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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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Holiday Catered Norovirus

Norovirus

Outbreak Sickens 75 at Minnesota Banquet

Might the norovirus have entered the catered event via an ill worker, perhaps symptom-free? Or a guest? Or from contact with a high-touch surface contaminated the week before?

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Kindling a Culture of Cleanliness

Come Compete in the Handwashing For Life Olympics

Handwashing For Life® overcomes underwashing of hands and high-touch surfaces by integrating a series of best practices. At the Food Safety Consortium, being staged at the Schaumburg Conference Center, on December 4th & 5th, attendees will learn how to assess their hand hygiene related risks and assemble a sustainable solution. The program is a driver to establish a culture of cleanliness, one handwash at a time.

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What Constitutes a Handwash?

Blending available resources into an effective protocol.

From a Food Code perspective there is but one handwash. We like to think of it as a minimum and one of perhaps many. Handwashing For Life designates a soap-water 15 second hand wash, with a 2.0 gpm flow of warm water and paper towel drying, as its Core Hand Wash. Depending on risk, adjustments are made at the operator level to exceed the minimum where required.

Technically, a handwash is blend of four factors, four resource categories:

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Training Handwashing: A Sisyphean Task

Sometimes training handwashing feels futile and frustrating. For the professional who daily works through this repetitive task, we found a parallel image from back in Greek mythology. Sisyphus, the king of Corinth, was charged with rolling a stone uphill for eternity.

Luckily for our dedicated handwash trainers, their toil has a more rewarding outcome, especially when they introduce performance standards and incorporate success into staff rewards.

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The Case For Added Hand Wash/Cleanse/Sanitize Protocols

Light duty hand cleaning may increase frequency

The Model Food Code serves as a minimum standard, providing a foundation on which operators can build solutions tailored to their operation and their assessment of risk.

There is an unresolved handwashing dilemma in the Model Food Code in that it prescribes the same wash whether the hands are very lightly contaminated (visibly unsoiled) or are heavily soiled. The identical 15 second scrub time is specified for both.

Intuitively this doesn't make sense to the kitchen staff. Some, perhaps many, compensate by not washing at all when hands are seen as unsoiled. This likely accounts for over half of the 8.6 hand washes per employee hour identified in a CDC observational study as the number required to conform to the Model Food Code. (J Food Prot. 2006 Oct;69(10):2417-23)

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HandsOn™ System

HandsOn System

5 steps to convert underwashing to under control. Set and track your risk-based ServeReady® Hands and TouchReady® Surface standards.

SaniTwice® for Catered Events

SaniTwice for Catered Events

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

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