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Module 6
Employee Health, Hygiene and
Hand Washing
So far in this course you have learned why pest control,
building maintenance, sanitary facilities and the type of
equipment and utensils you use are important to make
sure that the food you are processing does not get
contaminated. Now lets talk about you. Yes, you and
the people who work with you! In this module you will learn about the GMPs that relate
to employees and employee practices which can ultimately contaminate the food that you
are processing.
This Module will help you understand:
Why employees with certain types of illnesses should not work directly with
food.
How good personal hygiene can help make sure that food does not become
contaminated.
What practices are not allowed in food handling areas because they could
contaminate food.
Why proper hand washing is essential.
How and when to wash your hands or change your gloves.
There are 38 pages, 13 GMP TVs, and 6 questions in this Module. You will see many
different GMP TV examples of both good and bad practices and some fun activities.
Lets get started!

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Overview of Microbiology
To understand how employee health and hygiene can
contribute to food contamination you need to know some
basic microbiology.
Microbiology is a broad term that covers the study of
organisms that you cant see without a microscope. For our
purposes in this course, microorganism means bacteria,
yeast, mold, viruses and some parasites.
Foodborne illness takes quite a toll. More than 200 known
diseases can be transmitted by food. In the United States,
foodborne diseases have been estimated to cause 76 million
illnesses and up to 5,000 deaths each year.
The primary microorganisms that cause foodborne illness
are bacteria, viruses, and parasites. The symptoms of foodborne illness range from
nausea, headaches and cramps to more severe complications that can lead to death.
Common Mistakes That Cause Illness: Studies have shown that the two most common
causes of foodborne illness in the U.S. are:
1. holding food at the wrong temperature,
2. and poor personal hygiene of food workers
Food workers typically transmit disease causing organisms to food from their hands by:
touching contaminated surfaces and then touching food.
touching contaminated food and then touching other food.
touching a portion of their own body and then touching food.

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Microscopic Organisms and Food

Not all microorganisms are alike. Some can cause disease. These microorganisms
are called pathogens. Others only cause spoilage, which results in objectionable taste,
textures and odors in a food. Although the food will look, taste, and smell bad, these
organisms dont cause people to get sick. Some organisms are actually beneficial and are
used to make products like blue cheese (mold), bread, beer, and wine (yeast), and yogurt
(bacteria).
Types of Microorganisms

Molds: While some molds are used in food processing to manufacture food products
like specialty cheeses they can also be involved in food spoilage and even produce a
toxin called mycotoxin that is a poisonous substance that can have serious health
consequences.
Yeasts: Yeasts can also cause food spoilage problems in foods such as fruit juices, meats,
and wine but fortunately they are not associated with foodborne illness.
Bacteria: Bacteria can be divided into two groups, the spore formers and the non-spore
formers. In general the spore forming bacteria are extremely resistant to heat, cold and
chemical agents. But what is most important about bacteria is that some of them can
cause foodborne illness. These types of bacteria are called pathogens which means
disease-causing. With pathogens there is typically no obvious visual signs or odors
that would indicate the food was unsafe or bad. That is what makes them even more
dangerous.

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Some Common Microbial Pathogens

Bacteria: Some of the more common foodborne bacterial pathogens include:
Salmonella, E. coli, Shigella, Listeria, Vibrio, Campylobacter and Staphylococcus. All of
these organisms can cause illness if they are present in food. These bad bacteria or
pathogens can come into the plant on raw or processed food products or on the people
that work in the plant or from pests or other sources in the plant environment. When you
are sick, these organisms can be spread to food and other persons.
Viruses are much smaller than bacteria. Some of the common food viruses include:
Hepatitis A, Norovirus, and Rotavirus. Some diseases, like Hepatitis A, can be caused
when an infected food worker directly contaminates the food they are handling with their
hands.
Parasites can be transmitted to people by water, food, or from another person. Some
of the common food parasites are Cryptosporidium, Cyclospora, Giardia, Trichinella, and
various worms.
GMP TV: The GMP TV below shows microscopic photographs of two of the common
disease causing organisms, viruses and bacteria, that can be transmitted to people by
food. (this feature only works while online)

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How Disease Causing Organisms Are

Transmitted by Food
People can be a source of disease causing organisms. When you are sick, these organisms
can be released when you sneeze, cough, or go to the bathroom. Some people may
carry these organisms and release them into their environment without ever getting sick
themselves. Some pathogens may also be present in an open wound, cut or other sore
that is infected.
Lets review some possible routes that disease causing organisms can take from workers
to food and then cause the person who eats the food to get sick.

