CFP 2025 Submissions on Handwashing
Issue to Consider:
Alcohol-based hand antiseptics (ABHA), also known as hand sanitizers or in healthcare as hand rubs, can be used quite effectively1-3, especially by doubling a normal dose and adding the friction of a paper towel (PT) finish4-7. Together, this ABHA x 2 + PT provides a simple, convenient and highly effective choice for those operators seeking to lower their risk of an outbreak. The combined pathogen kill and cleaning factors yields up to approximately a Log 5 reduction6-7. In 2009 Clark County Nevada Schools chose to use a similar ABHA handwash to continue food service during water outages. Their protocol, still in use approximately 15 years later, is ABHA x 2 + PT + a second application of ABHA.
The performance of hand antiseptics to reduce pathogens on hands of foodservice workers has been critically assessed in a published 2021 literature review8. The authors conclude: “Alcohol-based solutions are better than soap when soil is light to moderate”. A 2024 laboratory-controlled study shows both hand washing and hand antiseptic effectively reduce germs on hands and reduce transmission from cleaned hands to food.6 They found that the ABHA x 2 + PT handwash demonstrated superior efficacy in reducing pathogens and minimizing their transfer to food, fresh melon.
Handwashing guidance “when a facility has no operational handwashing sinks, but an alternative handwashing facility can be set up” was issued by a Conference for Food Protection Working Committee9. In those temporary situations they recommend setting up of a temporary handwashing station, comprised of a clean and sanitized container to hold and dispense water (e.g., a sports style water cooler or a food grade bucket with a spigot). The ABHA x 2 + PT handwash avoids sanitation risks in transferring of potable water and potential hand contamination from the nearly uncleanable, manual plastic spigots. The lower water flows from this type of makeshift setup are also likely to result in skin dermatitis because of poor rinsing of the soap.
In situations where access to potable water via temporary handwashing stations is not possible, the CFP Guidance Document advocates for ceasing all food preparation operations and switching to the sale of pre-packaged foods. During these situations, the CFP Guidance Document advocates for use of an FDA approved alcohol-based hand sanitizing hand antiseptic in lieu of handwashing with soap and water9. Currently, the FDA Food Code does not allow for use of the ABHA x 2 + PT handwashin lieu of washing hands with soap and water at temporary events.
Public Health Significance:
Safe food and beverage service requires effective handwashing and is expected by the away-from-home public even when attending temporary events. The service is commonly located at distances well away from a plumbed handsink making it practically impossible for the staff to wash their hands without leaving the food and cash box unguarded. Without readily available handwashing, food service gloves cannot be changed hygienically. The temporary event employees very rarely experience heavy visible soiling in these temporary locations; however, they are often exposed to transient invisible microbes that may cause infection without effective hand hygiene at key moments.
Recommended Solution: Amend FDA Food Code 5-203.11 Handwashing Sinks
- (A)
- (B)
- (C) When food exposure is limited and handwashing sinks are not conveniently located, such as at outdoor events, mobile or temporary food service, employees may use a non-handsink regimen of washing hands with alcohol-based hand antiseptic wherein the application is treated as a handwash with full scrubbing action for 20 seconds and then, while wet, wiped off with a paper towel.
- (1) Said hand antiseptic shall meet requirements of 2-301.16.
- (2) Said hand antiseptic shall have supporting in vivo test data on hands indicating antibacterial statistical equivalence to a standard handwash.
References:
- 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.
- Pittet, D. (2009). “World Health Organization guidelines for hand hygiene in health care.” Geneva: World Health Organization website issue.
- 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.
- Edmonds, S. L., Mann, J., McCormack, R. M., Macinga, D. R., Fricker C. M., Arbogast, J. W., Dolan, M. J. (2010). “SaniTwice: A Novel Approach to Hand Hygiene for Reducing Bacterial Contamination on Hands When Soap and Water Are Unavailable”, Journal of Food Protection, 73(12), 2296-2300.
- Fabiszewski de Aceituno, A., Bartz, F. E., Hodge, D. W., Shumaker, D. J., Grubb, J. E., Arbogast, J. W., Davila-Avina, J., Venegas, F., Heredia, N., Garcia, S., Leon, J. S. (2015). “Ability of Hand Hygiene Interventions Using Alcohol-Based Hand Sanitizers and Soap To Reduce Microbial Load on Farmworker Hands Soiled during Harvest”, Journal of Food Protection, 78(11), 2024-2032.
- Arbogast, J. W., Comstock C., Beausoleil, C. M., Buckley, D. A., Lyon, S. A., Marsden, J., Schaffner, D. W. (2024). “Comparative Efficacy of Alcohol-Based Hand Rub vs. Hand Wash by an In Vivo Cross-Contamination Test Method”, IDWeek 2024 conference, poster #324.
- 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.
- 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.
- Conference for Food Protection (2014). Emergency Action Plan for Retail Food Establishments.
Available at: https://www.foodprotect.org/media/guide/Emergency%20Action%20Plan%20for%20Retail%20food%20Est.pdf
Co-Submitters: James W. Arbogast (presenter) and James “Lee” Budd
NOTES:
Documents submitted (2 types allowed – “Content” and “Supporting”):
- Content = The Issue itself as a word doc (see above). “Hand Hygiene at Temporary Events Issue Summary”
- Supporting = “CDC et al Published Guidance Supporting Alcohol-Based Hand Rub as the Primary Hygiene Practice in HC”, Glowicz et al 2023 publication. (reference #3 above)
- Supporting = “AFDO Webinar Summary Slides Nov2024” (summary of ID Week Poster reference #7 above). Note – The ID Week Poster itself was too large of a file to submit.
- Supporting = “Boyce & Schaffner Normal Soiling Hand Hygiene Options Lit Review Publication in JFP”. (reference # 8 above)
Comments: “James “Lee” Budd is a co-submitter. We both plan to attend CFP March 2025 & I plan to present it. We have consulted with other knowledgeable, experienced people to refine this issue; they also support making the proposed improvement to the Food Code.” This was near the max number of characters allowed (only 5 characters remaining).
Issue #1446 – submitted on 3 Jan 2025