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2014 CFP Hand Hygiene Success: Groundwork for 2016

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.

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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.

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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 600+ 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".

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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.”

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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.

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