Food handlers carry disease organism with or without symptoms

These organisms can be transferred from people to food

From the respiratory

tract by coughing or
sneezing

From open sores.

cuts and boils

From the intestinal

tract by hands,
gloves, or clothes
soiled with feces

Contaminated food is eaten by customers

Foodborne illness occurs and customers get sick

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GMP TV
The photos in the GMP TV below show how bacteria, viruses or other disease causing
organisms from various sources can contaminate food in the plant. (this feature only
works while online)

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GMPs For Plant Personnel

Now that you have a basic understanding of microbiology and how it relates to foodborne
illness, it is easier to understand why employee health and hygiene are essential to
minimize the risk of foodborne illness.
Lets now take a look at that part of the GMP that covers the people that work in your
facility. It describes what you need to do to reduce the chance that employees could
contaminate your food products with bacteria, viruses or other microorganisms.
This section of the GMP begins with a statement directed to food facility managers.
GMP Requirement: The plant management shall take all reasonable measures
and precautions to ensure the following:
The regulation then lists all of the requirements that, at minimum, describe the controls
that a food processor would be expected to have in place in order to reduce the likelihood
that employees could contaminate food.
These requirements include employee disease control, cleanliness, hygiene, and hand
washing. We will discuss each of these requirements in this Module, starting with
employee health.

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Employee Health
GMP Requirement: Disease Control - Any person who is shown to have or
appears to have an illness, open lesion, including boils, sores or infected wounds
or any other abnormal source of microbial contamination by which there is a
reasonable possibility of food, food contact surfaces or food packaging materials becoming
contaminated shall be excluded from any operations which may be expected to
result in contamination until the condition is corrected. Personnel shall be instructed
to report such health conditions to their supervisors.
This GMP requirement contains a lot of words, but simply put it means employees must
not work with food if they are sick or have open sores.
Do Not Work With Food When You Are Sick: Employees must not work with food if
they are sick with an illness that could be transmitted to food. In a review of 81 foodborne
illness outbreaks that infected almost 15,000 people in the U.S. from 1975 to 1998, 93%
of these outbreaks involved food workers who were ill either prior to or at the time of the
outbreak.
Symptoms To Report: Employees need to know that the
illness they have could be transferred to others by handling
food that someone else will eat. Some of the more common
symptoms that must be reported to the supervisor are:
Diarrhea Vomiting
Fever

Dark urine

Jaundice (yellow color in skin or eyes)

Open or infected sores, cuts or boils
In most cases, the organisms that cause these symptoms can
easily be transmitted from employees to food from their hands, clothes and other items
that may have become contaminated.
Take Action to Reduce Risk: If employees are required to report these illnesses to a
supervisor, it will give the supervisor the opportunity to assess the situation and either
send the employee home or assign them to other work or a work area that does not
involve direct handling of food, food contact surfaces, or food packaging materials. Either
action helps to reduce the possibility of food contamination that could make someone else
sick.

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What You Can Do

The GMP regulation requires plant management to take all reasonable measures and
precautions to prevent food contamination by employees who appear to have an illness or
sores that could transmit harmful bacteria or other microorganisms to food, food contact
surfaces or packaging materials. To comply with this GMP requirement your firm needs to:
Develop company policies and procedures that describe the symptoms, illnesses,
or conditions that employees must report to their supervisor. Policies should identify
what action will be taken to prevent food contamination, such as reassigning
employees to tasks that do not involve food handling or taking sick leave. Procedures
should describe how the firm will determine that the employees condition has been
resolved and they can resume their normal work activities.
Train supervisors or managers to ensure that they understand company policies
and procedures and can recognize symptoms or signs of illness that could represent a
potential risk for food contamination.
Train employees to ensure that they understand company policies and procedures
and the symptoms or conditions that must be reported and their potential impact on
food safety.
Monitor employees and their behavior daily to ensure that employees who are ill
or who have open sores or wounds do not contaminate food.

How To Monitor
Supervisors should monitor employee health conditions daily. Although the current GMP
does not require monitoring records, you may want to keep a record of the results of
your observations for your own use. If any actions are necessary to correct problems,
these actions should also be noted on a written record. Records should also be kept to
demonstrate that all employees have been properly trained.

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Employee Hygiene
The next part of the GMP regulation describes the hygienic practices that food workers
must follow to protect the food they are handling from contamination.
GMP Requirement: Cleanliness. All persons working in direct contact with food,
food-contact surfaces, and food-packaging materials shall conform to hygienic
practices while on duty to the extent necessary to protect against contamination of food.
As you can see, this GMP requirement states that food, food contact surfaces, and food
packaging material must be protected from contamination by workers. It then goes on to
outline nine specific hygienic requirements for food workers.
Hygiene Requirements for Food Workers
1. Wearing suitable garments.
2. Maintaining adequate personal cleanliness.
3. Protecting food from jewelry or foreign objects.
4. Wearing proper hair covering or restraints.
5. Proper storage of clothing and personal items.
6. Confining eating, drinking, and smoking to appropriate areas.
7. Preventing contamination from perspiration, cosmetics, tobacco, and chemicals
or medicine applied to the skin.
8. Washing hands properly at the proper times.
9. Sanitizing hands and using gloves appropriately.
We will review each of these requirements starting with employee garments.

