“Proper hand hygiene is the food processing plant’s first line of defense against food contamination,” said Gojo Food Processing Sales Manager Jim Grubb. In fact, Grubb said, citing former European Food Safety Authority Chairman Patrick Wall, two of the leading causes of foodborne illness are inadequate hygiene facilities for staff and poorly trained and supervised staff.
The regulations for handwashing at food and beverage processing facilities are set by the Code of Federal Regulations (See CFR Standards, sidebar below), but standards and guidelines are also set by various agencies and third-party organizations, such as CDC, FDA, NSF, auditing agencies, and the Global Food Safety Initiative.
Although there is some vagueness around “who is supposed to do what by what regulatory agency,” the FDA and CDC do work together, with FDA using handwashing guidelines set by CDC as the foundation, said Best Sanitizers Regional Sales Manager Harry Reeder. Additionally, for food and beverage facilities, the guidance centers around the implementation of HACCP, Reeder said. When a processor sets out to determine its CCPs, it should consider handwashing as a critical point, then implement practices to reduce related risk.
Handwashing. The CDC guidelines set some general best practices of handwashing standards that can be used to set the foundation for any food-handling facility program. (See CDC Handwashing Recommendations, www.qualityassurancemag.com, Online Extras.) “Best practices start with the very fundamental guidelines laid down by CDC—washing your hands with soap and water, “ Reeder said. From that basis, each facility should then consider its individual processes, practices, and products to develop and train workers on a hand-hygiene program.
Having a fully developed, implemented, and documented program becomes even more important with the 2011 passage of the Food Safety Modernization Act. “Plants are required to verify and validate that they have an effective process in place for protecting the food supply,” Reeder said. And handwashing is certainly a key element in such protection.
Although guidelines for hand-hygiene protocols vary among organizations, Grubb said, “Standard accepted practices tend to include, at a minimum, handwashing before entering the work environment, before and after meal and work breaks, after every restroom visit, and after leaving work.” In addition, workers should wash their hands anytime they believe hand contamination has occurred.
“Glove Juice.” Even when gloves are required, it is important that workers wash hands before and after donning the gloves, with the practice of handwashing in addition to glove use also mandated by some local health codes.
According to Section 110.10 of the Code of Federal Regulations Title 21, plant management shall take all reasonable measures and precautions to ensure … Cleanliness. All persons working in direct contact with food, food-contact surfaces, and food-packaging materials shall conform to hygienic practices while on duty to the extent necessary to protect against contamination of food.
The methods for maintaining cleanliness include, but are not limited to … Washing hands thoroughly (and sanitizing if necessary to protect against contamination with undesirable microorganisms) in an adequate hand-washing facility before starting work, after each absence from the work station, and at any other time when the hands may have become soiled or contaminated.
In addition, Section 110.20 requires that adequate lighting be provided in hand-washing areas, and Section 110.37 requires that hand-washing facilities be adequate, convenient, and furnished with running water at a suitable temperature. Compliance may be accomplished by providing:
Protective gloves provide a “nice, warm environment for bacteria to grow” enabling the development of “glove juice,” Reeder said, explaining the term as relating to the sweat and moisture that develops on hands encased in gloves. If a worker tears a glove while working or removes a glove, then touches food or equipment, this bacterial-laden moisture can immediately transfer contaminants. “You’re delivering an ultra-concentrated colony of germs,” he said.
Handwashing after glove use also provides an extra level of protection and assurance, Grubb said, explaining, “Gloves can become compromised or punctured with even the slightest nick, especially when worn over a period of time. This could allow contaminants to reach the skin and get spread to food.”
Hand Sanitizers. Although regulations state that hand sanitizers are not to be used in place of handwashing, risk of contamination can be further reduced by the use of sanitizers after handwashing. “If you just spray hand sanitizer on dirty hands, it won’t have much effect,” Reeder said. The act of rubbing the hands together with soap and water is essential to the removal of surface dirt, after which a sanitizer can act to reach the underlying bacteria as well as any areas that were not throoughly scrubbed. The highest percentage of germs on hands tends to be underneath the nails and cuticle, with the second highest proportion being between the fingers. Using sanitizer after handwashing can help ensure these areas are reached.
