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James Mann @ HandwashingforLife®by on

Additional Hand Hygiene Definitions to Enable Improved Employee Hand Cleansing and Management / Monitoring

CFP 2025 Submissions on Handwashing

Issue to Consider: 

For over 20 years the Conference for Food Protection, through recommendations to FDA Food Code has attempted to improve food handlers handwashing to advance food safety and reduce infection. 

Yet published hand hygiene results summarized and presented at an AFDO (Association of Food and Drug Officials (AFDO) webinar series November 22, 20241, showed concerning deficiencies. The ranking order chart demonstrates only 13.3% of handwashes are conducted in accordance with Food Coderequirements (when to wash) and procedures (how to wash). Conversely that means that 86.7% of the time employees are NOT effectively cleaning hands.  Prominent attorneys have stated they “would agree” the data indicates the EMPLOYEE, Person in Charge (PIC) and Permit Holder (PH) would be negligently liable in a foodborne event involving lack of employee handwashing based on the terms “effectively cleaning hands” and “routinely monitoring” handwashing performance.  

Use of an Alcohol-based Hand Rub (ABHR) is a different process of handwashing scientifically proven to be more effective in reducing microbial contamination with lightly or moderately soiled hands2 and has become the standard of care globally for healthcare worker hand hygiene3-5. Food service settings are different than healthcare, as such ABHR should be excluded as the primary mode of hand hygiene in direct cutting or forming of raw meat, poultry, fish, and when bussing or handling soiled items and refuse. Use of paper towel while hands are still wet with ABHR enables removal of soil.

Public Health Significance:

The public health significance is there is more than one way to wash hands at most retail food establishment food handling stations that will help protect the customer from unnecessary contamination by employees and reduce foodborne illness. By defining the term alcohol-based hand rub and limiting its use in a food establishment to workstations that do not cut or form raw meat, poultry or fish, permit holders have another tool on their tool belt to reduce foodborne illness.

In order to clarify the term ‘effectively cleaning hands’, address the disparity, and provide guidance to protect EMPLOYEES, Person in Charge and Permit Holder, “effectively cleaning EMPLOYEES hands” needs to be defined, documented, and verified. Furthermore, in the spirit of reduced transmission of pathogens and foodborne illness prevention, definition and guidance are needed to help the Person in Charge better “Routinely Monitoring the EMPLOYEES Handwashing”.

Recommended Solution: Amend FDA Food Code to add these hand hygiene definitions as appropriate within the current code.

Definition A: “EMPLOYEES are effectively cleaning hands” means:

Effectively cleaning EMPLOYEES hands means: 

  1. Washing hands in accordance with SECTION 2-301.12 HOW TO WASH and
  2. With hands that are lightly or moderately soiled from handling similar foods or materials may wash hands in accordance with the Definition of “Alcohol-based hand rub” a minimum of every half hour (30 minutes).

Definition B: Routinely Monitoring the EMPLOYEES handwashingPf means: 

Person In Charge visually observes and documents employee handwashing or electronically monitors and verifies handwashing data in the following manner:

  1. Minimum of two times per shift (i.e. 4-hour interval) Person in Charge observes, reviews, monitors, and verifies handwashing data 
  2. Takes corrective actions to improve individual or group hand washing in real time based on observation and/or recorded documentation
  3. Maintains records 6-months minimum. 

Definition C: Alcohol-based hand rub means:

Recommended Solution:  Add to Food Code Chapter 1 Definitions in alphabetical order the below language for the term Alcohol-based hand rub.

  1. An approved alcohol-based hand antiseptic consisting of at minimum 60% alcohol and
  2. Specific hand scrub process consisting of:
    1. Application of at minimum 60% alcohol-based hand antiseptic to hands
    2. Friction scrub concentrating on:
      1. fingertips 
      2. between fingers 
      3. claw to paw scrub of palms
      4. friction scrub of wrists and exposed arms if needed.
      5. Completed with thorough single-use paper towel wiping of scrubbed areas.
  3. Except that an Alcohol-Based hand rub shall not be used as a replacement for hand washing or gloving at a food establishment workstation that direct cuts or forms raw meat, poultry, fish, and when bussing or handling soiled items and refuse.

References:

  1. Schaffner, D. W. & Arbogast, J. W. (2024). “New Handwashing Evidence: No Soap? No Water? No Worry!”. AFDO Fresh Take Friday webinar series, November 22, 2024.
  2. Boyce, J. M., & Schaffner, D. W. (2021). Scientific Evidence Supports the Use of Alcohol-Based Hand Sanitizers as an Effective Alternative to Hand Washing in Retail Food and Food Service Settings When Heavy Soiling Is Not Present on Hands. Journal of Food Protection, 84(5), 781–801.
  3. Boyce, J. M., Pittet, D. (2002). “Guideline for Hand Hygiene in Healthcare Settings. Recommendations of the Healthcare Infection Control Practices Advisory Committee and the HICPAC/SHEA/APIC/ IDSA Hand Hygiene Task Force. Society for Healthcare Epidemiology of America/Association for Professionals in Infection Control/Infectious Diseases Society of America.” MMWR Recomm Rep 2002;51 (RR-16):1-45.
  4. Pittet, D. (2009). “World Health Organization guidelines for hand hygiene in health care.” Geneva: World Health Organization website issue.
  5. Glowicz, J. B., Landon, E., Sickbert-Bennett, E. E., Aiello, A. E., deKay K., Hoffmann K. K., Maragakis, L., Olmsted R. N., Polgreen, P. M., Trexler, P. A., VanAmringe, M. A., Wood, A. R., Yokoe D., Ellingson, K. D. (2023). “SHEA/IDSA/APIC Practice Recommendation: Strategies to prevent healthcare-associated infections through hand hygiene: 2022 Update.” Infection Control and Hospital Epidemiology, 44(3):355–376.

Co-Submitters: James W. Arbogast and James “Lee” Budd (presenter), Issue #1439 – submitted on 3Jan2025

NOTES:

Documents submitted (2 types allowed – “Content” and “Supporting”):

  1. Content = The Issue itself as a word doc (see above). “Hand Hygiene Necessary Definitions Issue Summary”
  2. Supporting = “AFDO Webinar Summary Slides Nov2024”. (reference #1 above) 
  3. Supporting = “Boyce & Schaffner Normal Soiling Hand Hygiene Options Lit Review Publication”. (reference # 2 above)
  4. Supporting = “CDC et al Published Guidance Supporting Alcohol-Based Hand Rub as the Primary Hygiene Practice in HC”, Glowicz et al 2023 publication. (reference #5 above)

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