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Outer Garments
GMP Requirement: All persons shall wear outer garments suitable to the
operation in a manner that protects against the contamination of food, food-contact
surfaces or food-packaging materials.
Bacterial pathogens and viruses exist everywhere in our environment. This includes your
street clothes, shoes, and hands. So it makes sense that you would not want to wear
these clothes or shoes into processing areas where you might contaminate the food you
are handling. It may be necessary to change clothes or put on protective outer garments
such as aprons, coats, uniforms, smocks, or boots to prevent food contamination.
GMP TV: Click on the pictures in the GMP TV below for some examples of how some food
processors have or have not complied with this part of the GMP regulation: (this feature
only works while online)

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Personal Cleanliness
GMP Requirement: Workers shall maintain adequate personal cleanliness.
The human body itself can be a source of microbial contamination if it is not kept clean.
People who do not bathe can smell bad. This is because body odor is often caused by
bacterial growth.
Skin Can Harbor Bacteria: The average adult has a skin area of about 19 to 20 square
feet. From healthy skin, approximately 10 million particles are released into the air each
day, and 10% of these skin particles contain living bacteria. The chemical composition
and moisture of skin varies and dictates what type of bacteria will grow on it and how
much.
The surface of skin (epidermis) is not a favorable place for microbial growth because it
is often dry, salty, and acidic. Most microorganisms are located in sweat glands and hair
follicles because of the moist and nutritious environment in those places.

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Jewelry and Personal Items

So far we have covered two areas of personal hygiene including cleanliness of outer
garments that come in contact with food and personal cleanliness. The next part of the
GMP outlines hygienic requirements for jewelry, hair coverings, storage of personal items,
and employee practices. Lets take a brief look at each one starting with jewelry.
GMP Requirement: Remove all unsecured jewelry and other objects that might
fall into food, equipment or containers, and remove hand jewelry that cannot
be adequately sanitized during periods in which food is manipulated by hand. If such
hand jewelry cannot be removed, it may be covered by material which can be
maintained in an intact clean and sanitary condition that protects these objects from
contaminating food, food contact surfaces, or food packaging materials.
Food Hazards: Jewelry, like rings and earrings, or even artificial nails, can be a source
of food contamination. If any of these items fall into the food it can become a physical
hazard - and the person who might bite into the article can get hurt (and probably would
feel disgusted). Items like jewelry or artificial nails provide an excellent place for food
residues to collect and pathogens to grow because
they interfere with proper hand washing and
sanitizing.
Prevention Options: In order to comply with this
portion of the GMP you have two choices:
The best solution is to have employees remove all
unsecured jewelry or other objects that could fall
into or otherwise contaminate food, or
If the jewelry or other objects cannot be removed,
the other option is to cover the jewelry with gloves
or other material that can be kept intact, clean,
and sanitary to protect food from contamination.

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Hair Restraint
GMP Requirement: Wear hair nets, headbands, caps, beard covering or other
effective hair restraints when appropriate and in an effective manner.
Hair and Hair Covering: To comply with this portion of the GMP, employees working in
food processing areas must wear hair covering or restraints. This is because hair is filthy
and can contribute to contamination as well as the fact that no one wants your hair in
their food! The type of hair covering that you would need to comply
with this portion of the regulation can vary depending on where you are
working.
Examples: Employees in loading docks or warehouses where there is
no exposed food may not need hair coverings. Typically these workers
wear baseball-type caps which is fine, but they should not be the same
ones that are worn at home. In contrast, workers in areas where food
is exposed must wear hair coverings that completely cover their hair,
including beards and moustaches.
GMP TV: Click on the photos in the GMP TV below to see both
acceptable and unacceptable hair covering practices. (this feature only
works while online)

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Personal Belongings
GMP Requirement: Clothing or other personal belongings should not be kept in
areas where food is exposed or where equipment or utensils are washed.
So far in our discussion of hygienic practices we have covered outer garments, personal
cleanliness, jewelry, and hair coverings. The next three topics under hygienic practices
deal with what you do with your clothing, personal items, where you eat, smoke and drink
and finally what you wear on your skin - all of which can contribute to food contamination
if they are not managed properly.
Clothing and Personal Items: Coats, shoes, and other clothing or personal items should
never be stored in areas where food is being processed or stored. This is because your
personal items cannot be cleaned and sanitized and could potentially contaminate food,
food contact surfaces, or food packaging material. Ideally your personal items will be
stored in a locker room or at least an area that is dedicated to storing your items and is
separate from food processing areas.
GMP TV: Click on the photos in the GMP TV below to see examples of items that should
not be in areas where exposed food is handled or stored. (this feature only works while
online)

