective clothing procedure must be audited at least annually to ensure it is reviewed and updated for compliance.

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Self Assessment

How much do you know about Protective clothing?

Take this short assessment to find out.

Question 1

Cindy is the site quality manager at a dairy processing facility and has recently received several consumer complaints about foreign matter found in their product. In particular, several instances of a hair-like foreign substance has been reported by consumers.

Assuming the foreign object contamination occurred in the manufacturing area, as the site quality manager, what actions can Cindy take to rectify the issue?

Click all that apply.

Question 2

Emily was recently employed by a dairy processing facility and she is excited to be working in production, on a casual basis. Emily has experience working in similar dairy production companies in the past.

As a new casual employee, what measures can the dairy processing facility management take to ensure Emily is aware of site protective clothing and uniform requirements?

Click all that apply.