Personnel: Protective Clothing and PPE
Aligned with BRCGS Food Safety Issue 9 – Clause 7.4
Requirement Overview
BRCGS Clause 7.4 requires sites to provide, manage, and monitor protective clothing (PPE) appropriate to the risk level of the food operation. This ensures protection of the product from contamination and safeguards personnel in relevant environments.
Clause 7.4.1: “Protective clothing shall be provided, worn, and maintained to protect products from contamination.”
Clause 7.4.2 – 7.4.5: Further specify requirements for PPE design, laundering, storage, change frequency, and use in high-risk, high-care, and ambient high-care areas.
Proper PPE procedures support both product integrity and employee hygiene standards, particularly in food handling, processing, and packaging zones.
Aligned with BRCGS for Storage & Distribution Issue 4 – Clause 4.3.1 & 4.3.3
Requirement Overview
BRCGS for Storage & Distribution requires that products moved via cross-docking are traceable and controlled at all times, even when they are not held in storage for extended periods.
Clause 4.3.1: “The company shall ensure that traceability is maintained at all stages, including during cross-docking operations.”
Clause 4.3.3: “Procedures shall be in place to ensure that all products handled, including those not stored on-site, remain under control and are not subject to contamination or substitution.”
Cross-docking operations must not compromise product traceability, safety, or integrity. Even with minimal handling and temporary presence, each product must be accurately identified, documented, and protected.
Key Compliance Objectives
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✓ Ensure personnel are properly protected to prevent product contamination
✓ Align PPE type and use with hygiene zones (e.g., low-risk vs. high-care)
✓ Standardize laundering, replacement, and storage of clothing
✓ Maintain traceable records of PPE compliance and inspections
Step-by-Step Compliance Implementation
1. Define PPE Requirements by Zone
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Considerations Include:
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• Risk classification (low-risk, high-risk, high-care)
• Product exposure level
• Personnel movement patterns
• Cleaning and sanitation protocols
Evidence to Maintain:
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• Zoning map with PPE requirements
• Risk-based clothing matrix or policy
• Signage at entry points and gowning areas
- • Risk classification (low-risk, high-risk, high-care) • Product exposure level • Personnel movement patterns • Cleaning and sanitation protocols
- • Zoning map with PPE requirements • Risk-based clothing matrix or policy • Signage at entry points and gowning areas
2. Provide and Control PPE Use
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PPE May Include:
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• Coats, aprons, coveralls
• Hairnets, snoods, beard covers
• Gloves (disposable, cut-resistant)
• Shoe covers or dedicated footwear
Control Measures:
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• Company-issued clothing only
• Color-coded or zone-specific garments
• Clear change frequency and replacement policy
Evidence to Maintain:
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• PPE issuance logs
• Staff training on proper donning/doffing
• PPE specifications and approved vendor list
- • Coats, aprons, coveralls • Hairnets, snoods, beard covers • Gloves (disposable, cut-resistant) • Shoe covers or dedicated footwear
- • Company-issued clothing only • Color-coded or zone-specific garments • Clear change frequency and replacement policy
- • PPE issuance logs • Staff training on proper donning/doffing • PPE specifications and approved vendor list
3. Manage Laundering and Storage
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Key Controls:
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• PPE cleaned by approved external laundry or validated internal system
• Separate storage for clean and soiled items
• No home laundering unless validated and documented
Evidence to Maintain:
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• Laundry contract or validation records
• PPE storage area inspection logs
• Laundry pickup and delivery records
- • PPE cleaned by approved external laundry or validated internal system • Separate storage for clean and soiled items • No home laundering unless validated and documented
- • Laundry contract or validation records • PPE storage area inspection logs • Laundry pickup and delivery records
4. Train and Monitor Compliance
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Training Topics Should Include:
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• When and how to wear protective clothing
• Hand hygiene and glove policy
• Cross-contamination prevention during PPE changes
• Use of PPE during breaks, toilet use, or zone changes
Evidence to Maintain:
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• Training logs and sign-offs
• Spot check reports and internal inspection records
• CAPA records from PPE-related non-conformances
- • When and how to wear protective clothing • Hand hygiene and glove policy • Cross-contamination prevention during PPE changes • Use of PPE during breaks, toilet use, or zone changes
- • Training logs and sign-offs • Spot check reports and internal inspection records • CAPA records from PPE-related non-conformances
Common Audit Findings & Recommended Fixes
| Audit Finding | Recommended Action |
|---|---|
| Employees not wearing PPE correctly | Retrain and conduct random compliance spot checks |
| Use of personal clothing underneath PPE | Provide guidance and enforce company-issued garments only |
| Mixed storage of clean/dirty PPE | Redesign storage areas and introduce physical separation |
| No PPE zoning map or documented policy | Develop risk-based PPE zoning charts and post in relevant areas |