Operator Hygiene Requirements: Hands, Clothing, and Health

Why People Are the Focus

Food machinery is mostly stainless steel and is disassembled, washed, and sanitized every day; but what touches raw materials, parts, and products most each day are the operators' hands. Bacteria on hands, hair, jewelry, and nail polish can all fall into the product. If personnel hygiene isn't managed well, no matter how clean the machine is, it's wasted effort.

These requirements are set out in Annex 2, "Personnel Hygiene Management," of the Regulations on Good Hygiene Practice for Food (食品良好衛生規範準則). Each item is explained below.

Are Health Checks Required?

Yes. Point 1 of Annex 2 states:

• Before hiring: Food workers may be hired only after passing an examination by a medical institution for hepatitis A, typhoid, rashes, abscesses, wounds, and skin diseases of the hands.
• Every year: Employers must arrange the above examination for food workers at least once a year.

Under Article 3 of the regulations, "food workers" are personnel whose work involves direct contact with food, or who handle food with machinery and tools during processing in ways that affect product hygiene and safety. People who operate encrusting and forming machines fall within this scope.

Training

Point 1 of Annex 2 also states:

• New food workers must receive at least 3 hours of training, and records must be kept.
• Current staff must receive training in food safety, hygiene, and quality management of at least 3 hours each year, and records must be kept.

Besides hygiene knowledge, machine operators should also receive machinery safety training: where the emergency stops are, lockout/tagout procedures, and never removing guards.

What Operators Should Wear

Annex 2 requires food workers in the work area to wear clean work clothes, caps (and shoes), and masks; personal clothing may not be brought into the work area.

In practice:

• Work clothes: Light-colored, with no pockets or only pockets below the waist so items don't fall out; snug cuffs.
• Cap or hairnet: Fully covers the hair; tie back long hair first.
• Mask: Covers the mouth and nose.
• Work shoes: Slip-resistant and waterproof, worn only in the work area.
• Gloves: When preparing ready-to-eat foods, hands must be thoroughly washed and sanitized, and clean impermeable gloves worn if necessary.

The clothing must also account for safety: Article 279 of the Occupational Safety and Health Facilities Regulations (職業安全衛生設施規則) requires workers who operate or approach running machinery to wear suitable clothing and caps when there is a risk of their hair or clothing being caught. Loose sleeves, dangling cap strings, and scarves are all hazards next to rollers and mixers. In addition, Article 56 of the same regulations states that for work with rotating cutting tools such as drilling machines, workers must not wear gloves when their fingers may come into contact with the tool. When operating rotating machinery such as rollers and mixers, assess whether gloves could be caught based on the characteristics of the machine.

Hand and Personal Hygiene

Annex 2 requires:

• Hands must be kept clean; no long fingernails, nail polish, nail art, artificial nails, or jewelry; cosmetics, medicines, and the like must not contaminate products.
• Before entering the work area, and after using the toilet, spitting, blowing the nose, or any other action that could contaminate the hands, wash immediately before resuming work.
• No smoking, chewing betel nut, chewing gum, eating, or drinking during work.
• Hands that prepare ready-to-eat foods must not simultaneously or successively touch money or other items that could be contaminated.
• The entry and exit of non-food workers (visitors, maintenance staff) must be controlled, and they must also meet the clothing, hand hygiene, and other requirements when entering.

Maintenance staff who enter the line to repair machines are often overlooked: where the toolbox goes, whether they wash their hands afterward, and whether parts are dropped in the product area all need to be managed.

Can Injured Staff Work?

Annex 2 states that anyone suffering from or infected with hepatitis A, typhoid, rashes, abscesses, wounds, skin diseases of the hands, or other diseases that could contaminate food must, for the duration of the illness or infection, proactively inform the on-site supervisor and must not do work involving contact with food.

So when someone has a cut, an infection, or a skin condition on their hands, they can't touch food directly. They can be assigned work that doesn't involve food contact (such as outer packaging or moving boxed products) and return to the line after they recover. Plants should build a system that encourages employees to report proactively, instead of letting people push through with injuries.

FAQ

Q: Do employees who operate encrusting machines need health checks?
A: Yes. Before hiring, they must be checked for hepatitis A, typhoid, rashes, abscesses, wounds, skin diseases of the hands, and so on, and then at least once a year.

Q: Can workers wear rings or watches during work?
A: No. Annex 2 of the Regulations on Good Hygiene Practice for Food prohibits wearing jewelry.

Q: Can someone with a cut on their hand still make dumplings?
A: They may not do work involving food contact. They should inform their supervisor and can be reassigned to work that doesn't involve food contact.

Q: How many hours of hygiene training are required each year?
A: At least 3 hours per year for current food workers and at least 3 hours for new hires, with records kept for both.