Quality People,
Quality Products
5710 County Road H
Auburndale, WI 54412
JANUARY - GMP Study Guide for Employee Practices
Product Tampering
It is the responsibility of all employees to assure that our food products are safe for our customers. Any intentional act by an employee which could render an ingredient, product or package unsafe for consumers will result in termination. Legal actions will be pursued, including but not limited to criminal prosecution.
Employees who observe any intentional act which might compromise the safety of any ingredient, product or package are required to immediately report this activity to their department head or management.
Cross Contamination
Cross contamination occurs when harmful bacteria or allergens spread to food from: other food, surfaces, hands or equipment. The following are the steps and process we have in place to prevent contamination from happening.
Personal Hygiene
Employees must maintain a high degree of personal cleanliness.
Prohibited Acts
To help prevent product contamination the following actions are NOT allowed in the facility:
1. Eating and/or drinking outside of designated break areas or drinking further than 5 feet from the water bubbler.
2. Eating or taste testing product without authorization from quality assurance.
3. Chewing gum, candies, throat candies and tobacco.
4. Holding toothpicks, matchsticks or other objects in the mouth.
5. Placing pens or cigarettes behind the ears.
6. Wearing false eyelashes or fingernails.
7. Carrying objects above the belt or waistline.
8. Spitting inside the facility, this includes the outdoor patio.
9. Carrying pills or medication (cough drops) in clothing pockets (exceptions require authorization and approval from the Quality Assurance Department).
10. Smoking inside the facility.
11. Wearing perfume, cologne or body spray.
12. Buttons, service pins or similar articles on uniforms, smocks, or hard hats.
Visitor/Contractor Identification
Visitors will wear grey lab coats. Anyone who in not employed or leased by the facility is considered a visitor. Contractors will wear blue coats. Any non-employee who provides services is a contractor. All visitors must comply with company and site specific GMP rules.
Jewelry
Rings, watches, earrings, body piercings, necklaces, or other jewelry MUST NOT be worn in GMP areas unless they cannot be removed. If they cannot be removed, they must be covered, so they cannot fall off. Tongue piercings are NEVER allowed.
Traffic Patterns
Employees must follow established traffic patterns and controls to prevent microbial cross contamination within the facility.
Housekeeping
Littering and other poor housekeeping practices are not allowed. All refuse must be placed in properly identified containers.
Lunch Storage
Lunches must be stored in the employee break areas. Lunches must be completely enclosed in cleanable/reusable containers, or in single use packaging. Employees will not disturb or consume any other employees’ lunch.
Lockers
Storage facilities of sufficient size to accommodate all reasonable personal items are provided to employees. Personal lockers must be maintained free of trash and soiled clothing. Shoes and boots shall be stored on designated shoe and boot racks.
Items not allowed in employee lockers include:
1. Shoes and boots
2. Gloves and aprons for production use
3. Empty/full lunch bags or coffee cups
4. Any uniforms
5. Food, beverages and tools
FEBRUARY - GMP Study Guide for Clothing & Personal Equipment
Laundry & Approved Clothing
Washable food industry towels will be laundered and maintained by WCI.
Personnel, contractors and visitors who work in or enter areas where products, ingredients or primary packaging are exposed must wear appropriate clothing that is clean and in good condition.
Work wear is provided, laundered and maintained by WCI. Employees will not launder their own uniforms.
Employees who work in the facility will wear only company-approved clothing. Full time employees will wear company provided shirts and pants along with work dedicated footwear. Management and office personnel may wear a lab coat in lieu of a company issued uniform. Introductory and part-time employees will wear a company-issued white shirt and scrub pants along with dedicated footwear. If an undershirt is worn, it must not have any hoods, buttons or pockets.
If the undershirt is long sleeved or past the employees elbow, disposable sleeve protectors must be worn when in contact with product or product contact surfaces. It is acceptable for an employee to roll up their sleeves and not wear sleeve protectors. Sleeves are intended for a single days’ use, if stored in a sanitary manner when leaving the work station. Sleeves must be replaced if they become soiled or contaminated.
Clothing shall provide adequate coverage to ensure that hair, perspiration or other foreign materials do not contaminate the product.
All clothing must be free of potentially offensive markings.
Pockets above the waist must be removed or sewn shut.
Only zippers, Velcro or snaps may be used as the fasteners on shirts, coats, laboratory jackets or smocks.
