Conference for Food Protection

2023 Biennial Meeting

Issue View | Council I | 2023 Biennial Meeting

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Issue Number: Council I 017

Issue History

This is a brand new Issue.


Amend Food Code 3-301.11 - Double Handwashing and Nail Brush Usage

Issue you would like the Conference to consider

Amend 3-301.11(E)(6) to specify that double handwashing means washing hands twice whenever a hand wash is required and that nail brushes must be used every time hands are washed.

Public Health Significance

Bare hand contact with ready-to-eat foods is disallowed by the Food Code because of the potential for transmission of fecal-oral route pathogens by asymptomatic food employees. The Food Code allows food establishments to engage in bare hand contact under certain circumstances as long as two or more "control measures" are in place; two of the control measures specifically listed in the Food Code are "double handwashing" and "nail brushes." The Food Code does not provide any specific information about those control measures. Operators have interpreted this section of the Food Code to imply that double handwashing means washing hands inside the restroom and then again when returning to the kitchen (see attachments) and that nail brushes can be used occasionally instead of every time hands are washed.

In regards to the double hand washing issue, we have found several online sources, both from industry and regulatory, that defines "double handwashing" as washing hands in the restroom and then again in the kitchen. Further clarification would address the conflict between this interpretation and the guidance from the FDA.

Recommended Solution: The Conference recommends...

That a letter be sent to the FDA requesting the most current edition of the Food Code be amended as follows:

3-301.11 Preventing Contamination from Hands

(E) FOOD EMPLOYEES not serving a HIGHLY SUSCEPTIBLE POPULATION may contact exposed, READY-TO-EAT FOOD with their bare hand if:

(6) Documentation that FOOD EMPLOYEES contacting READY-TO-EAT FOOD with bare hands use two or more of the following control measures to provide additional safeguards to HAZARDS associated with bare hand contact:

(a) Double handwashing,

(i) For the purposes of this section, double handwashing means washing hands twice whenever required to do so as specified under § 2-301.14.

(b) Nail brushes used every time hands are washed,

(c) A hand antiseptic after handwashing as specified under § 2-301.16,

(d) Incentive programs such as paid sick leave that assist or encourage FOOD EMPLOYEES not to work when they are ill, or

(e) Other control measures approved by the REGULATORY AUTHORITY; and

Supporting Attachments

Submitter Information

Name Matthew Brandt
Organization Colorado Department of Public Health and Environment
Address 4300 Cherry Creek Dr South
Denver, CO 80246
Telephone 7205500322

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