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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.

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.

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.

Read more about The Unwritten Food Code

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. 

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.

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".

Read more about The Written Food Code: Prescription vs. Innovation

Michelin 2 Star Norovirus in London

“… staff told to wash their hands more often.”

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.”

Read more about Michelin 2 Star Norovirus in London

Fixing Food Code Flaws

2013 Food Code, FDA, U.S. Public Health Service

Risk vs. Inspection

[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.

Read more about Fixing Food Code Flaws

Kindling a Culture of Cleanliness

Come Compete in the Handwashing For Life Olympics

Handwashing For Life® overcomes underwashing of hands and high-touch surfaces by integrating a series of best practices. At the Food Safety Consortium, being staged at the Schaumburg Conference Center, on December 4th & 5th, attendees will learn how to assess their hand hygiene related risks and assemble a sustainable solution. The program is a driver to establish a culture of cleanliness, one handwash at a time.

Read more about Kindling a Culture of Cleanliness

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HandsOn<sup>™</sup> System

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SaniTwice<sup>®</sup> for Catered Events

Uncompromized hand cleanliness for those serving food at venues without running water.

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