Changing Facilities
Changing facilities are provided for all personnel, whether staff, visitor or contractor. These areas are sited to allow access to the production, packaging or storage areas.
MARCH - GMP Study Guide for Clothing in Process Areas
Disposable Clothing
In operations where clothing is rapidly soiled, and/or there is direct exposure to open product, disposable clothing (gloves, plastic aprons, arm guards, lab coats, etc.) must be worn and changed at a frequency to prevent product contamination.
When working in the Raw Area, if risk of cross contamination occurs, employees are required to wear a red smock or apron.
Clothing for Specific Process Areas/ Changing Facilities
1. Clothing used in food handling must not be used for any other purpose.
2. Employees will change into and out of work clothing inside the facility in designated changing areas.
3. All clothing must be kept in good repair. Damaged garments need to be tagged for repair.
4. Clothing must be clean at the beginning of the shift and kept reasonably clean during operations.
5. Work-wear dedicated to specific product areas (raw areas, etc.) must be restricted to those areas.
6. When not in use, work-wear clothing must be stored in a sanitary manner (on hooks or hangers).
7. All production, retail, ingredient and food service employees will change out of work uniforms before exiting the facility. Uniforms are allowed on the outdoor patio.
8. Employee clothing shall not be a source of contamination.
9. No hairnets, aprons, or lab coats can be worn outside. Hairnets are allowed on the outside patio.
10. Aprons must be hung up on appropriate hooks in appropriate locations when not in use.
11. Sleeve protectors must not be worn in the break room or outside.
12. Employees in contact with product or product contact surfaces will wear food grade gloves, unless the potential for glove breakage is a risk for causing extraneous matter.
13. Employees working in or entering the Blue Retail or Separator Room for longer than 10 minutes will wear appropriate hearing protection.
14. Safety glasses shall be worn in GMP areas of the facility.
Shoe Types
To help avoid product contamination and for personal safety shoes worn in the facility should be designed and constructed as follows:
1. Fully enclosed – NO open toes, open backs, open weave or sandals.
2. Low heeled.
3. Sole groove depth must not be a source of contamination.
4. Overall construction should be sturdy enough to provide protection.
5. Shoes worn in wet areas should not allow passage of water into or out of the base of the shoe (shoes should not absorb or trap water when walking through footbaths or foamers).
6. Captive footwear shall not be worn outside the plant but may be worn on the outdoor patio. (Yellow shoes laces cannot go outside the facility. Blue shoe laces can be worn outside the plant.)
APRIL - Monthly GMP Refresher
Bump Caps
Bump caps must be maintained and stored in a sanitary condition (right side up on a flat surface or hung by the back strap). Labels or stickers are prohibited.
Bump caps must not be used for storing or carrying objects such as cigarettes, notepads, food, pens, etc.
Earplugs
Hearing Protection devices must be secured to prevent product contamination. These include:
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Ear plugs attached by a string/rigid attachment worn around neck.
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Earmuffs attached by a headband.
Hair Condition & Accessories
In the facility, hair must be maintained as follows:
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Hair must be kept clean.
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Hair curlers, hair combs, and bobby pins are not allowed.
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Barrettes (at least 2 inches in length), clasps, scarves or bandanas may be worn neatly under the hair net.
Hair Restraints
Plant-supplied hair restraints must be worn in the facility:
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Hairnets and/or restraints must be of a close mesh type and be of non-elastic mesh.
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Hairnets and/or restraints must completely contain the hair and cover the ears.
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If bump caps are used they must be worn over appropriate hair restraints.
Facial Hair
In the facility, facial hair must be maintained as follows:
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Employees must be clean shaven or cover the hair as completely as possible with a plant supplied beard or hair restraint.
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Sideburns must be trimmed and be no longer then the bottom of the ear. If sideburns are longer than the bottom of the ear, employees must wear appropriate hair restraints.
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Employees with mustaches must cover them with appropriate hair restraints.
Hand washing/ Glove Changing Frequency
Personnel working in the facility must wash hands at the following times:
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Before entering a production or packaging area.
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Upon reentering a production or packaging area.
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Before entering to Feta area from Blue/Gorg area.
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After each visit to the restroom and/or lunch and break room areas.
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Prior to touching product or product contact surfaces.
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Any time when hands have become soiled or contaminated.
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When gloves become soiled.
