1. Start by hiring smarter … Hire managers with leadership skills to help employees reach and sustain their professional handwashing standards. Don’t hire employees with nervous habits of unconscious twitches and touches of their face or hair. Hire people with cleanable hands.
Our world of restaurant food safety is blessed with a cadre of good trainers and creative programs. This has been true for at least the last decade as more technology now leverages the messaging.
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.
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.
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.”
Express the values of your organization and provide the mile markers for individual and team success.
[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.
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