Defining a safe level for handwashing frequency
Norovirus outbreaks commonly raise this question: What is a safe level for handwashing frequency?
If we look to the FDA for answers, the Model Food Code wisely avoids getting over prescriptive, considering all the variables.
The CDC conducted a valuable observational study using the Model Food Code as its benchmark. They concluded 8.6 Handwashes/Employee Hour (HW/EH) were required to be code-compliant, a total of 69 Handwashes per 8 hour shift
This led to other questions: Is the Model Food Code already over-prescriptive or truly risk-based? Would this level of handwashing be in conflict with customer service? In general, a level of 8.6 HW/EH is seen as too much to ask of employees. Regulators generally agree.
More effective use of tongs and wraps can lower the need for handwashing but the basic issue remains. Some situations, like following restroom use, clearly demand a good handwash. A casual touch of the face or hair is a lot less risky yet the Code specifies the same handwash for both. Is that risk-based or inspection based?
A frequency rate target of 8.6 HW/EH discourages reasonable, attainable compliance improvement. It protects the status quo. "Don't let perfect be the enemy of good."
We believe the Food Code in this case should prioritize the risks by establishing categories of High, Moderate and Low. Operators then set up a controllable process based on risk, a process to which they are committed. We will be discussing this at CFP 2014 and will likely propose this change at CFP 2016.