Tasks such as, but not limited to, cooking burgers on a grill require handling of both raw and ready-to-eat product by the same person.
Better handwashing protocols specify disposable paper towels or continuous towel systems as they add a valuable friction factor, significantly increasing cleaning, perhaps even doubling it when measured in log reduction. This is a benefit unavailable to all styles of air dryers, warm air or air blade. For this reason the Department of the Army in Technical Bulletin (TB) MED 530 specifies either disposable paper or continuous fabric roll towels be used at all handsinks used by employees.
(Submitted by a former State Regulator after reading this blog series in preparation for the 2014 biennial Conference For Food Protection (CFP))
The ‘prescriptive' nature of the food code is now being understood by local health officials as: 'The health authority prescribes how a task is done and the operator is responsible to do the task as prescribed.' This interpretation, which differs from the traditional approach of Food Code which defined the minimum standard needed and operators were encouraged to innovate to complete the task at a standard that exceeded the minimum required by regulation.
The handwashing minimum water temperature in Section 5-202.12 of the Food Code, states " ... equipped to provide water at least 38°C (100°F) ..." This is interpreted by both operators and inspectors as the definitive base for effectiveness of the handwash while the goal is largely user comfort. All temperatures between a common ambient and 107°F are sufficiently comfortable. As to cleaning effectiveness, the body's 98.6°F quickly heats the soap and initial scrub-water.
30,000+ health inspectors/assessors have an opportunity to be more focused on prevention in keeping with the principles of Active Managerial Control (AMC) and in the spirit of the Food Safety Modernization Act (FSMA).
A condition for improved learning for food handlers and their managers can be achieved by scheduling inspections rather than expecting food service managers to learn in what often feels like a raid, especially when key managers are missing.
Health authorities help operators prepare and serve safe food. These agencies take their guidance from the FDA's written Model Food Code which sets out minimum standards in a 642 page tome.
Every successive edition of the Code becomes more prescriptive, leaving less choice available for the operator. This dangerously dilute's the operator's commitment to the standards of safe food as he realizes he's not fully in charge of food safety. He interprets regulatory's reduction of choice as a shift in responsibility. Health authorities take over by virtue of them no longer allowing the operator to choose the method of compliance that works best for them - even when the solution is superior to the Code's "prescription".
After the closing of another world class restaurant due to a norovirus outbreak, a piece of world class food safety advice was passed along by London's health inspectors as reported in The Guardian newspaper: “Environmental health officers have told staff at the two Michelin star restaurant to wash their hands more often, an embarrassing order for those preparing evening starters beginning at £12 and main courses ranging up to £42.”
[Notes for those interested in enhancing the Model Food Code via the Conference For Food Protection (CFP) process.]
Unintended consequences are many as the FDA's Model Food Code strives to further protect public health. The operators have prime accountability for serving safe food and the more than 30,000 health inspectors look to help them. Both have the same goal. It can be a team effort and often is. But there is tension baked into their respective DNAs. The power to close a restaurant is intimidating and discourages frank dialog.
Customers are increasingly seeing restroom cleanliness as an indicator of the organization's culture and the reflection of their true customer care. It is proving to be one of the best spaces to invest in customer loyalty.
Not everyone treats kitchen cleanliness as a cost. Some leading chefs consider it the foundation of their culture of cleanliness where creativity, quality and efficiency generate the prime revenue of returning customers. High standards translate to the staff's professional pride and unquestioned compliance with accountabilities.
This portable no-water "handsink" has added an important gloving feature. This unit can now be located exactly where it is most needed and most likely used. There is no need to delay changing a contaminated or torn pair of gloves. There is no need to leave the work station unguarded while taking a hike to the nearest restroom or kitchen.
Once a public health driven need is identified, local resources seek solutions, often with supplier partners. Concept prototypes and programs are developed. Costly research is often involved and manufacturers seek patent protection to make this investment worthwhile. This factor looms large as some links in the chain of innovation confuse basic capitalism with greed, slowing the implementation of new ideas.
Waste in terms of lost donning time and "multi-pull" losses are answered with a new generation of single-use gloves. FoodHandler Category Manager, Cory Sexson, outlines benefits:
Might the norovirus have entered the catered event via an ill worker, perhaps symptom-free? Or a guest? Or from contact with a high-touch surface contaminated the week before?
Thanksgiving, the eater's favorite holiday. Ours always starts on Wednesday with a little pre-prep and gathering last minute supplies.
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