Aren’t all disposable gloves the same? Will medical gloves do in a food setting? Are my gloves food safe if the website says so?
The answer is No, probably No, and maybe not.
During some recent BRC internal audits that we have conducted within the food industry (against the BRC Global Standards Food Safety Standard Issue 8) the question “are my gloves food safe” has arisen a number of times.
For example the BRC Global Standards (BRC Global Standards) Food Safety Standard says in clause 7.4.5: If gloves are used, they shall be replaced regularly. Where appropriate, gloves shall be suitable for food use, of a disposable type, of a distinctive colour (blue where possible), be intact and not shed loose fibres.
So what are suitable gloves?
The standard is clear that they must be disposable. What this means is used for a limited time, and changed whenever there is a change of product type, if the glove has contacted dirty and contaminated surfaces, if the glove has (accidentally) contacted the face, or if the glove has torn or ripped. The key thing to remember is that taking the glove off inevitably results in one hand contacting the outer surface of the glove that it is trying to remove. Coupled with the fact that the hands will perspire under the glove, which causes a considerable increase in the proliferation of the skin bacteria normally present, this demonstrates a clear need to ensure that a full and proper hand wash is conducted before putting on a new pair of disposable gloves.
The reason for the clause in the BRC Global Standards Food Safety Standard demanding distinctive colour is the same as that presented in the standard for plasters. Blue is distinctive and would show up easily in almost all food types. A shredded glove, if the shreds are blue, will show up, presenting the food handler with the opportunity to remove food that has been contaminated by the shreds.
What does the BRC Standard mean by “suitable for food use”?
This means that the gloves may be used without risk of dangerous levels of unintended migration of chemicals from the material of the disposable gloves into the food being handled. This is in fact demanded by EC 1935/2004 on materials and articles intended to come into contact with food and by EC 10/2011 on plastic materials and articles intended to come into contact with food. The former statute contains a template statement of compliance that can be used by manufacturers of materials intended to come into contact with food. The latter statute stipulates the migration testing protocol which should be used by manufacturers of such materials, as evidence that unintended migration of chemicals, from the material, remains at safe levels.
How would “food safe gloves” be tested?
EC 10/2011 contains the Union List of permitted starting substances, used in production of materials intended to come into contact with food. It also contains in Annex III details of simulants that must be used in migration testing together with a table of food types and the simulants that should be used based on the chemical properties of that food. In Annex V, a migration testing protocol is detailed, based on potential worst case contact time and food substrate temperature to which the material would be subjected. It is this protocol that is followed by contract testing laboratories when materials are submitted to them to determine food contact suitability. So let’s consider the regulation in terms of disposable gloves food contact testing:
A glove manufacturer, when setting the specification for the disposable gloves, may consider the food that may be handled (Annex III) and the tables in Annex V (expected use) and decide upon:-
- Worst case total contact time 2 to 6 hours (this would be reasonable as it would not be expected that a disposable glove would be used for longer than this time)
- Temperature that accounts for warm or hot food, so let’s say 20 to 40C (again not unreasonable – any hotter and scalding could result!)
- Gloves may reasonably be expected to handle most food types, From Annex III, we could consider perhaps fatty foods, protein foods, baked goods and acidic foods (again not unreasonable if you think of the foods handled in a factory or in your average High Street coffee chain, burger chain or sandwich bar). So from Annex III we would need to consider which of the following test simulants to apply.
- Food Simulant A – 10% ethanol (for foods with hydrophilic character)
- Food Simulant B – 3% acetic acid (used for acidic foods which are below pH 4.5)
- Food Simulant C – 20% ethanol (used for alcoholic foods up to 20% and foods which contain a relevant amount of organic ingredients that render the food more lipophilic)
- Food Simulant D1 – 50% ethanol (to be used for alcoholic foods with an alcoholic content above 20%, and where contact is expected with oil in water emulsions)
- Food Simulant D2 – vegetable oil (for foods which contain free fats at the surface, for instance, butter and some meats)
- Food Simulant E2 – (OK so we may need a chemistry qualification for this one!) poly(2,6-diphenyl-p-phenylene oxide), particle size 60-80 mesh, pore size 200 nm – this is the simulant to be used for dry foods.
Your accredited contract laboratory will now mimic these conditions in a chamber and conduct analysis to determine what, if any, migration into the food simulant has occurred.
For Overall Migration Limits EC 10/2011 says: Plastic materials and articles shall not transfer their constituents to food simulants in quantities exceeding 10 milligrams of total constituents released per dm2 of food contact surface (mg/dm2). There are also a number of Specific Migration Limits that may apply depending on the constituent materials of the material tested. For instance there is a specific migration limit of 0.05 mg/kg for vinyl esters.
What proof should be presented by a glove supplier?
Following the above analysis, the glove supplier must be able to provide a declaration of compliance which has been extracted and summarised from Annex IV of EC 10/2011, in relation to the above (please see Annex IV for full details):
- the date of the declaration;
- confirmation that the plastic materials or articles, products from intermediate stages of manufacture or the substances meet relevant requirements laid down in this Regulation and Regulation (EC) No 1935/2004;
- specifications on the use of the material or article, such as:
(i) type or types of food with which it is intended to be put in contact;
(ii) time and temperature of treatment and storage in contact with the food;
(iii) ratio of food contact surface area to volume used to establish the compliance of the material or article;
The glove box should also show wine glass and fork symbol
Can I rely on the wine glass and fork symbol alone?
Sadly no! Fraudulent use of this mark is not entirely uncommon. So talk to your glove supplier and ask for demonstrable evidence (copy some of this article into your request if you like!)
BRC certification to the Food Safety Standard means that food manufacturers are well versed in securing proper evidence. But what about food service operations?
Well the good news is that if you are audited by a credible third party, or you are using a food safety audit tool like HygieneCheck, then you will already be aware of the importance of proper proof that a glove is truly suitable for food contact!