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CFP 2014

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2014 CFP Hand Hygiene Success: Groundwork for 2016

A recommendation of “No Action” at the CFP (Conference for Food Protection) can be viewed as a strike out and to continue the baseball metaphor, Handwashing For Life went 0 for 7 on the issues submitted in 2014. We thought at least one would be accepted but all were presented as a foundation for 2016. In that context our efforts were well received and rewarded with calls to continue our quest for codifying hand hygiene innovations. Lively discussion demonstrated the need for changes but the system favors the status quo.

Non-voting Council Members, the FDA and CDC, sharply tilt the decision making power. A timely sound-bite can end Council discussion. Who of the regulatory Council Members are willing to vote against the non-voting regulatory Members?

Here is our interpretation of what happened, why and how each sets up for 2016.

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Hand Cleanse-Sanitize Protocol Not Requiring Running Water

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.

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The Hand Cleaning Factor of Paper Toweling

Better handwashing protocols specify disposable paper towels or continuous towel systems as they add a valuable friction factor, significantly increasing cleaning, perhaps even doubling it when measured in log reduction. This is a benefit unavailable to all styles of air dryers, warm air or air blade. For this reason the Department of the Army in Technical Bulletin (TB) MED 530 specifies either disposable paper or continuous fabric roll towels be used at all handsinks used by employees.

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Lower Handwash Water Temperature Minimum

Open the door to convenience, compliance and water savings.

The handwashing minimum water temperature in Section 5-202.12 of the Food Code, states " ... equipped to provide water at least 38°C (100°F) ..." This is interpreted by both operators and inspectors as the definitive base for effectiveness of the handwash while the goal is largely user comfort. All temperatures between a common ambient and 107°F are sufficiently comfortable. As to cleaning effectiveness, the body's 98.6°F quickly heats the soap and initial scrub-water. 

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Expansion of Scheduled Inspections

30,000+ health inspectors/assessors have an opportunity to be more focused on prevention in keeping with the principles of Active Managerial Control (AMC) and in the spirit of the Food Safety Modernization Act (FSMA).

A condition for improved learning for food handlers and their managers can be achieved by scheduling inspections rather than expecting food service managers to learn in what often feels like a raid, especially when key managers are missing.

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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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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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Hand Hygiene Survey - Recommendations

Executive Summary:

The 12 questions, delivered in three short survey segments, were designed to raise awareness of some unaddressed sub-issues remaining from the 2012 Conference For Food Protection's Hand Hygiene Committee, charged with identifying alternate handwashing protocols.  This qualitative study was independent of the CFP process but conducted in a timeframe to capture and maintain the momentum from the May, 2012 Indianapolis session and serve as a bridge to the 2014 Committee which will be formed later this month.

Respondents were all attendees of the 2012 CFP meeting and included industry, regulatory and academia. 

The overarching goal of this study is to seek the 2014 CFP Hand Hygiene Committee's consideration of each recommendation. No direct response is anticipated. The final committee report will be presented at the 2014 session.

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Result Summary: Hand Hygiene Pre-Committee Survey #2

An independent gathering of perspectives for consideration by the 2014 CFP Hand Hygiene Committee ...

The 2014 CFP Committee charge and composition will not be finalized until the CFP Board meets in August. The intent of this independent survey is to make use of the three months where no official committee exists.

Two rounds are down.The final 4 questions will be sent in mid July. Participant suggested questions are welcomed through July 6th.

Qualitative interpretations for Survey 2 ...

  1. Solid agreement. This question came from a survey participant with considerable regulatory experience. He felt that without the FDA's signing on to a log 2 pathogen reduction as a standard, the committee could still move forward by considering it "supportive qualitative guidance."
  2. Without some agreed reference point, finding alternatives would not be feasible.
  3. Participants appear unwilling to restrict the committee charge to soap and water variables, even though evidence suggests a strong regulatory bias.
  4. Convenience plays an important role in compliance. Solutions which take the worker away from the work station are of little interest to many. Some respondents, 28.3 %, likely feel that inconvenience can be overcome with manpower and/or training adjustments.
  5. Responses are fairly clear cut. In the context of hand hygiene, removal of pathogens is equal to killing them.
Read more about Result Summary: Hand Hygiene Pre-Committee Survey #2

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Result Summary for Survey: Hand Hygiene Pre-Committee

Hand Hygiene Pre-Committee

A special thanks to the 81 who responded. Please review round one results below.

We have 8 remaining questions available to help the CFP Hand Hygiene Committee before its re-formation in August. Round two will be sent out in early June. Please send your candidate questions.

There is a definite response pattern making these results generally easy to interpret.

Question 4 required attendance at a particular session, resulting in a high count for the "neutral" option.  Read more about Result Summary for Survey: Hand Hygiene Pre-Committee

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