Sanitary Design: Across The Board

The Right Tool For The Job


Perhaps you’ve tried to do a job at home and said to yourself, “This would be so easy if I had the right tools!”  Aficionados of home improvement shows know that the projects seem so easy simply because the host always magically has every specialty tool that they need.  


This same idea -- the right tool for the job -- can be applied to all industries. In the food, healthcare and pharmaceutical industries, this plays out in “sanitary design.”


What Is Sanitary Design?


Sanitary design means setting things up for sanitary conditions right from the start. This applies to buildings, equipment, and even the clothing worn by workers.


Think about it: it’s much easier to keep a food plant clean if the floors are properly sloped to ensure drainage, the walls are made of smooth, easily-cleanable materials. and that the wall/floor juncture is coved to allow water to run away from the walls. 90° angles can easily trap water and debris, and are hard to clean.


The Law Regarding Worker Clothing


Let’s take a look at what your workers are supposed to wear. In the Code of Federal Regulations, the regulation states the following;


(b) Cleanliness. All persons working in direct contact with food, food-contact surfaces, and food-packaging materials must conform to hygienic practices while on duty to the extent necessary to protect against allergen cross-contact and against contamination of food. The methods for maintaining cleanliness include:


(1) Wearing outer garments … in a manner that protects against allergen cross-contact and against the contamination of food, food-contact surfaces, or food-packaging materials...


(6) Wearing… hair nets, headbands, caps, beard covers, or other effective hair restraints.


(7) Storing clothing or other personal belongings in areas other than where food is exposed or where equipment or utensils are washed.


The regulation does not specifically define what plant workers and visitors must wear, but it does set basic guidelines.  This kind of regulation is known as an “interpretive regulation”. In other words, it gives each company options for compliance. The key wording is “protect against allergen cross-contact and contamination of food.”


Okay, so, what is appropriate? It really depends upon the operation. A processor that is manufacturing aseptic beverages or puddings in a closed system will face different issues than a plant that processes and packages ready-to-eat products like smoked salmon or luncheon meats. Let’s get specific.


Safe Clothing in Sanitary Design


  1. Safety-oriented clothing should be comfortable and not prone to shredding or shedding.


  1. Clothing should be secured with snaps or Velcro.


  1. Some companies favor smocks which tie in the back. These are good work clothes, but some safety experts discourage ties, which could conceivably get caught in moving machinery parts.


  1. Make sure there are no pockets located above the waist. Why? If someone has a pocket, they will inevitably something in it (like a pen), which could fall out and end up in the food.


  1. Garments provided by the company must fit properly so they don’t pose any kind of risk.


  1. Look for breathable fabrics, which are more pleasant to wear. Workers in a hot environment wearing garments made from polyester are going to get very uncomfortable.


  1. Workers must have a place to change from street clothes to work clothes. This should be a place where they feel that they, and their valuables, are secure.


  1. You will also need to set up a system for cleaning and sanitizing worker clothes. This can be done in-house or through a contract company. Whichever you choose, it’s important to ensure that laundry is done correctly. That means washing, drying, storage and handling not only to clean the garments, but to protect them from contamination once they are cleaned.


  1. Another part of the equation is hair restraints. You’ll need hair nets or beard nets (snoods) to cover all hair on the head and face. Hair restraints come in different styles and weaves, so find something that is effective and comfortable. Also consider color when selecting hair restraints. Light-colored hair restraints allow managers to more easily monitor workers, since they can see if they are being worn, and if they are being worn correctly. If your work force has dark hair, black or brown hair nets really don’t allow your managers to easily monitor compliance.


  1. Sometimes, sanitary design includes boots, safety shoes, plastic sleeves, masks or gloves.  


  1. A critical piece to the Sanitary Design equation is education.  Make sure that your workforce is taught not only what they must wear, but also how to wear it properly.


  1. The final note in the system is compliance. Your managers must know that their duty is to enforce the safety rules within your company. Of course, they shouldn't be looking to “catch” and “punish” people, but offenders place themselves, their colleagues, and your company at risk, and they need to be reined in. Safety rules are no joke, and the consequences for violations can be very scary. This is why enforcing the rules is so vital.


