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Defining a safe level for handwashing frequency
Norovirus outbreaks commonly raise this question: What is a safe level for handwashing frequency?
If we look to the FDA for answers, the Model Food Code wisely avoids getting over prescriptive, considering all the variables.
The CDC conducted a valuable observational study using the Model Food Code as its benchmark. They concluded 8.6 Handwashes/Employee Hour (HW/EH) were required to be code-compliant, a total of 69 Handwashes per 8 hour shift
This led to other questions: Is the Model Food Code already over-prescriptive or truly risk-based? Would this level of handwashing be in conflict with customer service? In general, a level of 8.6 HW/EH is seen as too much to ask of employees. Regulators generally agree.
More effective use of tongs and wraps can lower the need for handwashing but the basic issue remains. Some situations, like following restroom use, clearly demand a good handwash. A casual touch of the face or hair is a lot less risky yet the Code specifies the same handwash for both. Is that risk-based or inspection based?
A frequency rate target of 8.6 HW/EH discourages reasonable, attainable compliance improvement. It protects the status quo. “Don’t let perfect be the enemy of good.”
We believe the Food Code in this case should prioritize the risks by establishing categories of High, Moderate and Low. Operators then set up a controllable process based on risk, a process to which they are committed. We will be discussing this at CFP 2014 and will likely propose this change at CFP 2016.
In a similar European study, the University of Wales, under the direction of Dr. Christopher Griffith, found that food workers washed their hands adequately in 9% of those instances in which they touched their face or hair and in 25% of those instances in which they touched potentially contaminated objects.
Some operators have resorted to handwashing by the clock. While positioned as a fallback, it tends to disconnect employee behavior from the need to wash. “I just washed, I’m golden for the next 20 minutes.” Handwashing For Life encourages by-the-clock handwashing until better behavior driven process control methods can be instituted.
Operator approximations were researched recently with 25 QA managers. They selected a minimum of 3 HW/EH, remembering that these interpretations are driven by employee behaviors/actions. The reference to time in this case is to normalize the data and provide a method to track throughout a shift in the spirit of Active Management Control and HACCP.
Regulatory readings were taken at the Southwest Environmental Health Conference in early 2013. Thirty four respondents provided a median of 21.5 hand washes per 8 hour shift. Their range was 5 – 85 per 8 hour shift. While that range looks quite unbelievable, it could reflect a likely reality at the low end and a strict following of the food code at the other.
When researching the handwashing frequency issue, we assume that all hand washes are thorough, at least 15 seconds with soap and warm water flowing at 2 gpm and dried with a single-use paper towel. Handwashing For Life deals separately with fixing the hand wash quality question.
Recommendation: Determine your actual HW/EH in a sample of your restaurants. From there determine the value in solving the handwashing issue to align the science-based risk with the corporation’s tolerance for risk and image damage. It may be your lowest cost liability insurance. Might your leadership on this issue lower your insurance rates?
