New posters created to mark 10 years of seeking Food Code approval
“Bookend” posters have been created to mark two important milestones. In 2006 a new hand hygiene protocol came onto the USA food safety scene from its original military use in the Middle-East, Jordan to be specific. http://handwashingforlife.com/handsonsystem/sanitwice
In 2016, after garnering another research accolade, the innovation team will again look to the CFP and the Model Food Code to assess this protocol one more time in the context of public safety for all water-compromised locations serving or handling ready-to-eat foods. http://handwashingforlife.com/blog/mike-mann/farmhands-field-handwash
You are invited to download and pass along these free posters to produce growers, military offices, health departments who license temporary foodservice venues, petting zoo operators, county fairs, sporting events, schools who suffer temporary water-outages, catering operators, portable bars, boil-water situations, cruise line excursion operators, trains, food trucks, etc . . . anyone who doesn’t want to compromise hand cleanliness just because they have no water.
The current Oak Leaf Farm e-coli outbreak is a case in point for added hand cleanliness via a convenient no-water SaniTwice station. http://www.ct.gov/dph/cwp/view.asp?Q=578748&A=4820
The decision to use SaniTwice or not should be based on risk and common sense. Where there is no water, this protocol is not replacing a water-wash. It is replacing a non-wash with an uncompromising yet convenient hand cleansing method. These operators have the primary responsibility to protect the public, not the FDA and its local representatives. The SaniTwice protocol has been tested more and often against higher standards than handwashing itself. It works with any good, 70% alcohol hand sanitizer. (Handwashing For Life does not sell any hand sanitizer brand, just the science of safer hands.)
The Middle-East Connection
In 2003 the Coalition Provisional Authority and the Iraqi Ministry of Interior finalized plans for a new Iraqi Police training facility in Jordan. They contacted the Cini•Little International kitchen consulting/design firm in search of proper handwashing for remote locations where running water was unavailable: http://www.iraqcoalition.org/pressreleases/20031009_Oct-03-PolicetrngJordan.htm
Bill Eaton, Chairman of Cini•Little, contacted Handwashing For Life who then developed a protocol using hand sanitizer in a 2-step process that was immediately approved for its intended use. Interest from other water-compromised situations in the USA led to the protocol being given a name, SaniTwice®, http://handwashingforlife.com/blog/jim-mann/sanitwice-process-registration, and tested by an independent laboratory. The study was reported in the Journal of Food Protection, “… equivalent or superior to handwashing.” http://handwashingforlife.com/handsonsystem/sanitwice
The CFP Chronology
In 2006, SaniTwice was presented at the Conference for Food Protection for the first time, Issue III-022, to seek either codification or a national variance. It was discussed and recommended for “No Action”, without any direction for future development. It was presented as an intervention very much like an alcohol towelette that was already in the Food Code. This SaniTwice discussion included regulatory comments that suggested, more like threatened, that these towelettes were likely to be removed from the Code and therefore served as a poor standard.
In 2008, in San Antonio, Texas, more research had been conducted and thus was again presented. The issue was accepted by Council III as amended but then extracted by the Texas delegate and rejected by the assembly, without any reason other than “needed more research”. CDC kibitzers were noted in the scurry to help Texas bring down a protocol that fully passed the 21 member council of experts earlier in the Conference. Non-voting members, the FDA and CDC, carry the biggest sticks in the entire CFP process.
In 2010, SaniTwice, now armed with more research and years of field experience, was again rejected, this time with the non-voting voice of the CDC claiming CDER had to approve. Nothing about CDER had been raised in the 2006 and 2008 rejections. The status quo was obviously fighting back but without a scientific basis. The science was on the side of SaniTwice. A CFP hand hygiene committee was formed in lieu of a decision.
In 2012 and 2014 it was just more of the same, complete with another 4 years of go-no-where Hand Hygiene Committee work. The Council discussions were clouded by the myth of CDER and thus the Council was unwilling to approve, knowing the decision would be the same as that in 2010.
Boise Idaho, 2016
It is rumored that the Hand Hygiene Committee has again been unsuccessful in resolving the no-water SaniTwice issue and issue III-003 is a recommendation to disband the committee. Handwashing For Life, agrees totally with this recommendation because of the trail of regulatory resistance and the inability to clear the bureaucratic CDER hurdle. The FDA’s Model Food Code defines handwashing in very narrow terms to facilitate their periodic observational audits. In reality the method selected must match the situation: http://handwashingforlife.com/blog/jim-mann/choose-your-handwashing-regi...
The “When to wash” section of the Code is not prioritized by risk thus increasing the expectations to observe handwashing at the demoralizing and unworkable 8.6 handwashes per employee hour, 8.6 HW/EH. (Journal of Food Protection, Vol. 69, No. 10, 2006, Pages 2417-2423.)
The answer to codification is recommended in a series of short interviews with former FDA Associate Commissioner Dr. David Acheson: http://handwashingforlife.com/blog/jim-mann/resolving-inherent-conflict-between-innovation-and-model-food-code
Handwashing For Life’s Founder and Chief Scientific Officer, Jim Mann, will again bring SaniTwice to the floor in Boise, Issue III-010, to complete the decade of discussion. Of course we again have new research to consider. This time a study by Emory University calling out SaniTwice as a solution for the FSMA Produce Rule’s field handwashing in produce harvesting situations. http://handwashingforlife.com/blog/mike-mann/farmhands-field-handwash. They refer to SaniTwice as a "Two-step ABHS” method, again in the Journal of Food Protection. The two-step ABHS intervention led to significantly lower concentrations of coliforms and Enterococcus spp. than the pumice soap and label-use ABHS interventions (P < 0.05) and was the only intervention to yield significantly fewer samples with E. coli than were found in the control group (P < 0.05).
“Third time’s the charm” didn’t work out so Handwashing For Life is doubling down with a sixth try. If you are in Boise on April 17-20, stop by Council III and help create an environment of open-mindedness and innovation. From their mission statement: FDA is also responsible for advancing the public health by helping to speed innovations.