by The Conference for Food Protection is a working body to propose, evaluate and suggest enhancements to the FDA’s Model Food Code. It is structured to provide a representative and equitable partnership among regulators, industry, academia, professional organizations and consumers to identify problems, formulate recommendations, and develop and implement practices that ensure food safety. The primary mechanism to achieve this is a biennial meeting, scheduled for April 16-21, 2004 in Chandler Arizona.
The vehicle to propose changes to the model Food Code is the Issue Submission process. DEADLINE for Issue Submission: midnight February 2, 2004 PST.
Active Managerial Control: Beyond No Bare-hand Contact
The No Bare-hand Contact issue has dominated the agenda at the past three Conferences for Food Protection without resolution. We believe a statement from the floor on the final day of the 2002 meeting provides the foundation on which to draft an effective resolution at the 2004 meeting.
This is Richard Barnes’ verbatim clarifying response to a question from the floor before the final vote on the No-Bare Hand Contact issue that had been agreed by the working committee at the 2002 Conference For Food Protection.
The Chair: “The Chair recognizes Richard Barnes.”
Richard Barnes (FDA): “Richard Barnes, FDA. Thank you. There are a lot of issues here that we’re talking about, but I guess I’m going to talk primarily about the issue of Active Managerial Control of the risk factors.”
“We have reached consensus, I believe, among all of us that the goal of the retail program is managerial control of the risk factors that lead to foodborne illness. What we have done with this issue is taken language that existed in the previous Code in an annex and put it directly into the Code language itself which puts the onus on the operator of an establishment to manage the risk factor in his establishment which is what we say is the goal of this program.”
“If we are going to say that the manager is responsible for managing those risk factors, then we also must follow that in the language of the Code. We do not believe that there is any difference in what we have done previously in exception by taking the language from the annex and putting it in the Code and putting it back onto the manager of the establishment to do it, for him to maintain a plan, to develop a plan, to implement a plan.”
“Our goal as regulators then is to insure that he implements that plan, takes appropriate compliance actions when they do notâ€â€to go back to no bare-hand contact.”
“So, if truly our goal of the retail program is Active Managerial Control of the risk factors in the establishment, this is one issue that puts it directly back on the manager to control.”
Richard Barnes , has been the Director, Division of Federal-State Relations, Food and Drug Administration since August 1995. At FDA, he chairs the Retail Food Program Steering Committee and is a FDA representative to the Coordinating Body of the National Food Safety Systems project and other Federal-State initiatives.
Issues under development:
- Clarity in Accountabilities
- Terminology Consistency – Handsink vs. Lavatory
- Effective Uses of Alcohol-based Hand Sanitizer
- Monitoring the Kitchen Handwash: A HACCP & AMC priority
Richard Barnes, Director
Division of Federal-State Relations (HFC-150)
5600 Fishers Lane, Room 1207
Rockville, MD 20857
E-mail: rbarnes@ora.fda.gov
Mr. Barnes’s statement was the inspiration for The Handwashing For Life Institute’s creation of its Hands-On Process.