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Activities That Involve Hand To

Mouth Contact
GMP Requirement: Eating food, chewing gum, drinking beverages, or using tobacco
is not allowed in any areas where food may be exposed or where equipment or utensils are
washed.
This section of the GMP regulation requires that any worker activity that involves hand-tomouth contact never be allowed in areas where food is handled.
Restricted Activities: Activities in which the hands touch the mouth can lead to the transfer
of harmful microorganisms from the mouth or face to the hands, which could then contaminate
food, food contact surfaces, or food packaging material. Items like food, gum, or tobacco
products could also fall into food and contaminate it. For this reason, the following activities
should be restricted to non-work areas such as break or lunch rooms, locker rooms or
designated areas where no food is handled.
Eating any kind of food or snack.
Chewing gum.
Drinking any kind of beverage in a container other than from a water fountain.
Smoking cigarettes or cigars or chewing tobacco products.
Posting Signs: State and local health authorities may have requirements related to the posting
of signs that remind workers that they cannot smoke, drink or eat in food handling areas. Even
if these signs are not required, they can be an effective way to remind workers that these
activities are not allowed in specific areas.
GMP TV: Click on the photos in the GMP TV below to see examples of unacceptable and
acceptable practices related to the GMP requirement that prohibits eating, chewing gum or
tobacco, drinking and smoking in food handling areas. (this feature only works while online)

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Personal Care Products

GMP Requirement: Take any necessary precautions to protect food, food contact
surfaces or food packaging materials from contamination with microorganisms or
foreign substances including but not limited to perspiration, hair, cosmetics, tobacco,
chemicals and medicines applied to the skin.
This part of the GMP regulation is included to make sure that other things related to
worker hygiene and behavior do not become a source of contamination for
food.
Body Hair and Sweat: You learned earlier that microorganisms are likely
to live in the areas of the skin near hair follicles or sweat glands. Body hair
from arms and perspiration or sweat can be a source of contamination if
it falls onto food or food contact surfaces. Individuals with excessive body
hair may need to wear protective sleeves or other covering to prevent food
contamination. Steps must also be taken to keep workers from dripping
sweat onto food or food contact surfaces. The temperature of the air in food
handling areas should be adjusted to keep workers from sweating. Some
individuals who may have a problem with excessive sweating may need to
wear protection or be re-assigned to another job where they do not work in
areas where exposed food is handled.
Skin Products: Many different personal care products such as cosmetics,
hand lotions or creams, ointments and other products available to the
general public could have the potential to contaminate food. Workers should
be aware of this potential and receive guidance on what products are not
acceptable. Workers should also be aware that skin medicines, salves,
and ointments can also be a potential source of contamination. This is one
reason why the GMP requirement described earlier does not allow workers
with cuts, sores or boils to handle food. If workers use salves or other
skin medicine they should be required to wear gloves and another outer
garment or disposable sleeves to cover their arms. Other chemicals or
medicines should also not be used in food handling areas where they could
unintentionally contaminate the food that is being handled.

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What You Can Do

To meet GMP requirements for employee cleanliness and hygiene your company needs to:
Develop company policies and procedures for:
1. The garments or other body coverings and shoes that will be worn in areas
where food is handled, stored or processed including aprons, sleeve protectors and
shoes that will be provided by the company. How workers should use lockers or
other facilities away from food handling areas to store street clothes, coats, shoes
or other items. Which items are to be laundered or maintained by the company,
and what employees are required to do.
2. The hair and beard or moustache restraints that are required for workers in
each area of the plant and what employees need to do to meet this requirement.
3. Company standards for personal cleanliness, wearing jewelry, and the use
of cosmetics, skin care products or medicines.
4. Company policies that prohibit eating, drinking or smoking in any food
handling, storage or processing area. If necessary, specific instructions should be
provided to employees describing where these activities can take place if they are
allowed during break or other periods away from work areas.
5. Company restrictions for personal items that can be brought into work areas.
Train all employees to ensure that they understand all company policies related
to cleanliness, personal hygiene, attire, and personal activities. Most firms provide
employees with a handbook to make sure that they understand what is expected
of them. Training programs can be used to further explain the handbook and help
employees understand why these policies and procedures are necessary.
Monitor employees routinely during the day to make sure that they meet
requirements for cleanliness, hygiene, attire, and proper practices.

