Hand Antiseptic Use During Emergency Situations Inhibiting Hand Wash Water

CFP 2025 Submissions on Handwashing

Issue to Consider:

Hand hygiene is a critical step in fighting disease, especially foodborne pathogens. In food handling settings, washing hands with soap and water is the required primary method for performing hand hygiene. In other settings, such as healthcare, alcohol-based hand sanitizers (aka hand antiseptics) are the preferred method of hand hygiene when hands are not visibly soiled (1).

The performance of hand antiseptics as a means to reduce pathogens on hands of foodservice workers has been critically assessed in a published 2021 literature review (2). Those authors highly experienced in hand hygiene conclude that “Hand washing and alcohol-based solutions are both effective when used separately” and that “Alcohol-based solutions are better than soap when soil is light to moderate”. A 2024 laboratory-controlled study shows that both hand washing and hand antiseptic effectively reduce germs on hands and reduce transmission from cleaned hands to food (3). Furthermore, they found a hand antiseptic combined with a paper towel (as a means to remove soil) demonstrates superior efficacy in reducing bacterial load and minimizing pathogen transfer to food items.

In certain emergency situations, such as boil water advisories, access to clean potable water can become compromised. Water contamination and natural disaster challenges to water quality are on the rise in the US. In those circumstances restaurants are trying to stay open to help their community, and they would often rather use the limited trustworthy, clean water they have for other needs besides handwashing. Draft guidance issued by a Conference for Food Protection Working Committee (4) recommends in these situations setting up a temporary handwashing station, comprised of a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). This container can then be filled with water, either from bottled water source or pre-boiled water that has cooled.

Public Health Significance:

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 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 water (4).

Currently as written, the FDA Food Code does not allow for use of hand antiseptics in lieu of washing hands with soap and water. However, during emergency situations, such as boil water advisories, use of hand antiseptics as the primary means of hand hygiene is recommended as outlined by the CFP Guidance Document, if the local regulatory authority has approved the plan. This is not overly clear in the FDA Food Code. Clarifying this allowance in the FDA Food Code will prevent situations where individuals in emergency operations are potentially washing hands with contaminated water to be compliant with FDA Food Code requirements.

Recommended Solution:

Amend FDA Food Code 2-301.16 (Hand Antiseptics) as follows:

(3) Be applied only to hands that are cleaned as specified under § 2-301.12 Pf , unless pre-approved by the REGULATORY AUTHORITY in the PERMIT HOLDER’s written emergency operating plan for emergency situations where water service is disrupted, and employees do not contact exposed, ready-to-eat FOOD with their bare-hands.

References:

1. 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.
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. 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.
4. 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.pdfNotes from Submission

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

1. Content = The Issue itself as a word doc (see above).
2. Supporting = CDC Alcohol-Based Hand Antiseptic Fact Sheet.
3. Supporting = Boyce & Schaffner Lit Review Publication Referenced.
4. Supporting = AFDO Webinar Summary Slides Nov 2024 (summary of ID Week Poster referenced).