In summary, if you give your workers the right tools, the right environment, the right training, and the right supervision, then you are using a Sanitary Design approach.


Glove Mismatch: Wrong Glove for the Right Job

Your employees wear protective gloves while working, so their hands are completely safe. Right?

Well, maybe.

The truth is that in workplaces across the world, workers are wearing the wrong gloves for the job. Protective gloves are not one-size-fits-all, and the cheapest option will not work for every application. Even more surprisingly, a very cut-resistant glove that provides maximum protection may still not be the right glove for your application. Why? Here’s the lowdown.

Cut Resistance: The Basics

If you’re running an ice cream parlor and need your employees serving the ice cream to wear gloves for sanitary reasons, you don’t need to worry about cut resistance at all. In this case, there’s no need to buy gloves made of stronger materials; instead, opt for comfortable poly gloves.

But let’s say your employees are handling more than just an ice cream scoop. Let’s say they’re hospital employees, handling instruments that can cause cuts and lacerations. In this case, you’ll want gloves that are much more cut resistant, but still allow them to have the dexterity they’ll need. Your best bet, in this case, might be 3 to 5 mil nitrile gloves.

Now imagine that you’re in the pest control industry, and your employees may have to deal with rabid animals or stinging insects. In these cases, you’ll want to choose gloves that are extremely strong, such as those made from Kevlar or metal mesh. You might also want to look into options that include gauntlets or extended sleeves to protect your employees’ arms.

You’ll also want to think about whether your employees’ hands will be exposed to caustic chemicals or intense heat. Either of these situations would require different glove specifications.

Some gloves also include a gripping surface to deal with slippery surfaces, such as those covered with motor oil. Workers in the automotive industry may prefer this option.

The Dangers of Overgloving

So why not just buy the most protective glove possible, no matter what the job? Besides the added expense, the most protective glove may still not be the best option for your needs. Gloves with higher levels of cut resistance tend to have lower levels of dexterity. For example, a surgeon would have a hard time using a metal mesh glove, because it would be difficult to maneuver the fingers in the precise way to perform surgery. Using an overly protective glove, in this case, could severely compromise the surgeon’s ability to successfully complete his job.

In addition, if your employees view the protective gloves as too restricting and uncomfortable, they may decide to avoid using the gloves altogether. This can put them at a far higher risk of hand injury than if they had been provided with adequate -- but not as strong -- protective gloves.


Glove Size

In addition to looking at cut resistance and material, you’ll also want to make sure that the gloves are sized correctly. Gloves that are overly large can be difficult to manipulate, and gloves that are too small can tire out the employee’s hands, plus they are prone to tearing more easily.

If you choose the wrong glove for the application, you may be putting your worker’s safety in jeopardy, while thinking that you’re actually ensuring their safety. So no matter which industry you work in, choosing the right glove for each application is essential.

Keep Hair Where It Belongs


Have you ever had the misfortune to find a hair in your food? Most of us can unfortunately answer “Yes” to that unsavory experience.  That hair probably did not make you sick, but it could certainly ruin a meal or discourage you from ever buying the product that contained the hair ever again.

The picture below is of a cookie that was offered as a snack at a sanitation workshop presented many years ago. The cookie became a great teaching aid, as it emphasized the importance of good personal hygiene, and especially the use of hair restraints.  Hair, whether it is on the head, face, or arms, will fall out eventually.  That’s what hair does. Look at your comb or brush after you comb your hair -- there are always a few hairs -- so the trick is to keep those hairs out of food that is being prepared or processed.


Food Processors vs. Foodservice Operators

Food processors spend thousands of dollars each year to keep foreign materials, including hair, out of their products. Part of the program is outfitting workers  in a food plant with hair restraints.  These include hair nets, snoods, or beard nets, and in many cases, sleeves. (Yes, hair on arms may end up in product.)

It is a shame that foodservice and restaurant operators generally don’t have the same commitment. While some do require hairnets, many restaurants don’t require that their employees use any kind of hair restraints, and others feel that baseball caps or tall chefs hats are adequate. They aren’t.  

