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FDA Food Code Hand Hygiene Definitions

Jim Mann's picture

Words conjure up predetermined perceptions. 

Handwashing creates an expectation of contaminant removal with soap and water. Protocols that remove soil without water, such as moistened towelettes and those using alcohol hand-sanitizer as a soap/water-substitute, do not qualify as hand washes.

Operators need to know that there are more options available in how to decontaminate hands, beyond that covered in the Cleaning Procedure of the Food Code Section 2-301.12 There are variables within each step and combination protocols that best fit a myriad of individual situations.

Food Code Section 2-301.12 - The Food Code Handwash

(A) " ... shall clean their hands... for at least 20 seconds, using a cleaning compound in a handwashing sink that is equipped as specified under § 5-202.12 and Subpart 6-301. Cleaning procedure... Rinse under clean, running water... Apply an amount of cleaning compound... Rub vigorously for at least 10-15 seconds... Thoroughly rinse... dry using a method as specified under § 6-301.12."

Enhancements in performance of the basic handwash technique (§ 2-301.12) can be achieved by adding time, friction (as in adding a nailbrush step or the use of a paper towel to dry), and better choices from the vast array of cleaning compounds and materials available.

A final step of antiseptic application can be added as another combination option. This would open up a selection of handwashes from which the operator can choose based on documented effectiveness and risk.

A similar option would be unlocked with a simple differentiating definition of hand cleansing. The use of towelettes is an example of a process better positioned under the generic of hand cleansing.

Public Health Significance

Clarity in process descriptions between handwashing and hand cleansing opens more doors to research and the development of products and processes best suited to serve the public in the many away-from-home situations in which they choose to eat and drink.

Recommended Solution: The Conference recommends...

that a letter be sent to the FDA recommending the addition of two generic definitions to the 2013 Food Code in Section 1-201.10, as follows (new language is underlined):

  1. "Handwashing" means the removal of contaminants with soap and water.
  2. "Hand cleansing" means the removal of contaminants with means other than soap and water.

What's your view on this proposed addition:

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