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After touching a water hose. (not applicable during clean up)
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After touching the floor or items that have fallen to the floor.
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Upon leaving a raw area and entering a ready to eat area.
Hand Sanitizing Frequency
Personnel in direct contact with product must sanitize hands:
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If working in a production or packaging area (after washing hands)
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After touching non-product contact surfaces (boxes, floor, cleaning equipment, etc).
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Anytime hands become soiled. Hands must be washed prior to re-sanitizing.
Hand Washing and Sanitizing Methods
The steps listed below are required when washing and sanitizing hands/gloves:
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Wet hands with warm water.
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Apply soap. Lather soap by thoroughly rubbing hands together taking care to apply both rubbing action and soap to the entire surface area of the hands. Scrub for 20 seconds.
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Rinse hands completely.
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Dry hands.
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Put on gloves and sanitize, if not wearing gloves, sanitize hands.
MAY - Monthly GMP Refresher
Hand Wash Stations
All hand wash stations shall be operated hands-free. Hand washing stations must be sufficiently located, equipped and maintained:
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Hand wash stations must be conveniently located to optimize usage in production areas where hands routinely contact product.
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Hot and cold water must be available at all stations.
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Hand soap must be provided at each hand wash station.
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Single service paper towels and a place to dispose of used paper towels must be placed near the station.
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Signs reminding people to wash their hands must be posted in all employee restroom facilities; as well as conspicuously located near production hand wash stations.
Control of Hand/Glove Uses
When working in the facility, the use of hands for unsanitary practices must be avoided. Specifically, hands should not be used to:
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Scratch head and body.
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Touch face or wipe forehead.
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Place fingers on, or in, mouth, nose, or ears.
Hand Lotions
Unscented hand lotions may be used if an employee wears appropriate gloves when in contact with food or food contact surfaces.
Fingernails
In the facility, fingernails must:
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Be kept clean and properly trimmed.
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Not be decorated in any way, including:
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Decals.
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Nail polish.
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Nail jewelry.
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False fingernails or nail extenders.
Disease Control Policy
No person will be admitted into a product contact area if he or she has been exposed to, are infected with, or are a carrier of any potential source of microbial or viral contamination.
Employee Illness/ Communicable Disease Management
Anyone who has been exposed, or possibly exposed, to a communicable disease must report it to their department head prior to reporting to their work area:
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Diseases that can be transmitted from person-to-person through typical workplace contact, but are not transmissible through food must be evaluated on a case by case basis. Coordination between Quality and HR may be necessary. A doctor’s note may be requested.
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When consulting with a physician, employees should tell their physician they work in a food production facility.
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A company approved physician will make the final decision in all questionable instances.
Minor Cuts on Hands
Personnel with minor cuts or injuries on hands:
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Must be able to protect the wound and keep it clean and free from infection.
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Will be allowed to work on production lines provided the cuts are bandaged and covered with an impermeable sanitary material (glove or sleeve).
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Adhesive bandages must be metal detectable.
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Any time a bandage is worn on hands or arms, employee MUST cover the bandage, even if the employee is not in contact with food or food contact surfaces.
JUNE - Monthly GMP Refresher- Proper Storage
Designated Storage Practices
Product or ingredient containers must not be stored immediately next to containers for waste or non-product items (cleaning chemicals). They are to be stored to avoid direct contact with the floor or walking surfaces (on appropriate pallets or racks).
Non-product items should be stored in separate, designated areas (chemical shelves).
Titration chemicals shall not be stored in designated break areas. They should be stored in the quality assurance lab/office and other designated departmental areas.
Ingredient Storage Practices
Ingredients must be adequately protected and stored in a sanitary manner:
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In the original, labeled container or
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In another authorized sanitary container that is clearly marked for the use of the specific ingredient.
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Ingredient identification and lot number/ traceability must be maintained.
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Containers must be properly closed/ sealed/ covered.
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When returning ingredient containers to storage, ensure ingredients are stored in the proper place.
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Open bag of ingredient or product must be covered when not in use for longer than 30 minutes.
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Cups with cheese inside can be stacked on the ends of a packaging line only (not on the sides) in a staggered manner (like a pyramid; see below) for no longer than 30 minutes.
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For product that has been pre-cooled, including rework, product shall not remain outside of refrigerated conditions for more than 3 hours.
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If product touches the floor it must be bagged for floor cheese.
