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FDA’s Model Food Code Is Challenged By Science

Bureaucracy buries addition to public health

A handwashing-without-water protocol has perplexed the FDA and its Conference for Food Protection (CFP) for 12 years, unable to resolve it at six successive biennial sessions. This recurring issue, Hand Cleanse-Sanitize Protocol Not Requiring Running Water, will again be presented at the 2018 CFP in Richmond Virginia, April 16-20.

The two-step process now serves as a consideration for farm use as part of FSMA’s Produce Rule and has two more years of successful use by the Clark County School District (Las Vegas) when protecting students during periods of water-outages when serving food. These effective applications were based on science rather than Food Code approval.

Handwashing issues and any hope of a CFP Hand Hygiene Committee were taken off the table at Conference For Food Protection 2016 in Boise Idaho as the regulatory community decided that a definition of a handwash could not be reached thus any proposed alternative protocol innovations could not be measured, considered or approved. Research for two years has been dealt a blow. The official CFP Hand Hygiene Committee was dissolved and a motion to renew it was rejected as neither the FDA nor CDC currently could say what a handwash is or does.

Reasons to reject this Hand Cleanse-Sanitize Protocol Not Requiring Running Water have ranged from lack of research and use-history to the lack of CDER approval. Some regulators mistakingly interpreted this as an issue of supporting a commercial product when the process was given a name of SaniTwice®  and trademarked by Handwashing For Life. This was done to define, normalize and control the process for training, much like the IAFP did when trademarking their food safety icons, free for everyone to use.

The FDA, CDC and CFP Council III have ignored the fact that SaniTwice is just a process and works for all approved hand sanitizers (considered hand antiseptics by regulatory). The reality appears to be a deep FDA or CDC bias in foodservice against these hand sanitizers while they have been credited with saving untold lives in healthcare for decades.

The alleged bias ends up restricting the use of SaniTwice at outdoor events and emergency situations, even at Petting Zoos, although there are unofficial accounts of it being deployed by CDC teams in Haiti and in other disaster relief efforts.

For a more detailed history of this chronic issue, visit: http://handwashingforlife.com/blog/mike-mann/sanitwice-celebrating-10th-anniversary

For a simple demonstration visit: http://handwashingforlife.com/handsonsystem/sanitwice/sanitwice-core-handwash

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SaniTwice® for Catered Events

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

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

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