The food processing industry does a pretty good job when it comes to keeping hair out of food, but it could do better. Let’s consider the basics of a program designed to keep hair out of foods and ingredients.

Elements of an Effective Program

The first step is an element that the processor has little control over: personal hygiene. Good hygiene keeps the hair clean, and it also provides a side benefit. Washing the hair flushes out loose hairs that have fallen out.

The next step is ensuring that the workforce properly contains the hair. It’s up to the company to provide the garments (hair restraints and sleeves), and to make sure that the workers understand why it’s important to wear them.

The Basics: Hair Restraints, Beard Restraints, and Sleeves  

Hair restraints come in many names, sizes, colors and formats. Here’s a rundown of what you need to know.

Names. Hair restraints go by many titles. They may be called “hairnets,” “bouffants,” or something else.

Format means weaves or apertures. There are hair nets that have a very fine weave with extremely small apertures (< 1/16 inch) and those with course weaves (1/4 inch or more). The smaller the aperture, the greater the probability hair will be properly restrained and contained.

Color is actually an important consideration. Among the colors offered by Gloves by Web are white, blue, green, red, orange, pink, and yellow. A company should choose a hair restraint that will allow management to determine, at a glance, that the hair restraint is being worn properly. This is why black or brown hair restraints are a bad idea; it’s really hard to see whether someone with dark hair is wearing their hairnet properly.  We also offer hairnets and bouffant caps in different colors so that companies can color-coordinate your work zones and prevent cross-contamination.

How beard and moustache restraints are worn is another issue that must be addressed.  Some operations try and establish policies that define the size or configuration of moustaches and whether a restraint is required (for example, “If the moustache does not go below the top lip, no restraint is required.”) If a man wishes to sport a beard or moustache, he will have to wear a restraint of some sort.

The next element in building a program for restraining hair is to properly educate the work force on how to wear the gear, and to make certain that supervisors are overseeing proper use.  The basic rules are:

  1. Hair nets should cover the hair and the ears.
  2. All hair should be restrained within the net.
  3. Hair restraints must be worn by every worker entering the processing area, even those workers with shaved heads.  
  4. No exceptions.

Education is the key.  When hiring new employees, personal hygiene and how to properly wear uniforms and hair restraints must be part of the orientation process. If your workforce includes employees who don’t speak English well, make sure your training and materials are bilingual. The subject of hygiene and hair restraints should be addressed during yearly refresher training sessions. In addition, it’s a good idea to post pictures that show the right and wrong way to wear a hair net, snood and sleeves, if they are required. Many companies get their people to pose for these pictures to promote a sense of ownership and make them feel more involved.

Finally, it is up to the supervisors to be sure that the work force follows the rules.  If they observe someone without hair restraints or wearing one or more items improperly, they need to take action.

The photograph here shows a situation in which management was simply “asleep at the switch.” The company mandates that hair nets be worn, yet the workers in the picture are not complying.


So, to help keep hair out of foods, food processors (and restaurant operators) need to select the proper hair restraints for the people, set policies on how they are to be worn, train the workforce  on these policies, and make sure management enforces the policies that have been set.  Hair may not make someone sick, but it is not something that anyone wants to find in their food. Food processors and restaurant operators rely on repeat sales.  That single hair could cost you a customer -- so do what you can to keep hair out of your products.

Pictures used with permission of Richard F. Stier

Don’t Throw In The Towel! How to Encourage PPE Compliance in the Workplace

How do you get your factory workers to wear protective equipment?

You’re constantly reminding your employees to wear the necessary Personal Protective Equipment (PPE) for their jobs, but sometimes you feel like you’re talking to a brick wall. Some may be noncompliant because of job fatigue, a lack of knowledge, or discomfort with the provided PPE. Others may rationalize or feel too complacent to add another step to the routine. Think you’re alone? You’re not -- in fact, a survey conducted by Kimberly-Clark Professional at the 2006 National Safety Council Congress found that 85% of the attendees had witnessed PPE noncompliance at their organizations.

