MEMORANDUM 41
Submitted by the Textile Services Association
The Textile Services Association represents
the interests of the commercial laundry, retail drycleaning and
textile rental industries in the United Kingdom. Membership of
the Association includes all of the major companies involved in
the supply of rented/managed workwear to the food industry, (Sunlight
Service Group, Johnson Service Group, Rentokil—Initial,
Sketchley Textile Services, Brooks Service Group, OCS—Smarts
Group, Fishers Services) together with the majority of smaller
to medium sized companies operating in the sector. The Association
is formally recognised by the Department of Trade and Industry
and actively promotes best practice within the sector through
participation in, inter alia, appropriate working groups
of CEN and ISO and on-going work with the Health and Safety Executive
to review the industry's health, safety and environmental guidelines.
CEN, supported by the Association, is currently working on a European
standard for the hygienic quality of laundry processed textiles
in sectors where it is necessary to control biocontamination (CEN/TC248/WG17).
The Association is thus well placed to contribute to the proposal
to form an Independent Food Standards Agency.
The Association welcomes Government's initiative
to establish the FSA as an important first step, but feels that
the aim of consumer protection will not fully be met without more
stringent regulation of the provision and laundering of workwear
used in food processing and retailing areas.
EVIDENCE FOR
THE PROVISION
OF WORKWEAR
TO THE
FOOD INDUSTRY
BY TEXTILE
RENTAL SERVICES
Introduction
Government recognition of the need to manage
food safety better has increased, on a worldwide basis, over the
last 10 years. In Europe, one of the most powerful driving forces
is the European Community Directive 93/43 EC (1993) on the Hygiene
of Foodstuffs. Article 3 of the Directive states that food business
operators shall identify any step in their activities critical
to ensuring food safety and ensure that adequate safety procedures
are identified, implemented, maintained and reviewed. Indeed,
the Directive lists the first five principles of a safety management
system known as HACCP (Hazard Analysis Critical Control Points).
In essence the Directive is a very strong recommendation that
food businesses throughout Europe should use the HACCP approach
as a means of demonstrating compliance with its essential requirements.
HACCP
The HACCP system was developed by the Pillsbury
Company in the USA, in collaboration with NASA, to provide safe
and hygienic food for astronauts on the space programme. In some
senses HACCP is a subset of ISO 9000 systems. Whereas the latter
deals with the "quality" aspects of a product or service,
HACCP is concerned with the safety of the product. The proper
implementation of a HACCP system will require a very detailed,
multi-disciplinary approach and will often employ sophisticated
statistical techniques. However, at its core, it analyses the
production flowline to identify points where contamination risks
occur and it sets down procedures for identifying and controlling
the risks.
WHERE IN
THE PROCESS
DOES HACCP START?
HACCP cannot successfully be applied if its
scope is restricted to the immediate food handling, processing
or manufacturing plant. It must start with the suppliers of raw
materials, goods and services. The hazard of any inward goods
must be identified and two questions answered. First, will the
hazard be processed out at some stage? Second, is there a contamination
risk to the food product, which will not be controlled? If the
answers are "No" and "Yes" respectively, then
the point of entry of such goods to the processing plant constitutes
a Critical Control Point or CCP and a high level of control is
required.
Raw foodstuffs obviously require special consideration,
but other articles, peripheral, but essential to the food processing
must be controlled. One of these is the protective workwear worn
by the food handling staff.
WORKWEAR
Food handlers and other personnel with access
to food processing areas could contaminate the product by introducing
microbiological, chemical or physical (foreign body) hazards.
Whilst plant layout and movement controls can reduce the risk,
it is essential to provide the work force with appropriate protective
clothing. The wearers must appreciate that the purpose of the
workwear is primarily to protect the foodstuffs, although of course
it will serve to keep them clean as well.
Selection and laundering of workwear is as amenable
to a HACCP systems approach as the actual food processing itself.
Clearly though, the discipline to apply HACCP in order to satisfy
the conditions of control at the delivery CCP can only take place
in a properly managed environment.
Most textile rental operations are ISO 9002
registered and of those providing workwear to food companies,
many are already operating HACCP systems and are well used to
receiving audit visits from their customers or their agents. They
offer an expert, totally managed textile package, within the ISO
9002 and HACCP systems, which starts with advice on the selection
of garments for staff with different duties, frequency of garment
changes and includes the design of laundry processes matched to
soiling types and levels.
Above all the textile renter offers assurance
through traceability. All processing equipment is properly maintained,
checked for actual performance against its programming and regularly
calibrated. At intervals processes are revalidated for effectiveness
and monitoring records of key parameters are kept between validations
to ensure processes remain within control limits. If non-compliance
arises, loads are isolated for reprocessing and prescribed corrective
action is taken.
The result, for the customer, is a stain and
foreign body free, hygienically clean garment which is functional,
fits well and is finished to a high standard every time. It will
be designed to satisfy the Food Company HACCP team, the company
Marketing Director responsible for image and the staff member.
This is particularly important because wearer comfort and self-esteem
are vital components in a safe and successful operation.
Food Companies are required, in the UK's 1990
Food Safety Act, to demonstrate "due diligence" in their
management and operations. The decision to contract a properly
managed textile renter to supply protective workwear allows a
food company to demonstrate compliance in this important area.
It is most unlikely that a laundry operated
by a food company could assure all aspects of this level of service.
Clearly home laundering by company staff by definition lies outside
the managed environment and is completely unsatisfactory.
BIBLIOGRAPHY
R A Sprenger, Hygiene Management, Highfield
publications 1983.
S Mortimore and C Wallace HACCP a practical
approach Chapman & Hall 1994.
Laundering Workwear for the High Care sector
of the Food Industry Fabric Care Research Association 1997.
J I Rigarlsford Private Communications 1998,
1999.
CIN IC248 WG17 Working draft: Laundry processed
textiles—biocontamination control.
ISOIC209 WG2 ISO/CD 14698 part I: Cleanroom
technology—biocontamination control—general principles.
Recommendations
FSA should, by regulation, improve the protection
offered to consumers by:
(1) requiring all appropriate companies operating
in food processing, handling and retailing to supply clean workwear
to all appropriate staff;
(2) requiring such workwear to be supplied
by a company operating a quality system such as ISO 9002 and HACCP
systems;
(3) mandating that such workwear is changed
on a daily basis; and
(4) prohibiting the home laundering of workwear
with its inherent risk of cross-contamination.
Compliance Cost
Although there will clearly be a compliance
cost for businesses not currently meeting best practice, the benefits
and reassurance to the end user are clear and unambiguous.
TSA would be prepared to supply further information—or
give oral evidence to the committee—if required.
March 1999
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