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Handwashing for Life

Overcoming Underwashing
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2014 CFP Hand Hygiene Success: Groundwork for 2016

A recommendation of “No Action” at the CFP (Conference for Food Protection) can be viewed as a strike out and to continue the baseball metaphor, Handwashing For Life went 0 for 7 on the issues submitted in 2014. We thought at least one would be accepted but all were presented as a foundation for 2016. In that context our efforts were well received and rewarded with calls to continue our quest for codifying hand hygiene innovations. Lively discussion demonstrated the need for changes but the system favors the status quo.

Non-voting Council Members, the FDA and CDC, sharply tilt the decision making power. A timely sound-bite can end Council discussion. Who of the regulatory Council Members are willing to vote against the non-voting regulatory Members?

Here is our interpretation of what happened, why and how each sets up for 2016.

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Hand Cleanse-Sanitize Protocol Not Requiring Running Water

Clean hands from the petting zoo to the Iditarod, from farmer’s markets to trade shows and elegant receptions

Food service situations with compromised potable water supply are many and growing as operators respond to the public's demand to have safe food convenient to their daily trail. This results in food being prepared and served in venues without running water for handwashing. Gloves are not the full answer as when they are damaged or contaminated or a task change is required, there is no reasonable option to clean hands between glove changes.

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FDA Food Code Hand Hygiene Definitions

Words conjure up predetermined perceptions. 

Handwashing creates an expectation of contaminant removal with soap and water. Protocols that remove soil without water, such as moistened towelettes and those using alcohol hand-sanitizer as a soap/water-substitute, do not qualify as hand washes.

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The Hand Cleaning Factor of Paper Toweling

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.

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The Unwritten Food Code

(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.

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Lower Handwash Water Temperature Minimum

Open the door to convenience, compliance and water savings.

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. 

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Expansion of Scheduled Inspections

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.

Jim Mann's picture

The Written Food Code: Prescription vs. Innovation

How the operator-interpreted code blurs food safety responsibility.

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".

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