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Issue Number: Council I 036
Issue you would like the Conference to consider
To designate Section 5-202.12 (A) of the 2009 FDA Food Code as a Core Item, thereby changing the designation of delivery of water at a temperature of at least 38oC (100oF) through a mixing valve or combination faucet from a Priority Foundation to a Core Item.
Public Health Significance
FDA Food Code Chapter 5 [Plumbing, Water and Waste] Section 5-202.12, Handwashing Sink, Installation, paragraph (A), recommends that, "A handwashing sink shall be equipped to provide water at a temperature of at least 38oC (100oF) through a mixing valve or combination faucet..." This provision is currently designated as a Priority Foundation Item even though the temperature is specific to plumbing equipment and is not included in the handwashing procedures in section 2-301.12.
Hand-washing is an important food safety practice and specific procedures for hand washing are included in the Food Code in Section 2-301.12. The mechanical action of washing one's hands, use of soap, length of time hands are washed, rinsing, hand drying and proper hand-wash training have all been noted as important factors in accomplishing proper hand washing. More specifically, paragraph 2-301.12 (B) recommends that "warm water" be used for hand washing and rinsing, without a specific water temperature. Therefore the water temperature alone will not contribute directly to the elimination, prevention or reduction to an acceptable level, hazard associated with foodborne illness as specified in priority item definition.
Sighting a specific threshold water temperature does not predicate successful hand-washing, which can be accomplished at various water temperatures. This is supported by the work of Michaels et al (2002, see attached) which concluded that there was no statistical difference in log reductions for both resident and transient bacteria during handwashing based on water temperature (see attachment). The results reported by Michaels confirm the observations made by Price (Price 1938) and Larson (Larson et al. 1980) indicating water temperature has little or no effect on the removal of bacteria from hands.
In summary, specific procedures such as handwashing frequency, length and technique have been shown to have a direct impact on the risk factors that contribute to foodborne illness, and therefore are aligned with the definition of a priority foundation item.
However, the temperature of water delivered at a handwashing sink does not directly contribute to the elimination, prevention or reduction (to acceptable levels) of the hazards associated with foodborne illness. The temperature of the water is more consistent with the definition of a Core Item, which relates to general sanitation, operational controls, sanitation standard operating procedures (SSOP), facilities or structures, equipment design, or general maintenance. The plumbing recommendations listed in section 5-202.12 are consistent with the definition of a core item.
Recommended Solution: The Conference recommends...
that a letter be sent to the FDA requesting the 2009 Food Code (as modified by the Supplement issued in 2011) be amended as follows (new language shown with underline and deleted language shown with strike-through):
Section 5-202.12 Handwashing Sink, Installation.
(A) A HANDWASHING SINK shall be equipped to provide water at a temperature of at least 38oC (100oF) through a mixing valve or combination faucet.
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