The 12 questions, delivered in three short survey segments, were designed to raise awareness of some unaddressed sub-issues remaining from the 2012 Conference For Food Protection's Hand Hygiene Committee, charged with identifying alternate handwashing protocols. This qualitative study was independent of the CFP process but conducted in a timeframe to capture and maintain the momentum from the May, 2012 Indianapolis session and serve as a bridge to the 2014 Committee which will be formed later this month.
Respondents were all attendees of the 2012 CFP meeting and included industry, regulatory and academia.
The overarching goal of this study is to seek the 2014 CFP Hand Hygiene Committee's consideration of each recommendation. No direct response is anticipated. The final committee report will be presented at the 2014 session.
1. Significant enhancements in foodservice hand hygiene compliance will more likely come from creative changes in worker motivation than from advances in chemistry, biology, physics or math. Confirm that this broad topic will remain in the purview of the science-oriented Council III.
2. Consider motivating industry and academic research by publishing a statement on acceptable pathogen reduction to qualify for consideration as a suitable substitute for traditional handwashing.
3. Acknowledge that ill customers are a likely source of norovirus for foodservice establishments. Considering the ratio of customers to staff and CDC's Vessel Sanitation experience, that risk is likely significant but a more hidden threat to public health than the ill employee. (Staff with symptoms must continue to be excluded as they too have been proven to be an important source of outbreaks.)
4. Confirm in writing that CDER controls packaged products that make label efficacy claims. Process driven handwashing solutions like extending time and adding friction when soap is unavailable are not within the purview of CDER.
5. Note that without the FDA's signing on to a log 2 pathogen reduction as a standard, the committee could still move forward by considering it "supportive qualitative guidance".
6. Consider listing alcohol as a substitute for water as a cleaning agent when water is not available, provided the process includes friction and soil removal with a single-use paper towel.
7. Acknowledge that convenience plays an important part in hand hygiene compliance and frequency of hand hygiene interventions must match up with soiling rates and locations.
9. A two-step cleanse-sanitize protocol has been approved for use by the U.S. Military, the Southern Nevada Health District (one client, under a letter-of-no objection) and the Clark County Nevada School District. This protocol, with its years of use, third party peer reviewed research and various approvals, should be thoroughly considered by the 2014 CFP Hand Hygiene Committee.
10. Consider noting in the foundation documents of the Hand Hygiene Committee that the need for alternative hand cleansing methods is primarily in water-short environments, thus eliminating most all proposed water-based alternatives.
11. Confirm that Independent research has proven that alcohol hand sanitizers can be formulated to be effective on Norovirus, the number one cause of foodborne illness.
12. Confirm that Emory University's work has proven that human norovirus (HuNoV) is harder to kill than its surrogates. Consider recommending Emory's protocol be the new standard favored for future research. (It uses the "finger pad" method and HuNoV.)
Two insightful notes from survey participants:
“All operators want to do is put the best solution for clean hands at the employees' discretion. Best solution is defined as: The practice that is easiest for employees to do while working, is the most effective in removing soil without aggravating hand health and is the most economical compared to other options.”
“Handwashing process control is like taking your pulse. If it's within the healthy range, keep going. If not, take the corrective action asap. Immediate feedback to staff is more important than volumes of logs. Annual unread/unused reports for a restaurant open 24/7/365 can easily exceed 4,000 pages/year.”