Clean hands from the petting zoo to the Iditarod, from farmer’s markets to trade shows and elegant receptions
Food service situations with compromised potable water supply are many and growing as operators respond to the public's demand to have safe food convenient to their daily trail. This results in food being prepared and served in venues without running water for handwashing. Gloves are not the full answer as when they are damaged or contaminated or a task change is required, there is no reasonable option to clean hands between glove changes.
A range of compromised water systems were approved by jurisdictions around the country based on the presence of water rather than its effectiveness. The flow rate in these options is normally nothing close to the effective flow rate of 2.0 gallons per minute, specified in the Uniform Plumbing Code (UPC). There is no supporting effectiveness data for any of these water-compromised variations, including the $5,000+ low-water flow portable handsink solutions.
The most common interpretation of an "approved method" for handwashing at venues without running water is a jug of water actuated by manually depressing a release button or lever, a cleaning agent, toweling and a waste receptacle to catch wastewater. Inconvenience limits use.
A cleanse-sanitize protocol was developed for the US Military in 2006 and picked up by special water-short venues in the Southern Nevada Health District, including use by Clark County Schools during water outages. Along with years of use, several independent research studies have been added, confirming the cleanse-sanitize antimicrobial effectiveness against bacteria and viruses.
Separate studies also identify three hand sanitizers effective on norovirus, the best of those three was selected by Clark County and other noro-concerned operators like the cruise ships and the world's largest 5 star resort - the Venetian and Palazzo properties. This protocol's superior convenience elevates compliance.
Under the 2013 FDA Food Code, Subparagraph 2-301.16 (A)(3) requires hand antiseptics "Be applied only to hands that are cleaned as specified under § 2-301.12.Pf"
It has been demonstrated, documented and published in the credible, peer-reviewed, Journal of Food Protection, that effective hand cleansing, "equivalent or superior" to handwashing with soap and water as specified in Section 5-203.11, can be achieved by applying an excess of alcohol based hand sanitizer as the cleaning agent, scrubbing for 15 seconds, wiping on a single-use towel, followed by an application of alcohol based hand sanitizer following normal label usage instructions.
The latest testing of this hand cleansing/degerming technique shows it to be effective in the presence of organic food soils. This adds an additional safety factor to support incorporation of the method into food safety practices.
This protocol is not a substitute for handwashing in stationary facilities where cleaning can be accomplished per Section 2-301.12. The same is true for the use of chemically treated disinfectant towelettes per Section 5-203.11(C).
Public Health Significance
Potential contamination of ready-to-eat foods is increased in situations where access to running water is limited or unavailable. The new proposed option increases the odds of effective hand degerming in those situations, including its use between single-use glove changes at catered events.
Recommended Solution: The Conference recommends...
a letter be sent to FDA requesting the 2013 Food Code be amended as follows (new language underlined):
5-203.11 Handwashing Sinks
(D) When food exposure is limited and handwashing sinks are not conveniently located, such as at outdoor events, mobile or temporary food service, and some vending machine locations, employees may use a regimen using hand antiseptic as the cleansing agent wherein this step is treated as a handwash with full scrubbing action for 15 seconds and then, while wet, wiped off with a single-use paper towel, immediately followed by a second application which is allowed to dry per standard label instruction.
(1) Said hand antiseptic shall meet requirements of Section 2-301.16.
(2) Said hand antiseptic shall have supporting test data indicating statistical equivalence to a standard handwash in hand degerming.