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How To Monitor
Supervisors should observe all employees at the beginning of the shift and
periodically throughout the day as necessary to make sure that they are:
clean, and practicing good hygiene,
wearing appropriate outer garments,
not wearing jewelry or other prohibited items,
wearing appropriate hair and beard restraints,
have not brought personal items into work areas,
not smoking, eating, or drinking in work areas, and
not using personal care products that could contaminate food.
If problems are observed, employees should be required to correct their attire or
behavior before they start to work. Supervisors should be trained to make sure that they
understand what is acceptable and how to work with employees to correct problems.
It may be useful to develop a simple check list that covers all of the personal hygiene
requirements that should be monitored on a daily basis. Although the current GMP does
not require monitoring records, you may want to keep a record of the results of your
observations for your own use. Records should also be kept of employee training for
both supervisors and for other employees to demonstrate that have been informed about
company policies and understand them.

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Proper Hand Washing

Now that you understand what personal hygiene practices need to be followed by food
workers, lets look at the GMP requirement for proper hand washing.
GMP Requirement: All persons working in direct contact with food, food-contact
surfaces, or food-packaging material must wash their hands thoroughly (and
sanitize if necessary to protect against contamination with undesirable microorganisms) in
an adequate hand-washing facility before starting work, after each absence from the
work station, and at any other time when the hands may have become soiled or
contaminated.
There are three parts to proper hand washing in this GMP, how to wash your hands,
when to wash your hands and where to wash your hands. We will discuss each of these,
including why hand washing is so important on the following pages.

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Why Hand Washing is Important

Handwashing is one of the most important things you can do to reduce the likelihood of
contaminating food. This is because microorganisms are commonly transferred to food by
workers hands.

Hand Washing Behavior: Many different studies have shown that when it comes to
washing hands, what people say they do can be very different from their actual behavior.
In one study of hand washing behavior done for the American Society for Microbiology,
more than 9 in 10 people said that they wash their hands after using a public restroom,
but only two thirds of them actually did wash their hands after using the bathroom. The
study also found that women were more likely to wash their hands after using the toilet
facility than men.
High Risk Behavior: These findings are especially important if food workers behave like
the rest of the general public. If a food worker does not wash their hands after using the
bathroom or after they touch something that is dirty and then touch food, they increase
the risk of contaminating the food and even causing the person who eats the food to get
sick.

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How To Wash Your Hands

The GMP regulation doesnt just say that you need to wash your hands, it says that you
need to wash your hands properly. The skin on your hands has many cracks, wrinkles,
crevices, and hardened areas that can harbor dirt and bacteria as well as the areas around
and underneath the fingernails.
Hand Washing Procedure: Although hand washing seems to be a simple and easy task,
most people do not know how to wash their hands properly. Lets look at the steps you
should take to wash your hands properly. (this feature only works while online)

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How To Wash Your Hands

Hand Washing Tips: Thoroughly scrubbing all areas of your hands for enough time with
soap is the most effective way to loosen any dirt, oils, and microorganisms that might
be on your hands, which will then be washed away by rinsing your hands under warm,
flowing water. Studies have shown that the fingertips and the areas around and under
your fingernails can be the most difficult part of the hand to clean. That is why all food
workers should keep their fingernails trimmed and short. Hand washing cannot be relied
on to remove bacteria from infections, wounds or sores. That is also why anyone with cuts
or sores must either wear gloves or not work in areas where food is handled.
Hand Washing Video: Because proper handwashing is so important, lets review the
right way to do it. (this feature only works while online)

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When To Wash Your Hands

Its just as important to know when to wash your hands as it is to know how and where
to wash them. The GMP requires that food workers wash their hands at any time when
their hands may have become dirty or contaminated. At a minimum you need to wash
your hands before starting work, after going to the bathroom, and any time you leave
your work station.
Click on the start button below to see WHEN you need to wash your hands. (this feature
only works while online)

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Where to Wash Your Hands

Now that you know how and when to wash your hands, lets discuss where to wash your
hands. The GMP says that you have to have an adequate facility to wash them. What does
this mean?
Hand Wash Stations: Food workers should wash their hands in sinks or hand wash
stations that are only used for this purpose - not in a sink that might be used to wash
equipment or food. These dedicated hand wash facilities must be located either in the
restroom or outside the restroom and in any area where food is handled. It is important
that these hand wash facilities be located in an area that is convenient for workers to use.
If it is difficult for workers to get to hand wash sinks or stations they are not likely to use
them.
Equipment: There are many different types of hand washing facilities that can be used.
Although they may be designed differently, it is essential that all hand wash facilities
provide the following things:

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Hand Washing Facilities

GMP TV: Click on the photos in the GMP TV below to see some examples of various
types of hand wash stations that could be used in a food facility, and both good and bad
practices. (this feature only works while online)

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What You Can Do

Anyone who works in food plant will need to wash their hands many times each day. To
meet the hand washing requirements of the GMP you need to:
Evaluate the location of washing facilities or stations to ensure that it is
convenient for employees to wash their hands at all times when it is necessary.
Develop company policies that describe when, where and how all employees must
wash their hands throughout the workday.
Train all employees to make sure that they understand why hand washing is
important and when, where and how to wash their hands properly.
Monitor hand wash stations daily to make sure that they are working and are
properly equipped with hot and cold running water, soap, and disposable towels.
Monitor employee hand washing practices routinely to make sure that all
employees follow company policies on how and when hands must be washed.

