If an operation is field/orchard/vineyard packing, should they use Form C or Form D to train employees?
The operation should be using Form C – Employee Personal Hygiene and Food Handling Practices Policy – Production Site.
No, latex gloves are not allowed (due to allergens). Forms C and D describe the types of gloves that may be used depending on if they are used in the production site, packinghouse, harvested product storage or market product storage.
If employees are ill, they can transfer pathogenic organisms to the products they are handling. This mainly occurs due to poor personal hygiene and employees’ hands cross contaminating product and potentially passing on the illness to the person consuming the product. Some of these illnesses that employees can transfer to food include Hepatitis A, Salmonella, E. coli O157:H7, Norovirus, Shigella spp, etc.
Can employees carry drinking water with them while working in the production site (e.g., field, orchard, etc.)?
No, according to the CanadaGAP Food Safety Manuals it is not acceptable for employees to carry drinking water with them into the production site when they are working because of the potential for cross-contamination (e.g., mouth to hands to product).
This requirement is outlined in Form C (Employee Personal Hygiene and Food Handling Practices Policy – Production Site) of the CanadaGAP manual. Employees need to wash their hands each time after having a drink of water.
If an operation would like to allow employees to carry drinking water, they must first mitigate the food safety risks associated with this practice. Within the CanadaGAP program allowances can be made for operations to do something different from what is laid out in the manual. These are called deviations. This process is explained in “How to Complete the Manual” under the important note where it states:
The requirements along with their procedures were determined based on food safety risks that may be present in an operation. If the hazards are not controlled, there is potential for contamination of the product. To mitigate the risks the procedures need to be followed. However, deviations from these procedures are possible and may be acceptable in completing the requirement. There may be a variety of ways to meet the requirements and still mitigate risk. An operation may choose to implement different procedures than those contained in the manual and these may be acceptable to satisfy program requirements. A risk assessment would need to be completed (see Appendix U: Introduction on How to Assess Risk – with examples). Procedures would need to be carefully developed to ensure the hazards are controlled, and thoroughly documented to ensure the procedures are followed consistently. If this approach is taken the effectiveness of those procedures will have to be assessed during an audit. It will be up to the certification body to determine if procedures different from those provided in the manuals are acceptable or not.
Therefore, the operation would have to implement different procedures to mitigate the food safety risk. For this scenario, the operation would have to have procedures in place to mitigate the potential for cross-contamination from mouth to hands to product. There may be various ways to mitigate the risk. An example could be a procedure where the operation allows only water bottles that have a non-removable lid and contact from hands is not required to open and close the bottle (see examples below). This procedure would need to be clearly documented and employees trained accordingly. It would be up to the certification body to determine if this deviation was acceptable.
|Water bottles that would NOT be acceptable||Water bottles that COULD be acceptable with written procedures on how to appropriately use the water bottle.
NOTE: employees need to be trained on the proper procedures to ensure that hand to mouth contamination does not occur (for example, Gatorade bottle needs to be opened with mouth/teeth, purple bottle needs to always be ‘popped’ open, etc.).
Yes, apron and smock can be used interchangeably.
“Working effects’ are defined in the CanadaGAP Food Safety Manuals as “Items that have been provided to the employees to minimize contamination to product (e.g., aprons, booties, gloves, smocks, etc.)”. Working effects are covered on both Form C Employee Personal Hygiene and Food Handling Practices Policy – Production Site and Form D Employee Personal Hygiene and Food Handling Practices Policy – Packinghouse/Product Storage of the manuals. Only aprons are referred to on the forms. However, although they are two different words, aprons and smocks can be used interchangeably and smocks would be held to the same requirements.
- are worn when employees hold product against their body (e.g., to trim product)
- are made of rubber
- if reusable are washed daily by the operation