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)