How To Monitor
Supervisors should monitor employee hand washing practices daily to ensure that
expected practices are followed. Hand wash facilities should also be monitored daily
to be sure that they are operating properly and have the proper supplies including
soap, disposable towels, and other items that are needed. Although the current GMP
does not require monitoring records, you may want to keep a record of the results of
your observations for your own use. If any actions are necessary to correct problems,
these actions should also be noted on a written record. Records should also be kept to
demonstrate that all employees have been properly trained.

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Using Gloves
GMP Requirement: Maintain gloves, if they are used in food handling, in an intact, clean
and sanitary condition. Gloves should be of an impermeable material.
Follow Local Regulations: For some tasks, such as the handling
of foods that will not be cooked before they are eaten, workers
may need to wear gloves to protect food from contamination. In
fact, some states and many local regulatory agencies do not allow
any direct hand contact with food. These authorities believe that
wearing gloves provides an extra barrier to protect food from
potential fecal contamination from workers who have not properly
washed their hands. But remember, even if you wear gloves
you will still need to wash your hands before putting on your
gloves! If you dont, you will contaminate the gloves.
Gloves and Hand Washing: Workers who wear gloves must
still wash their hands properly at the proper time and place as we
discussed earlier. Gloves can be as easily contaminated as bare
hands, and workers should follow the procedures described earlier in when to wash.
Workers should change their gloves after all of the activities described earlier for hand
washing. For example, if a worker wearing gloves coughs or sneezes, they should wash
their hands and change their gloves. If a worker leaves the work station to go on break,
they should throw their gloves away when they leave and wash their hands and put on a
new pair of gloves before they start handling food again.

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Gloves
Types of Gloves: The GMP also requires that gloves
be impermeable. This means that water, oils or
other materials in the food must not be able to be
absorbed by or pass through the glove. Two general
types of gloves, vinyl and latex, can provide an
effective barrier. Since some people may have or
develop an allergy to latex gloves, most firms use
some type of vinyl or plastic gloves. Cloth gloves are
not impermeable, and therefore are not acceptable
when handling food products.
Glove Durability: You should also consider how
strong the gloves need to be for the work that is
being done. Inexpensive gloves can be very thin, not
fit well, and tear or puncture easily. You may need to
evaluate several different types of gloves to find ones that are suited and durable enough
for the job, but not so expensive that workers would be discouraged to change and throw
them away as often as necessary.
Sanitizing Gloves: Gloves (or hands for that matter) should be washed and sanitized
if the food you are working with will not be cooked by the consumer before it is eaten.
Food plants typically set up hand dips with a sanitizer solution so that after hand
washing, employees can dip their hands, or gloves. These hand dips should contain a
sanitizing solution whose strength is equivalent to 100 ppm (parts per million) of chlorine
or 12.5 to 25 ppm iodine or other suitable hand sanitizer. Its important to keep in mind
that these hand dip solutions will lose their effectiveness if gloves or hands are dirty. Hand
dips must also be consistently checked and maintained throughout the work day to be
sure that the proper sanitizer strength is maintained. Remember that hand-dips never
take the place of hand washing.

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Gloves
GMP TV: Click on the photos in the GMP TV below to review information on the proper
use of gloves and hand sanitizer dips. (this feature only works while online)

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What You Can Do

To meet the GMP requirement that gloves be maintained in an intact, clean and sanitary
condition and should be made of impermeable material you need to:
Determine if there are any state or local regulations related to the use of gloves
when handling food, and adjust procedures or policies as necessary to meet these
requirements.
Evaluate the type of gloves that are used to make sure that they are
impermeable, durable for their intended use, can be cleaned and sanitized, and do
not create employee skin allergy or other problems.
Evaluate company procedures or policies that describe when and where
employees will wear gloves and hand washing and sanitizing procedures that must
be followed before and after employees put on their gloves. Make and implement any
changes that are necessary.
Monitor employees daily to make sure that they are using gloves properly and
following hand washing and glove sanitizing procedures.
Monitor glove sanitizing solutions daily to make sure that the proper sanitizer
concentration is used.