In fact, sanitizing without washing can actually increase risk. According to an FDA white paper, “Alcohol gel sanitizers that do not require rinsing may be ineffective on their own due to the fact that there is no mechanical action to wash away bacteria … As they dry, alcohol products may pull resident bacteria from deeper skin layers, thus an increase in resident bacterial counts may be noticed.”
For such reasons as well, Reeder said, the sanitizer should be used immediately after washing. Otherwise, a layer of soil could already be built up from anything the hands contacted between the two actions, such as a door, pen, face, etc.
Handwashing involves soap and water, while sanitizing is done with a hand sanitizer—also known as a hand rub—and without water, Grubb explained, adding, “When hand sanitizing, use enough of the product to completely wet the hands, and then rub hands for 15 seconds, thoroughly rubbing the formulation into the skin. Then air dry.”
Microbial Agents & Efficacy. “At the most basic level, hand soaps must be effective at removing such food processing industry soils as animal fats and oils,” Grubb said. Then facilities should consider the twin issues of efficacy and irritancy. Because hands must be washed and sanitized frequently to prevent food contamination, these constant acts can irritate and dry out the skin, he said.
Extensive studies have been conducted on log reduction of pathogens such as Salmonella and Listeria, and the extent to which different microbial agents can reduce these, Reeder said. “Generally the goal in food processing is to get to log 4 and log 5, whether it is surface sanitizing or hand sanitizing,” he said. Because logs relate to bacterial colonies with each log a multiple of 10 to that power (e.g., a 4-log reduction means the number of germs is 10,000 times smaller, log 5 is 100,000 times less, etc.), each log by which germs can be reduced provides a significant impact on reducing the potential of contamination.
However, effectiveness of any agent is also dependent on proper personnel practices. “Many microbials have to be on the hands for 20 seconds before they start working,” Reeder said. So if a person is not washing for at least 20 to 30 seconds (about the amount of time in which one can sing the ABCs), the soap cannot be as effective. And, Reeder said, “90 percent of people don’t wash their hands for 20 to 30 seconds.”
This is not only an issue with potential contamination but also with antibacterial resistance issues. When products are not used properly, Reeder explained, “the germ gets wounded. Then it shakes it off and heals. Now it’s stronger than before.” Then, with generations and generations of germs comes more and more resistance.
Sanitizers generally come in three types: gels, foam, and alcohol rinse. According to a CDC-posted article (Reynolds S.A., Levy F., Walker E.S., Hand sanitizer alert [letter]), alcohol-based hand sanitizers are recommended in healthcare settings. Similarly, FDA recommends a concentration of 60% to 95% ethanol or isopropanol, the concentration range of greatest germicidal efficacy. Such specifications are important because, as the article continues, “Some products marketed to the public as antimicrobial hand sanitizers are not effective in reducing bacterial counts on hands.” In fact, a study conducted in a classroom setting found that a retail-purchased sanitizer with a label claim of reducing “germs and harmful bacteria” by 99.9%, actually showed an apparent increase in the concentration of bacteria in handprints impressed on agar plates after cleansing.
Similarly, FDA recently issued a consumer update that some sanitizers are being labeled with unsubstantiated claims. The update focused primarily on MRSA (methicillin-resistant Staphylococcus aureus) but included the recommendation: “Don’t buy over-the-counter hand sanitizers or other products that claim to prevent infection from MRSA, E. coli, Salmonella, flu, or other bacteria or viruses.” In addition, the update stated, “FDA is cracking down on companies that break federal law by promoting their products as preventing MRSA infections and other diseases without agency review and approval.”
Soaps and sanitizers that are used in food processing plants are guided by FDA registration and regulation and/or NSF guidance (which replaces the previous authorization program administered by the USDA). These are primarily E2 handwashing and sanitizing compounds and E3 hand-sanitizing compounds that have been accepted on the basis of their equivalency to 50 parts per million chlorine.
How well a person washes—or sanitizes—his or her hands can be extremely subjective, Reeder said. But because hand hygiene truly is a first line of defense against contamination, it is important that all companies involved with food see this as a critical control point and have a hand-hygiene program on which employees are regularly trained, educated, and monitored.
The author is Editor of QA magazine. She can be reached at email@example.com.