Navigating Title 8 CCR §3368: When It Doesn't Apply to Corrugated Packaging

Understanding the nuances of Title 8 California Code of Regulations (CCR) §3368, which governs the consumption of food and beverages in the workplace, is crucial for any business operating in the corrugated packaging industry. While this regulation is designed to maintain a safe and hygienic work environment, there are specific scenarios where it may not apply or may fall short.

Exceptions to the Rule

There are certain exceptions where Title 8 CCR §3368 may not be applicable in a corrugated packaging facility. For instance, if the area designated for eating and drinking is completely separated from the production area by physical barriers, the regulation might not extend to those designated spaces. This separation ensures that no contamination from production materials like corrugated paper can occur.

Another scenario where the regulation might not apply is during maintenance or repair work that is not part of the regular production process. If employees are consuming food or beverages in a break area that is not near any operational machinery or production materials, the regulation's strict enforcement may be relaxed.

Limitations and Challenges

Title 8 CCR §3368 can sometimes fall short in addressing the unique challenges faced by the corrugated packaging industry. For example, the regulation does not specifically address the potential for airborne dust from corrugated materials, which can contaminate food even in designated eating areas. Based on available research, individual results may vary, but maintaining strict air filtration systems and regular cleaning protocols can mitigate this risk.

Additionally, the regulation does not provide clear guidance on how to manage food and beverage consumption during shift changes or overtime work, which are common in corrugated packaging plants. I've seen firsthand how challenging it can be to ensure compliance during these times, especially when production schedules are tight. We often recommend implementing flexible break schedules and designated areas that are further away from production zones to address these challenges effectively.

Best Practices for Compliance

To navigate these limitations and ensure compliance, consider the following best practices:

• Designate Clear Zones: Clearly mark areas where food and beverages are allowed, ensuring they are physically separated from production areas.
• Implement Strict Cleaning Protocols: Regularly clean and sanitize eating areas to minimize the risk of contamination from dust or other production materials.
• Use Air Filtration: Install air filtration systems to reduce airborne dust in eating areas.
• Flexible Break Schedules: Adjust break times to accommodate shift changes and overtime, ensuring employees have safe places to eat and drink.

By understanding the exceptions and limitations of Title 8 CCR §3368, corrugated packaging facilities can better tailor their safety protocols to meet the regulation's intent while addressing the unique challenges of their industry. For further guidance, consider consulting resources from the California Department of Industrial Relations or engaging with safety consultants who specialize in industrial environments.