How To Monitor
Supervisors should monitor employees daily to ensure that expected glove use and
practices are followed. Hand sanitizing stations or dips should also be monitored daily
to be sure that they are clean and have the proper sanitizer concentration. Although the
current GMP does not require monitoring records, you may want to keep a record of the
results of your observations for your own use. If any actions are necessary to correct
problems, these actions should also be noted on a written record. Records should also be
kept to demonstrate that all employees have been properly trained.

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Education and Training

Throughout this Module, we have emphasized the need for employee training to make
sure that employees understand what they need to do in terms of personal hygiene and
hand washing to make sure that they do not contaminate food, food contact surfaces,
or food packaging material. Recognizing the importance of training, this section of the
GMP includes a requirement that specifically addresses employee education and training.
There are two parts in this section of the GMP. Lets look at the education requirement for
supervisory personnel first.
GMP Requirement: Personnel responsible for identifying sanitation failures or
food contamination should have a background of education or experience, or a
combination thereof, to provide a level of competency necessary for production of clean
and safe food.
Supervisor Skills: This GMP requirement says that managers and/
or supervisors who are responsible for monitoring food production
and sanitation, and for correcting problems need to have appropriate
training or experience. It just makes sense that every company should
have people who understand food safety to take on the responsibility
of making sure that everything that is needed to produce safe food
under sanitary conditions is done each day. These same people should
be the ones to make the decisions necessary to solve or correct
problems when they occur and to determine if food safety has been
compromised.
Training Programs: There are many different types of education,
training, and experience that might be appropriate for different
situations. Formal education in food science or in culinary or food
service courses could provide adequate food safety knowledge. Other
training programs, such as this Internet course, may provide the
knowledge that supervisors need to help your firm comply with the
GMPs. There are a variety of other programs that provide training via
the Internet, workshops, continuing education courses, or other training
experiences.
Work Experience: The GMP also recognizes that on-the-job experience can provide
many of the skills necessary to make sure that individuals can adequately supervise
employees and make sure that your company can produce clean and safe food products.

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Supervision
GMP Requirement: Responsibility for assuring compliance by all personnel with
the requirements of this part (of the GMP regulation) shall be clearly assigned to
supervisory personnel.
The last requirement in this section of the GMP recognizes the need for supervision to
make sure that all employees follow the personal hygiene and hand washing practices
reviewed in this Module.
Monitoring Employees: Earlier we discussed the fact that employees dont always do
what they know they should do, or say that they do. It is up to supervisors to continually
monitor employee practices to make sure that food is not contaminated. Remember
it only takes a single incident, in which an employee is sick with an illness that can be
transmitted by food or if an employee doesnt wash their hands properly, to produce
contaminated food.
Supervisory Responsibilities: Each company must clearly define who is responsible
for supervising and monitoring employees personal hygiene and hand washing behavior
and practices. For example, in a small operation a single person may be responsible
for supervising employees behavior and practices. In a larger company, many different
individuals may have this responsibility for the employees associated with certain areas
of the plant or production activities. These supervisors should also be responsible for the
monitoring and record keeping activities described earlier in each section of this Module
such as the daily employee hygiene checklist.

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Basic Employee Training

GMP Requirement: Food handlers and supervisors should receive appropriate
training in proper food handling techniques and food protection principles
and should be informed of the danger of poor personal hygiene and insanitary
practices.
The second part of this GMP requirement relates to the basic food handling, personal
hygiene, and sanitary practices that are necessary to produce safe and clean food. This
GMP basically says that all employees who handle food should receive training on the
basic practices that we have covered in this Module.
Training Programs: Employee training can be conducted in many different ways, and
many different training tools have been developed. It is important that you select or
develop a training program that will be understood by your employees. You may need to
consider language, culture, learning skills, and other factors to be sure that employees
understand the practices that they are required to follow. There are also many different
approaches to training that can include written materials, visual aides such as videos,
CDs, posters or even on-site demonstrations.
Employee Handbook: Many firms develop a handbook that describes acceptable
behavior and practices that employees are required to read and understand. This basic
entry-level training should be followed with additional periodic training sessions conducted
by plant managers or supervisors that use the materials described above. Training
programs for employees that describe the practices covered in this and other Modules that
can be delivered in the plant are available upon completion of this Internet course and will
be described in Module 12.