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If sealed product touches the floor it must be sanitized before being placed back in line. Employee must wash hands after sanitizing package.
Bulk pre-weighed ingredients must be stored in appropriate approved containers (whirl-pack bags and ingredient pails).
Packaging Storage Practices
Packaging materials in full or partial quantities must be adequately protected and stored in a sanitary manner:
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Material should be covered to prevent contamination (closures, films, bags).
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Packaging material must be removed from the area or protected during wet cleaning.
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Packaging materials must not be stored directly on walking surfaces.
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Maintain the identification and traceability of packaging materials.
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Product must be adequately covered/protected during breaks or downtime while no personnel is in the room.
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Holding & Distribution of Human Food By-Products
Human food by-products held for distribution as animal food must comply with GMPs during holding and distribution.
Containers used to hold human food by-products for use as animal food must be designed and maintained to protect against the contamination and must be accurately identified.
July - Monthly GMP Refresher
Elimination of Standing Water on Floors
During daily operations all standing water on floors will be removed on a routine basis. This includes:
1. Water standing on top of drain clean outs.
2. Water standing on the floor due to routine clean up.
Cleaning & Sanitation:
Water criteria
Water used for cleaning and sanitation, or which otherwise contacts food or food contact surfaces, must be drinkable.
Water Handling & Prevention of Aerosols
Near sanitized equipment and in areas of exposed finished product, water hoses or compressed air hoses shall not be used to clean the floor or equipment due to the formation of aerosols.
No over spray – water must not be splashed from the floor or from unclean equipment onto cleaned equipment or processes during operation.
Water from cleaning operations in one area must be prevented from flowing or controlled when flowing into areas where product is being produced.
Sanitary Handling of Sanitation Tools & Equipment
To prevent contamination, certain tools and equipment must be used only for the intended purpose, dedicated to these specific uses, and handled and/or stored separately.
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Black – Drains Only
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Red – Raw Areas
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Yellow – Environmental and Cleaning (walls, ceiling, floors, Non-product contact surfaces)
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White, Purple, and Stainless/Aluminum– Product Contact Surfaces
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Blue or Purple – Blue Cheese Product Contact (excluding large blue tubs provided by suppliers)
Gasket Handling
Gaskets must be handled and stored in a sanitary manner:
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Product-contact gaskets need to be cleaned or replaced at a defined frequency.
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Used or damaged/worn gaskets need to be discarded to prevent inadvertent later use.
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New gaskets must be washed before use.
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Clean gaskets must be stored in a designated sanitary container.
August - Monthly GMP Refresher
Clean Equipment
Cleaned equipment must be handled/stored in a manner that maintains its sanitary condition and that prevents damage, including:
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Cleaned equipment, parts, cleaning aids/tools, etc., must not be placed directly on walking surfaces. Sanitary rubber mats designated by color or designated sanitary carts or racks may be used for storage.
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Cleaned equipment must not be dragged across the floor or walking surfaces. **Clean Cheese Tubs may be slid on their feet when standing upright (never on their side), if the floor is maintained in a sanitary manner. If the floor is not maintained in a sanitary manner, transport by hand jack or lift truck is required.
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Clean parts must not be stored in unclean containers.
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Clean parts must not be stored with dirty parts.
Sanitary Mats and Plastic Pallets
Designated sanitary mats and plastic pallets must be handled to maintain sanitary conditions, including:
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The mats or plastic pallets must not be stepped on. One side of the mat must be marked to distinguish between the floor contact side and the container or part contact side. An “X” will be used to designate the floor side.
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When not in use, mats must be stored off of the floor in a manner that allows them to dry.
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When mats are hanging, the “X” side needs to be facing the wall. The next mat needs to have the white side facing the white side of previous mat. If a third mat is hung, the “X” sides need to face each other.
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Rubber mats used for employee comfort at workstations need to be distinguishable by color (black or grey) from sanitary mats.
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When not in use, plastic pallets are stored leaning against the wall.
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When leaning against the wall, the feet of the pallet need to be facing the wall. The next pallet needs to have the top of the pallet facing the top of the previous pallet. (Feet to feet, top to top) This pattern will continue as more pallets are added.
Good Housekeeping Practices in Production Areas
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Avoid spillage and damage to product by careful handling.
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Maintain bagged product in a neat and orderly manner.
