Requirements for Work Shoes in A Food Factory
In the meticulously controlled environment of a food factory, every detail matters—especially what employees wear on their feet. Work shoes
are not merely a matter of personal protective equipment (PPE) for safety; they are a critical control point in a facility's food safety
management system. Contamination from footwear is a significant risk, capable of introducing pathogens, allergens, and physical hazards
directly into production areas.
Adherence to globally recognized standards, such as the BRCGS Global Standard for Food Safety Issue 9, is non-negotiable for any site
aiming to produce safe, legal, and high-quality products. This article provides a comprehensive guide to the requirements for work shoes in a
food factory, directly aligned with BRCGS Issue 9, to help you mitigate risks, pass audits, and protect your brand.
Why Footwear is a Critical Food Safety Control
Footwear can be a primary vector for contamination. Consider what shoes can track in from outside or transfer between different areas inside
a facility:
- Microbiological Hazards: Pathogens like Listeria, Salmonella, and E. coli can be harbored in the soles and uppers of shoes.
- Physical Hazards: Dirt, gravel, metal shavings, and other debris can become dislodged in production areas.
- Allergens: Residues from allergens processed in one zone can be traipsed into an allergen-free zone.
- Chemical Hazards: Residues from cleaning chemicals, oils, or external environments can be transferred.
The BRCGS Standard is built on a foundation of Hazard Analysis and Critical Control Points (HACCP) and Prerequisite Programmes (PRPs).
Effective footwear control is a fundamental part of these PRPs, specifically falling under:
- Personal Hygiene (Section 7)
- Protective Clothing (Section 7.4)
- Layout, Product Flow, and Segregation (Section 4.3)
- Production Risk Zones (Section 8)
Failure to adequately control footwear can lead to a major non-conformity during a BRCGS audit, potentially resulting in a failed certification.
The requirements for work shoes become more stringent as the risk level of the production area increases. The BRCGS Standard defines
specific zones like High-Risk and High-Care areas, which have dedicated protocols.
1. General Requirements for All Production and Storage Areas
These are the baseline rules that apply to anyone entering raw material handling, preparation, processing, packing, or storage areas.
Dedicated Site Footwear: The standard implicitly requires that footwear used in production areas is not worn outside. The most effective way
to achieve this is to provide dedicated, site-issued shoes or safety boots that remain on the premises (Clause 7.4.1).
Design to Prevent Contamination: Footwear must be designed to minimize the risk of product contamination. This typically means:
No Laces: Laces can come untied, introducing a physical contaminant and themselves becoming dirty.
Closed-Toe and Closed-Heel: To protect both the employee from injuries and the product from any personal contamination.
Smooth, Non-Absorbent Uppers: Easy-to-clean materials like rubber or PVC that do not trap dirt or moisture.
Cleated or Slip-Resistant Soles: Essential for employee safety, but the cleat pattern should be designed to be easy to clean and not trap
debris.
Hygienic Storage: Facilities must be provided for employees to store their personal outdoor footwear separately from their production-area
footwear (Clause 4.8.3).
2. Enhanced Requirements for High-Risk and High-Care Zones
Sections 8.4 and 8.7 of the BRCGS Standard outline specific, non-negotiable rules for footwear in high-risk and high-care areas. These are
areas where ready-to-eat products are exposed to the environment after the pathogen control step (e.g., cooking).
Visibly Distinctive Footwear: Footwear for these zones must be visually distinct from footwear worn in other parts of the factory (e.g., a
different color or style). This provides an immediate visual check to ensure compliance with segregation rules (Clause 8.4.1).
Dedicated to the Area: This footwear must not be worn outside the high-risk/high-care area. It must remain within the changing facility for that
specific zone.
Effective Footwear Control at Entry: The standard mandates an "effective control of footwear to prevent the introduction of pathogens into the
area." This is achieved through one of two primary methods (Clause 8.4.1):
Segregation and Bench System: A physical barrier (like a bench) separates the "dirty" side from the "clean" side. Employees remove footwear
from the low-risk side, step over the bench, and don the dedicated high-risk/high-care footwear on the clean side. This is often considered the
gold standard.
Managed Boot-Wash Stations: If a bench system is not used, boot-wash stations must be demonstrably effective. This means they must be
properly maintained, used correctly every time, and their effectiveness must be validated.
Validation via Environmental Monitoring: A site cannot simply state its boot-wash is effective; it must prove it. The standard requires that a
programme of environmental monitoring (e.g., swabbing floors and drains for pathogens like Listeria) is used to assess and verify the
effectiveness of the footwear controls (Clause 8.4.1).
3. The Critical Link to Hygiene and Zoning
Footwear control is not an isolated policy; it is deeply integrated with other core requirements of the BRCGS Standard.
Layout and Segregation (Section 4.3): The factory's layout must facilitate the safe movement of personnel without compromising product safety
. Clear maps defining routes and access points for different risk zones are required. Footwear protocols are a key part of enforcing this
segregation.
Housekeeping and Hygiene (Section 4.11): The cleaning procedures for the factory must include protocols for cleaning and disinfecting
footwear, especially when boot-washes are used. The frequency and methods must be based on risk.
Choosing the Right Footwear: A Practical Checklist
When selecting or specifying work shoes for your food factory, use this checklist to ensure compliance and safety:
- Material: Is it made of easy-to-clean, non-absorbent material like rubber, PVC, or certain polymers?
- Design: Is it fully enclosed, without laces, and with smooth seams to trap debris?
- Sole: Is it slip-resistant and designed with a tread pattern that is easy to clean?
- Safety Features: Does it offer the necessary safety ratings for your facility (e.g., steel toe, puncture-resistant sole)?
- Durability: Is it durable enough to withstand daily cleaning and disinfectant chemicals?
- Color-Coding: For high-risk/high-care zones, is it a distinct, dedicated color not used elsewhere?
Implementing and Enforcing a Compliant Footwear Program
Having a policy is one thing; ensuring it is followed is another. Here’s how to build a robust system:
Risk Assessment:
Conduct a formal risk assessment as part of your HACCP plan to identify the specific footwear-related hazards in each area of your facility.
Documented Procedures:
Create clear, written procedures for footwear use, changing protocols, and cleaning. These must be part of your food safety and quality
manual (Section 3.1).
Training and Competence (Section 7.1):
All employees, including temporary and contract staff, must be thoroughly trained on the "why" and "how" of the footwear policy. This is a
fundamental requirement. Training records must be maintained.
Adequate Facilities:
Provide well-designed changing rooms with clear "dirty" and "clean" sides, adequate storage, and well-maintained boot-wash stations where
applicable (Section 4.8).
Auditing and Verification:
Include footwear compliance in your internal audit schedule (Section 3.4). Regularly observe employees, check changing rooms, and review
the results of your environmental monitoring to ensure the system is working.
Management Commitment (Section 1.1):
Senior management must lead by example and provide the necessary resources (human and financial) to support the program. A positive
food safety culture is essential for long-term success.
In the world of food manufacturing, there is no room for oversight when it comes to contamination control. Work shoes, while seemingly a
simple piece of equipment, represent a critical line of defense in protecting product safety and integrity.
By understanding and implementing the stringent requirements of the BRCGS Global Standard for Food Safety Issue 9, food factories can
transform their footwear policy from a basic rule into a robust, validated, and auditable system. This not only ensures compliance and a
successful audit outcome but, more importantly, builds a foundation of trust with customers and consumers by demonstrating an unwavering
commitment to producing safe, high-quality food.