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What You Can Do

To meet the GMP requirements for proper supervision and training of employees you need
to:
Identify what training, experience, or other qualifications are needed
for supervisors or managers who will be responsible for food safety and basic
employee training.
Provide any additional training opportunities for managers and supervisors to
ensure that they have all necessary skills.
Develop company policies or written materials that describe how employees will
be informed about proper personal hygiene, illnesses, acceptable work practices and
hand washing.
Develop and conduct entry-level employee training activities. For example
an employee handbook can be developed that describes all company policies and
expected practices or behavior. Employees can be required to read the handbook and
acknowledge that they have read and understood its contents.
Conduct supplemental employee training programs to make sure that
employees understand all hygiene requirements and why they are important. It may
be necessary to develop and deliver employee training programs on various topics
and conduct on-the-job training activities to correct problems and ensure that proper
practices are followed.
Assign responsibility to specific supervisory employees for making sure that all
employees meet the GMP requirements for employee health, hygiene, hand washing,
and use of gloves each day.
Monitor and keep records of all employee training activities.
Monitor the activities of assigned supervisors to make sure that they are
ensuring that all employees comply with GMP requirements for employee health,
hygiene, hand washing and the use of gloves.

How To Monitor
Supervisors should be assigned to monitor employee behavior and practices on a daily
basis to make sure that they meet the employee health, hygiene, hand washing and glove
use requirements of the GMP. Although the current GMP does not require monitoring
records, you may want to require supervisors to keep track of the observations and any
corrections that are made for your own use. Records of employee qualifications and
training programs should be kept to demonstrate that the requirements of this section of
the GMP have been met.

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Review Exercise
This completes our review of the sections of the GMP that focus on employee health,
hygiene and hand washing.
To help review what you have learned, we would like you to look at the photograph
below and see if you can find the 4 different ways that these workers meet the personal
requirements of the GMP that we have covered in this Module. You will need to use your
computers mouse to move the cursor over a part of the picture you think is acceptable
and click the left button on your mouse. A member of our Clean Team will tell you why
the part of the photo you selected complies with the GMP regulation.
GMP TV: Use your mouse to find the acceptable activities or behavior in this picture. (this
feature only works while online)

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Checklist Questions for GMP Requirements in

Module 6
In Module 6 we reviewed the GMP requirements for making sure that employees: do not
have an illness that can be transmitted to food; wear the proper garments, foot wear, and
hair covering; comply with good personal hygiene practices; wash their hands properly at
the proper times; use gloves properly; and are properly supervised and receive the proper
training. We have compiled the items from the What You Can Do sections of this Module
into a simplified series of questions to help you create a list of things that you may need
to do to meet these GMP requirements.
Use this list to remind yourself to:
Evaluate the status or condition of your existing facilities or systems, and to develop a
plan to make any changes that are needed.
Create new procedures or change existing procedures if necessary.
Develop new monitoring procedures or change your existing procedures.
To download the Checklist below as a PDF file that you can print, click on the button.
Download Module 6 Checklist and Internet Resources

Employee Health
Do you have company policies and procedures that describe the symptoms, illnesses,
or conditions that employees must report to their supervisor? Do you need to develop
new policies or procedures or modify existing ones?
Do you have an employee handbook and/or conduct training for employees and
supervisors that explain company policies and procedures for employees who
may have an illness that could be transmitted to food? Do you need to develop a
handbook or training programs or modify existing ones?
Do you have procedures for routinely monitoring employees and their behavior to
detect symptoms of illness? Do you need to develop new monitoring procedures or
modify existing ones?

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Employee Cleanliness and Hygiene

Do you have policies and procedures that describe company requirements for:
Garments, body covering and shoes or boots?
Hair and beard or moustache covering or restraints?
Personal cleanliness?
Use of jewelry, cosmetics, skin care products and medicines?
Prohibited activities such as eating, smoking, and drinking?
Personal item restrictions in work areas?
Do you have an employee handbook and/or conduct training programs to explain
these policies and procedures to employees? Do you need to develop new training
materials or modify existing ones?
Do you have procedures for routinely monitoring employees attire, cleanliness and
hygiene? Do you need to develop new monitoring procedures or modify existing
ones?

Hand Washing
Do you have the proper hand washing facilities or stations in all of the proper
locations where they are needed? Make a list of repairs or installations that are
needed.
Do you have a procedure to routinely monitor all hand washing stations to make sure
that they are properly equipped with hot water, soap, and disposable towels? Do you
need to develop new monitoring procedures or modify existing ones?
Do you have a company procedure that describes how, when, and where employees
must wash their hands or use gloves? Do you need to develop these procedures or
modify existing ones?
Do you conduct training to make sure that employees understand how, when and
where they must wash their hands? Do you need to develop new training programs,
modify existing ones, or conduct them more frequently?
Do you have a procedure to routinely monitor employees to make sure that they are
washing their hands properly at the proper time or using gloves properly? Do you
need to develop new monitoring procedures or modify existing ones?

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Training and Supervision

Do the people responsible for identifying sanitation failures and problems related
to employee practices and behavior have the training and/or experience that is
necessary? What additional training is needed and can be provided?
Has responsibility been clearly assigned to one or more individuals for making sure
that all employees comply with all hygiene and hand washing requirements? Do
these people have the necessary training or skills? If not, what additional training is
needed?