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Avoid product overhangs on pallets.
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Damaged bags or drums must be immediately sealed to prevent product spillage and contamination.
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Contaminated ingredients must not be used.
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Littering or practices that cause poor housekeeping or other unsanitary conditions are prohibited.
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Put all waste and refuse in trash containers. Trash containers need to be labeled.
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Trash containers must be maintained in a sanitary condition by using liners and/or routine cleaning of the containers.
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Do not block exits.
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Roll up hoses when not in use.
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Footbaths shall be utilized.
Accessories Brought into Production Area
Radios, cameras, televisions, cell phones, books and magazines are not allowed in production or packaging areas unless permitted by management approval.
Live plants, flowers will be allowed in administrate offices. Animals must not be brought into the facility.
Displaying Information
Permanently displayed paper based information shall be in plastic sleeves or laminated to prevent deterioration.
Extraneous Matter Controls
Wood should not be allowed in production and packaging areas.
If wood is required, due to pallet use, then the number of pallets should be kept at a minimum operating level to prevent extraneous matter.
Paint and Rust Flakes
All product and product contact materials or surfaces must be protected from any peeling paint flakes and/or rust particles (from overhead equipment, motors, overhead structures, etc).
Cable Ties
Plastic cable ties must be managed to ensure they are not introduced into product. Metallic cable ties are not allowed.
Restricted Use of Tools and Cleaning Aids
Cleaning tools/aids that may be used under certain restrictions include:
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Scotchbrite pads may be used for a single purpose in a single location, stored in a sanitary manner and must be promptly disposed of at end of week.
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Metal scrapers and wire brushes should not be used on product contact surfaces.
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Washable food industry towels can be used for a single purpose in a single location. Towels will be laundered daily.
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Cleaning aids must be stored in a manner that prevents microbiological contamination or harborage.
Metal Detectable Pens and Markers
Blue Metal Detectable pens are to be used in Blue Production areas. Black Metal Detectable pens are to be used in Non-Blue Production areas.
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Pens are to be signed in and out at the beginning and end of shift on Form 7.154 – Departmental Check in & Check Out.
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Non-Metal Detectable pens, without covers, are allowed in Non-GMP areas.
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Pens are not to be disposed of. Ink cartridges are available for refilling the pens.
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Markers used within the facility are allowed by desk station areas, and must be click style.
Staples, paperclips, and pushpins
The use of staples, drawing pins, paper clips and similar items must not be permitted in production areas or in areas with immediate access to production. Use of staple-less staplers or metal clipboards is recommended for holding papers together.
Receiving & Unloading Bulk Materials
When unloading bulk raw materials from trucks, the dome openings must be adequately screened to protect the materials from contamination. The screening device must allow sufficient airflow into the tank to permit normal unloading. Bulk ingredients will be properly transferred through sanitary pipes and/or hoses, and filtered, screened or sifted as required.
Food Grade Materials Usage & Controls
Food Grade Materials with Product Contact
Lubricants and other materials that have direct or incidental product contact must be an approved food grade type. These materials include, but are not limited to:
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Adhesives.
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Coding inks.
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Hydraulic fluids.
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Aerosol sprays.
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Release agents.
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Hand cleaners and sanitizers.
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Cleaning and sanitation chemicals.
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Equipment lubricants and dressings.
Labeling of Food Grade Materials
Food grade processing aids that are used in processing/production areas must be properly labeled, including:
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A statement that the product or aid is certified/approved for use in a food plant by an authority (NSF, FDA, or CFIA).
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Identification of the substance.
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Listing of ingredient information.
Materials storage
Materials that meet the food grade and labeling criteria may be stored in processing areas.
Any material that is not approved as food grade and that is used on non-product contact surfaces, may only be stored in a food processing area if it is locked in a designated storage device (maintenance cabinet).
September - Monthly GMP Refresher
October - Monthly GMP Refresher
Control During Production
Clean Container Surfaces & Pre-lined Product Containers:
Ingredient containers’ surfaces must be inspected, and if needed, cleaned prior to use in processing.
Pre-lined containers intended for product use must be kept clean, including:
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Liners must be handled with clean/sanitized hands or sanitized gloves.
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Lined containers must be kept adequately covered or turned on their sides, above the walking surfaces, until the time of use.
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Lined totes must be used within 30 minutes of preparation. If the time exceeds 30 minutes, totes need to be covered with sanitary lids.
