Issue View | Council I | 2023 Biennial Meeting

This is a brand new Issue.

Amend Food Code to include procedures for clean-up of vomit and diarrhea

The clean-up of vomiting and diarrheal events, as stated in the 2022 FDA Food Code, does not specify what exactly is required for a proper response. Due to vague language in the 2022 FDA Food Code, regulatory agencies have deferred to the 2022 FDA Food Code 2-501.11 Annex 3 Public Health Reasons, which lists what a food establishment should "consider" (11 bullet points) when developing a written plan, in order to minimize the spread, exposure, and contamination. The word "consider" leads to confusion, a lack of understanding, and inconsistencies of what is actually required (at a bare minimum) among industry and regulatory agencies.

"According to the CDC, Norovirus is the leading cause of foodborne disease outbreaks in the United States." (2022 FDA Food Code 2-501.11 Annex 3- Public Health Reasons/Administrative Guidelines)

"When an employee, customer, or other individual vomits or has a diarrheal event in a food establishment, there is a real potential for the spread of harmful pathogens in the establishment. Putting the proper response into action in a timely manner can help reduce the likelihood that food may become contaminated and that others may become ill as a result of the accident." (2022 FDA Food Code 2-501.11 Annex 3-Public Health Reasons/Administrative Guidelines)

A timely response cannot occur without having the following in a written plan and onsite:

• EPA registered disinfection products sufficient to inactivate norovirus
• Personal Protective Equipment (PPE)
• Cleaning and disinfecting equipment
• Procedures for cleaning, sanitizing, and disinfecting
• Procedures for containment and removal

"Effective clean-up of vomitus and fecal matter in a food establishment should be handled differently from routine cleaning procedures. It should involve a more stringent cleaning and disinfecting process. Some compounds that are routinely used for sanitizing food-contact surfaces and disinfecting countertops and floors, such as certain quaternary ammonium compounds, may not be effective against Norovirus. It is therefore important that food establishments have procedures for the cleaning and disinfection of vomitus and/or diarrheal contamination events that address, among other items, the use of proper disinfectants at the proper concentration." (2022 FDA Food Code 2-501.11 Annex 3- Public Health Reasons)

"Additionally, exposed food employees are also at risk of contracting Norovirus illness and can subsequently transfer the virus to ready-to-eat food items served to consumers." (2022 FDA Food Code 2-501.11 Annex 3-Public Health Reasons)

"Once such an episode has occurred, timely effective clean-up is imperative. Key to achieving an appropriate, timely response by food employees is the availability and access to a written plan upon which to refer to for reference." (2022 FDA Food Code 2-501.11 Annex 3- Public Health Reasons)

The recommended language was developed to provide guidance to assist the operator and regulators when a vomiting and/or diarrheal event occurs. Adding clarifying language and specific requirements to the FDA Food Code will:

• Create consistency in requirements among industry and regulatory agencies.
• Better support regulatory agencies in the enforcement of requirements.
• Allow for a proper response in a timely manner due to having specific supplies onsite.
• Minimize the spread, exposure, and contamination due to adding the following supplies to the requirements: EPA registered disinfection products sufficient to inactivate norovirus, PPE, and cleaning and disinfecting equipment.

that a letter be sent to the FDA requesting Section 2-501.11 of the most current edition of the Food Code be amended as follows:

2-501.11 Clean-up of Vomiting and Diarrheal Events.

A FOOD ESTABLISHMENT shall have procedures for EMPLOYEES to follow when responding to vomiting or diarrheal events that involve the discharge of vomitus or fecal matter onto surfaces in the FOOD ESTABLISHMENT. The procedures shall address the specific actions EMPLOYEES must take to minimize the spread of contamination and the exposure of EMPLOYEES, consumers, FOOD, and surfaces to vomitus or fecal matter^Pf and shall include the following: ^Pf

(A) Availability of effective disinfectants, such as EPA registered disinfection products sufficient to inactivate norovirus, personal protective EQUIPMENT, and other cleaning and disinfecting EQUIPMENT and appurtenances intended for response and their proper use. ^Pf

(B) Procedures for cleaning, sanitizing, and disinfection of surfaces and cleaning and disinfecting EQUIPMENT that may have become contaminated. ^Pf

(C) Procedures for containment and removal of any discharges, cleaning and disinfecting EQUIPMENT, and food that may have been exposed. ^Pf