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Food Code

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The Unwritten Food Code

(Submitted by a former State Regulator after reading this blog series in preparation for the 2014 biennial Conference For Food Protection (CFP))

The ‘prescriptive' nature of the food code is now being understood by local health officials as: 'The health authority prescribes how a task is done and the operator is responsible to do the task as prescribed.' This interpretation, which differs from the traditional approach of Food Code which defined the minimum standard needed and operators were encouraged to innovate to complete the task at a standard that exceeded the minimum required by regulation.

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Jim Mann's picture

The Case For Added Hand Wash/Cleanse/Sanitize Protocols

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)

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Patents, Proprietary Resources & The Model Food Code

How should innovation be treated in a regulated environment?

SaniTwice® as an alternative protocol for soap/water handwashing was rejected by at least one of the Conference for Food Protection (CFP) Council III delegates because SaniTwice works best with patented Purell VF-481. This is based on its unique effectiveness on norovirus, the leading pathogen in foodborne outbreaks.

In reality, the SaniTwice protocol potentiates all alcohol hand sanitizers as it simply adds a cleaning step.

There are three shortcomings in the Model Food Code that are exposed in this 7 year pursuit of a protocol immediately accepted by the US military, for whom it was originally developed:

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