2008 CFP - Sequential Application of Hand Antiseptic for Use in No-Water Situations
2008 III-027
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Title
Issue you would like the Conference to consider
Effective hand hygiene for situations where soap and water are unavailable remains a challenge for food safety. The 2005 FDA Food Code, Section 2-301.16, outlines the parameters for hand antiseptics, but specifies that hand sanitizers "be applied only to hands that are cleaned as specified in § 20301.12." Per Section 5-203.11(C), employees may use chemically treated disinfectant towelettes when food exposure is limited and handwashing sinks are not conveniently available, such as in some mobile or temporary food establishments or at some vending machines. This leaves a gap in the Code for effective hand decontamination in situations where food exposure is limited and handwashing sinks are not available. It has now been found that an effective hand cleansing, equivalent in degerming to handwashing with soap and water as specified in Section 2-301.12(B), can be achieved by sequential use of alcohol-based hand antiseptics, wherein a first application is wiped off with a dry towel, followed immediately by a second application that is allowed to dry as per normal alcohol sanitizer use directions. This protocol is not a substitute for handwashing in stationary facilities where cleaning can be accomplished per 2-301.12.
Public Health Significance
Potential contamination of ready-to-eat foods is increased in situations where access to soap and water are limited or simply unavailable. The new proposed option can significantly increase the level of effective hand degerming in those situations.
Recommended Solution: The Conference recommends...
that a letter to FDA urging the following addition to the Model Food Code:
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 of sequential application of hand antiseptic wherein the first application is treated as a handwash with full scrubbing action and then, while wet, wiped off with a dry towel, immediately followed by a second application which is allowed to dry per standard label instruction.
(i) Said hand antiseptic shall meet requirements of 2-301.16
(ii) Said hand antiseptic shall have supporting test data indicating statistical equivalence to a standard handwash in hand degerming.
Attachments
Submitter Information
| Name | Jim Mann | ||
| Organization | Handwashing For Life Institute | ||
| Address |
1216 FLAMINGO PKWY
Libertyville, IL 60048 |
||
| Telephone | 847-918-0254 | Fax | 847-918-0305 |
| jmann@handwashingforlife.com | |||