But don’t give up! Luckily, there are steps you can take to improve employee PPE compliance and make your organization safer for all of your employees.

Choose the right PPE. If you choose the wrong products, your employees will rightfully grumble about using them. Get your employees’ input on the style, comfort levels, and ease of care of the different PPE options. Don’t forget to think about replacement frequency, ergonomics, and other factors. Ask your team for feedback after using the PPE for a period of time to make sure you’re all on the same page.

  • Example: Ill-fitting gloves will create hand fatigue. This is a simple ergonomic issue, and you can find out by asking your employees if their hands feel weak. If so, they likely need to switch to gloves of a different size of material.

    Establish policies and procedures about PPE. Gather your employees and ask for their input in creating rules that work for them. You’ll want to preface the conversation by explaining the rationale behind PPE use so that they don’t view it as a senseless chore.

  • Example: When you have employees with different hand sizes, which is usually the case, finding the correct gloves each morning can be annoying. An easy solution is to color-coordinate sizes so grabbing the right glove can be done quickly and without thinking.

    Make compliance easy. You don’t want it to be too difficult for employees to comply with the policies, so brainstorm ways to make it as simple as possible. That might mean creating multi-lingual applications and making sure that PPE is readily available and located near your employees’ workspaces.

  • Example: Place PPE in quick-grab dispensers, and make sure you reorder early. If your PPE is hard to find or always running out, you’re making it difficult for your employees to stay safe.

    Provide sufficient training. Make sure that your employees are clear on your company’s policies on PPE use, through the initial training as well as periodic reminders. You also may want to consider using outside trainers occasionally, both to show your company’s commitment and to show that outside sources agree with the importance of your safety protocol.

  • Example: A simple one-hour refresher course on the risks your employees face and how to protect against them can be very effective. Keeping workplace dangers top-of-mind makes employees more vigilant. Some vendors, including Gloves by Web, offer this service to their customers.

    Show that the leadership is committed. If managers are asking employees to follow a policy that they don’t follow themselves, they’ll be setting themselves up for failure. Lead by example and discuss PPE use before each new project to underscore its importance.

  • Example: Whenever you go on the factory floor or out in the field -- even briefly -- make a point of properly donning PPE. Your employees are watching your actions to see if your company policies are “just to stay compliant” or if they are genuinely important.

    Reinforce compliance. In order to ensure that your employees follow the company policies on PPE use, consider rewarding them for doing so, as well as creating adverse consequences for those who do not. This might mean requiring employees to sign a written policy or organizing a daily PPE check.

    • Example: Brightly colored PPE is easier to spot, so supervisors can easily see who is (and who isn’t) wearing it . In a large factory, white PPE is sometimes hard to see; use colors that stand out against your workplace background.


    Safety in your organization should be non-negotiable. The steps that you take to ensure that your employees comply with PPE policies can make the difference between an unsafe environment and one that does its best to protect every employee.

    The Importance of Allergen Cleaning

    Allergen Cleaning - Gloves by Web

    How things have changed. Twenty-five years ago, food allergens weren’t an issue. Today, every food processor needs to be conscious of allergens.

    Allergens are highlighted throughout the FDA’s recently-issued Preventive Controls Regulations. Good Manufacturing Practices have been modified to include both cross-contamination and cross-contact. While these terms are sometimes used interchangeably, there’s a difference. A good explanation can be found at MenuTrinfo:

    Cross Contamination

    Cross-contamination [typically] … happens when foods are raw. Whether this is at the processing plant, when it’s in the field, or on the cutting board, cross-contamination happens when bacteria from one food product transfers to another.

    More importantly, contamination implies that that one can easily avoid the problem altogether by heating it to a certain temperature. After all, that’s how you kill bacteria.

    When people with allergies … express a concern about cross-contamination, the cooks or chefs’ first thought is that it will be fine if they just cook it off. The problem … of course, is that you can’t cook away an allergy, no matter how high the heat.


    While cross-contamination refers to the transference of bacteria, cross-contact is the transference of proteins. Sadly, you can’t cook off a protein.

