Issue View | Council I | 2023 Biennial Meeting

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Reducing Cross Contamination Risk from Use of Reusable Wiping Cloths

The use of reusable cloth wiping towels for quick cleanup of food spills on non-food contact surfaces is a common practice in food establishments. However, it remains one of the most frequently encountered Food Code violations due to failure of one the many steps required to ensure this practice doesn't become a risk to guests and patrons of food establishments. Such steps include:

• Ensuring wiping cloths are held in a sanitizer solution at the appropriate concentration required for efficacy to prevent growth of microorganisms on the cloth itself.
• Ensuring wiping cloths are held in a sanitizer solution free from soil, as soils can negatively impact the concentration of the active ingredient in the sanitizer solution.
• Ensuring individual wiping cloths are not used for practices which could promote cross contamination (e.g., use of the same cloth for wiping raw and ready-to-eat food spills)

As noted below, failure of one or more of these steps may lead to microbial contamination of the sanitizer solution, the wiping cloth, or both, which may lead to cross contamination within a food establishment. We are asking The Conference to consider supporting an amendment to The FDA Food Code which would include code language restricting use of these reusable wiping cloths to non-food-contact surfaces only, mimicking language that already appears within the Annex.

Research has shown reusable wiping cloths to be a potentially risky practice for spread of pathogens within food establishments. A summary of research on the topic appears below.

A study in 2006 reported the findings of a bacterial survey of 37 dishcloths and 10 tabletops from bars and restaurants in New York, California, and Arizona (1). The authors detected coliforms in 89.2% of cloths (mean bacterial count: 7.6 × 10⁵ CFU/cloth) and Escherichia coli in 54.1% of cloths (mean bacterial count: 1.9 × 10³ CFU/cloth). The authors also noted that cleaning tables with in-use dishcloths resulted in a significant increase in both bacterial and coliform counts, as compared to be fore cleaning. Finally, the authors found a variety of bacteria, including Listeria innocua in 24.3% (n =9) of all dishcloth samples. While Listeria innocua is not itself a foodborne pathogen, its presence is sometimes used as an indicator organism for Listeria monocytogenes.

A 2020 study evaluated the potential for various food allergens (peanut, milk, and egg) to spread to multiple consecutive surfaces using a variety of methods, including the use of reusable terry cloths (2). It was found that allergen transfer was minimized when terry cloths were stored in appropriate solutions of sanitizer in between use, suggesting the potential for an increased chance of allergen cross contamination if sanitizer levels become inadequate.

Several studies have also demonstrated the potential for reusable wiping cloths to spread bacteria and viruses between surfaces. A 2020 study using large tabletops and reusable terry cloths held in sanitizer solutions found that both bacteria (E. coli, Listeria innocua) and virus (MS2 bacteriophage) were readily transferred to multiple consecutive surfaces in the absence of sanitizing solution, illustrating the importance of an appropriate concentration of sanitizer for minimizing cross contamination. Similar to these results, a 2012 study demonstrated the potential for damp terry cloths to readily transfer MS2 bacteriophage and Feline Calicivirus to clean surfaces (4).

Given that reusable wiping cloths can become a risk for bacterial and viral cross contamination within a food establishment, especially when sanitizer concentrations fall to levels inadequate for surface sanitization, the addition of language in the FDA Food Code emphasizing that these reusable wiping cloths are not considered an appropriate cleaning step for food contact surfaces may potentially help reduce the risk of foodborne illness outbreaks associated with cross contamination. This also would align code language more closely to that of the Annex, which states that the use of a reusable wet wiping cloth "does not constitute cleaning and sanitizing of food contact surfaces where and when such is required to satisfy the methods and frequency requirements in Parts 4-6 and 4-7 of the Food Code".

References:

1. Yepiz-Gomez, M. & Bright, Kelly. (2006). Identity and Numbers of Bacteria Present on Tabletops and in Dishcloths Used to Wipe Down Tabletops in Public Restaurants and Bars. Food Protection Trends. 26. 786-792.
2. Bedford, B., Liggans, G., Williams, L., & Jackson, L. (2020). Allergen Removal and Transfer with Wiping and Cleaning Methods Used in Retail and Food Service Establishments. Journal of Food Protection, 83(7), 1248-1260.
3. Goulter, R. M., Clayton, J. S., Moore, R. G., Bradshaw, J. M., Frye, J. W., Puntch, E. J., & Jaykus, L. A. (2020). Characterizing Microbial Cross-Contamination on Large Surfaces Using a Traditional "Cloth and Bucket" Disinfection Method. Food Protection Trends, 40(6), 392-401.
4. Gibson, K. E., Crandall, P. G., & Ricke, S. C. (2012). Removal and transfer of viruses on food contact surfaces by cleaning cloths. Applied and environmental microbiology, 78(9), 3037-3044.

Recommended Solution:

A letter be sent to FDA requesting to amend FDA Food Code 3-304.14 (Wiping Cloths, Use Limitation) as follows:

3-304.14 Wiping Cloths, Use Limitation.

(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 meeting the criteria specified under § 4-501.114; and

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

(C) Use of dry and wet wiping cloths do not constitute an appropriate method for cleaning and SANITIZATION of FOOD CONTACT SURFACES where and when such is required to satisfy the methods and frequency requirements in Parts 4-6 and 4-7 of the Food Code

(D) Cloths in-use for wiping surfaces in contact with raw animal FOODS shall be kept separate from cloths used for other purposes.

(E) Dry wiping cloths and the chemical sanitizing solutions specified in Subparagraph (B)(1) of this section in which wet wiping cloths are held between uses shall be free of FOOD debris and visible soil.

(F) Containers of chemical sanitizing solutions specified in Subparagraph (B)(1) of this section in which wet wiping cloths are held between uses shall be stored off the floor and used in a manner that prevents contamination of FOOD, EQUIPMENT, UTENSILS, LINENS, SINGLE-SERVICE, or SINGLE-USE ARTICLES.

(G) SINGLE-USE disposable sanitizer wipes shall be used in accordance with EPA approved manufacturer's label use instructions.