Handwashing has few standards because there is no specification for a clean hand. Soil has no standards because it varies so widely and so little is known about soil adhesion to human skin and its transfer profile. Operators have to sift through the grey science and determine what black-and-white regimens will be used as they are 100% accountable to serve safe food according to our legal system- the strict liability principle.
With this background the Model Food Code is best served by not being overly prescriptive and use every opportunity to speak in terms of ranges and keep regulators focused on their consultative role rather than their enforcement side.
Is their a way to make this hand hygiene area of the Model Food Code less prescriptive and help operators understand their own risk-based options?