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Issue Number: Council I 021


3-304.14 Wiping Cloths, Use Limitation

Issue you would like the Conference to consider

Some state/county regulatory jurisdictions only allow the use of reusable wet wiping cloths to wipe counters/equipment and require they be stored in a chemical sanitizing solution. Many retail establishments across the United States use dry disposable towels with pre-mixed sanitizer supplied in spray bottles in lieu of the wet cloth and bucket method. Some health authorities require that a variance must be applied for to use dry disposable towels with a spray bottle of sanitizer instead of the wet wiping cloths. The Food Code needs to recognize the use of dry disposable towels and a spray bottle of chemical sanitizer solution in lieu of wet wiping cloths stored in a sanitizing solution is an acceptable and equivalent method for wiping down counters and equipment.

Public Health Significance

As long as the disposable towels are disposed of after each use, and the chemical sanitizer solution in the spray bottle meets the concentration specified under 4-501.114, there are no adverse Public Health consequences. This process has been in use extensively throughout the retail food industry without consequence for years. In fact, it can further minimize risks by avoiding the potential build up of organic material associated with the re-usable cloth and bucket method for wipe downs. It also maintains the correct concentration of sanitizer since it is not exposed to dilution and organic buildup. Annex 3, 3-304.14 essentially supports this issue in that it states that dry wiping cloths do not require being stored in a sanitizer solution at all times and disposable wiping cloths avoid the issue of buildup of soil from organic material.

Recommended Solution: The Conference recommends...

that a letter be sent to FDA requesting that section 3-304.14, section (B), be amended to add subsection 3 as follows:

3-304.14 Wiping Cloths, Use Limitation.

  1. (A) Cloths in-use for wiping food spills from tableware and carry-out containers that occur as food is being served shall be:

(1) Maintained dry; and

(2) Used for no other purpose.

(B) Cloths in-use for wiping counters and other equipment surfaces shall be:

(1) Held between uses in a chemical sanitizer solution at a concentration specified under § 4-501.114; and

(2) Laundered daily as specified under ¶ 4-802.11(D); or

(3) Dry disposable towels used in conjunction with a spray bottle of chemical sanitizer solution at a concentration specified under § 4-501.114 are excluded from being maintained in a chemical sanitizer solution as long as the towels are disposed of after each use.

Submitter Information

Name Larry Kohl
Organization Food Marketing Institute
Address 2345 Crystal Drive
Suite 800
Arlington, VA 22202
Telephone 202-220-0659
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