Conference for Food Protection

2023 Biennial Meeting

Issue View | Council I | 2023 Biennial Meeting

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Issue Number: Council I 003

Issue History

This is a brand new Issue.

Title

Gloves Used as a Single-Use Disposable Utensil

Issue you would like the Conference to consider

Disposable gloves are defined as a utensil in the 2022 FDA Food Code (3-304.11). Currently, there is no specific provision within the FDA Food Code that covers hand washing and using a disposable glove as a single-use utensil, similar to a tong or spatula. When a glove is used as a single-use disposable utensil, and no contamination of the hand has occurred, there should be no need to wash hands after glove removal or between changes.

Public Health Significance

Hand washing is a critical activity to ensure against cross-contamination. The FDA Food Code indicates there are specific times when hands must be washed (2-301.14). The various rules within the FDA Food Code are focused on potential contamination events while there is an opportunity to include interpretation for when contamination does not occur, such as when using a disposable glove in a single-use situation, similar to a tong or spatula. Rather than adding an additional hand wash step that would not occur if any other utensil was used, the glove(s) should be allowed to be removed and/or changed without a hand wash procedure in instances where contamination of the hand has not occurred.

Recommended Solution: The Conference recommends...

That a letter be sent to FDA requesting that the most current edition of the Food Code Annex 7, Guide 3-B, 8. Hands clean and properly washed, be amended as follows:

IN/OUT

This item should be marked IN or OUT of compliance. This item is marked IN compliance only when employees are observed using proper handwashing techniques at appropriate times and places. Hands are not required to be washed between each change of gloves, if it is observed that there was no change in the task being performed and no activities which could potentially result in cross contamination. Also, hands are not required to be washed after or between glove changes if gloves are used as a single-use disposable utensil and no activities resulting in hand contamination were observed.

Submitter Information 1

Name Patrick Guzzle
Organization National Restaurant Association
Address 6751 Forum Drive, STE 220
Orlando, FL 32821
Telephone 208-515-8688
Email pguzzle@restaurant.org

Submitter Information 2

Name Kate Piche
Organization National Restaurant Association
Address 233 S Wacker Drive Ste 3600
Chicago, IL 60606
Telephone 3124856925
Email kpiche@restaurant.org

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