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Containers must be made of a food grade material.
Receiving, Storage, Handling & Shipping
Materials Stacking:
Racking and storage areas must be adequately spaced from the walls (minimum 12 inches) to allow for inspection of areas for cleanliness, insect or rodent activity. Additionally where rodent control devices are placed there should be an 18 inch gap to allow for inspection. Where this is not possible, alternative means of access must be demonstrated.
Materials and Pallet Handling:
All raw materials, packaging supplies, in-process product and finished product must be handled in a manner that prevents damage, contamination, and/or deterioration:
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Transport vehicles, such as forklift trucks and hand trucks, will be properly used, kept clean and well maintained.
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Broken pallets are not to be used.
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Pallets must be stored in areas that are free of moisture, dirt and litter, and free of bird, insect, or rodent contamination.
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Pallets found with bird, insect or rodent contamination must not be used.
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Pallets should not be stored outside.
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New pallets must be checked for any off odors.
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Damaged containers, where no product is exposed, must be moved to a designated rework area for prompt repackaging or liquidation.
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Damaged containers, where product is exposed, must be managed in a manner to avoid cross contamination, sanitation or pest control issues. If a container is damaged see QA or Management for instructions. See extraneous policy (1.037 Extraneous Matter)
Bulk Tank Trucks
Food Products or food grade materials must be shipped in appropriate vessels.
Trucks and tankers used to ship bulk ingredients must not be used for non-food materials.
November - Monthly GMP Refresher
Sanitary Conditions & Practices:
Idle Process Pipes
1. Pipes and sanitary hoses that are connected to product systems and are idle must be cleaned and capped.
2. Pipes that are stored on racks must be sufficiently cleaned and inspected.
Condensate Control
Product and materials must be protected from exposure to condensate (liquid dripping from overhead pipes):
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Whenever possible, condensate must be eliminated, such as by insulating the involved pipes (using cleanable, sanitary, closed cell type insulation materials).
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Where condensate cannot be prevented, a sanitary control program must carefully manage it.
Floor Contact and Proper Disposition Practices
Care must be taken to prevent ingredients or product from falling on the floor. However, if ingredients/product do contact the floor, they are no longer fit for human consumption and must be placed in the garbage or bagged and placed in a container labeled for floor cheese for proper disposal.
Sanitary Design:
Piping Systems
Piping systems must be designed and constructed to ensure there are no dead ends that may result in contamination to materials or products.
Knives
Knives that have folding, retractable blades are not permitted in production areas. One piece knives of sanitary design are recommended.
Facilities:
Rest Rooms
Rest Rooms shall not have direct entrance to exposed product areas. If existing facilities are necessary in the exposed product area, they will have, at a minimum two doors of separation from the exposed product area and have hand washing facilities.
Use of Doors
Drivers, Contractor and Visitors will remain in designated unlocked waiting rooms and denied plant entrance unless escorted or signed in by an employee.
All other exterior doors must have controlled access and be kept well sealed and kept closed at all times.
Department Uniform Changes
Any employee (excluding the cheese maker) working in a Blue Cheese Department for the first part of their shift and later must work in a Non-Blue Cheese Department must change their uniform and sanitize footwear before starting work in the Non- Blue Area. No aprons or arm guards shall be transferred between departments. The employee must wash hands before entering the Non-Blue Cheese Department.
Recyclable Material
Recyclable materials collection areas must be kept clean and neat. Materials shall be removed at a frequency to minimize pest harborage. Appropriate signage must be posted to identify the area.
Equipment and Materials Storage
Exterior storage of equipment and materials – including idle equipment, contractor supplies or other items should be:
1. minimized through routine inventory assessments and
2. neatly stored off of the ground and
3. away from the building perimeter.
Refuse Area
Refuse areas must be strictly controlled, including providing:
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An adequate number of covered trash bins.
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Appropriate separation between refuse area and facility.
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Designated containers appropriately labeled.
Documentation
Records, Documentation, and Recording Practices
Where employees are required to log, record or document activities, these records and/or other company documentation must be completed in a timely and accurate manner.
To ensure the integrity of document records:
1. Pencils must not be used on permanent records.
2. White-out must not be used.
3. If a mistake is made, a single line should be drawn though the
mistake and initialed by the person crossing out(see image below.
December - Monthly GMP Refresher