    Proteins can transfer in many ways. This can be with a fork that stirs a pot of boiling noodles, or using an uncleaned grill. As allergies don’t burn off, even a food from a long time ago can cause cross-contact and a severe allergic reaction!

     For the purposes of a food processor, allergen cross-contact means any unintentional incorporation of a food allergen into your products. The regulation mandates that food processors manage allergens. In practice, here’s what you do and don’t have to ensure:


    1. You DO have to make preventative protocols that minimize the potential for cross-contact.
    2. You DO have to establish sanitation controls, ensuring that food contact surfaces on which allergens are processed and handled are sanitary.  
    3. You DO have to verify cleanliness; demonstrating that the food contact surfaces and equipment in question have been cleaned as documented.
    4. You DON’T have to validate your allergen cleaning and sanitizing program, but in reality, many processors conduct this exercise.


    One of the reasons why allergens are emphasized in the regulation is apparent from Figure 1 developed by FARRP in 2016. Clearly, there has been an upward trend in allergen recalls for the past two decades. You can also see the same trend by looking at the FDA website.

    So far, so good. You understand the regulation. You want to protect your company, your products and your customers. But how should you go about doing this?


    Let’s look at how you might develop, document, implement, and maintain an Allergen Cleaning Program. A critical component of building this program will be making sure that all of the people doing the cleaning and management will be trained, and that the training is documented.


    Many processors utilize visually clean as their “cleanliness yardstick.Does it look clean? This sounds good. However, depending upon how the equipment is designed, visually clean is not always “properly cleaned.” Rather, the proper cleaning for equipment will depend upon the type of product being manufactured.


    • Equipment in plants manufacturing dry products like bakery products and tree nuts are dry-cleaned, which means no water is used.
    • Equipment in plants manufacturing most other foods, including ready-to-eat meats, entrees, and seafoods, are wet-cleaned using standard cleaning practices. This includes; rinse to remove gross soil; clean with detergent; rinse; sanitize; and rinse to remove the sanitizer.  


    Cleaning protocols must be developed by the food processor, usually with input from their chemical supplier. The chemical supplier needs to look at the operation and recommend the chemicals that will do the best job. Suppliers are also often called in to train the plant workers on handling and use of the chemicals and equipment needed for cleaning. Part of this training process must include the proper use of personal protective equipment (PPE) which includes gloves. The company’s staff needs to learn how to use the PPE, as well as how to maintain their protective equipment.


    But, let’s get back to developing the cleaning protocols. When developing the allergen cleaning program, you need to make sure that your protocol is effective. In the words of the regulation, the processor must “determine whether or not the plan is sufficient to ensure clean equipment and environment using visibly clean criteria and quantifiable methods.”  


    So how do you determine that clean is clean enough? And what are “quantifiable methods?”


    The best method is using allergen ELISA (Enzyme Linked Immuno-Absorbent Assay) tests. Validation tests should be done with the product that has the highest protein load. It’s also important to conduct a positive control.


    There are different ways to validate a system: swabbing, product push through, finished product testing and evaluation of CIP rinse water. If you use ELISA tests, you should evaluate different tests and select the best one. If the target allergen is recovered during validation testing, the cleaning protocol should be enhanced. A minimum of two cleaning trials must be conducted to properly validate the protocol. In industry, many operations run more during validation trials. Once a cleaning regimen is established, it must be repeated each day. This process should be documented.


    You will need a second party to verify that cleaning is done properly. This party will certify that procedures were followed and that equipment appeared clean. As part of cleaning verification, companies use swabs. These can be ATP, allergen swabs, protein swabs or even microbiological tests.


    In the end, controlling allergens is a careful and costly process. But as a processor, it’s simply part of protecting consumers and your business.




    United States Food & Drug Administration, (2015), Title 21, Code of Federal Regulations, Part 117, “Current Good Manufacturing Practice Hazard Analysis and Risk Based Preventive Controls for Human Food,” U.S. Government Printing Office, Washington, D.C.

    FARRP, (2016), FDA Allergen Recalls,” Food Allergen Research and Resource Program, Lincoln, NE