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Food Safety: Defensive handwashing

December 1, 2009
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Recent food safety problems have had some positive effects. They have inspired auditors to be more diligent-and it’s pushed firms to raise standards. In fact, one audit firm will be downgrading food plants that don’t have hands-free toilet facilities. 

Whenever toilets are mentioned, it leads directly to the subject of hand washing. Almost all food plants have good manufacturing practices (GMPs) or personal hygiene requirements pertaining to hand washing.

The current GMPs for hand washing in 21 CFR 110.37 (e) under “Handwashing Facilities” reads:

“Hand-washing facilities shall be adequate and convenient and be furnished with running water at a suitable temperature. Compliance with this requirement may be accomplished by providing:

• Hand-washing and, where appropriate, hand-sanitizing facilities at each location in the plant where good sanitary practices require employees to wash and/or sanitize their hands.

• Effective hand-cleaning and sanitizing preparations.

• Sanitary towel service or suitable drying devices.

• Devices or fixtures, such as water control valves, so designed and constructed to protect against recontamination of clean, sanitized hands.

• Readily understandable signs directing employees handling unprotected food, unprotected food-packaging materials, or food-contact surfaces to wash and, where appropriate, sanitize their hands before they start work, after each absence from post of duty, and when their hands may have become soiled or contaminated. These signs may be posted in the processing room(s) and in all other areas where employees may handle such food, materials, or surfaces.

• Refuse receptacles that are constructed and maintained in a manner that protects against contamination of food.”

Basically, this means hand-washing sinks should be supplied with warm water dispensed via hands-free (foot-, knee- or electric eye-activated) sinks. Each sink should be supplied with soap, hand sanitizer (if needed), a means to dry hands and signage reminding employees to wash their hands. These signs should be in the languages spoken by plant personnel. Finally, there should be a self-closing trash bin if disposable towels, instead of an air dryer system, are used. Processors must provide adequate hand-wash stations to ensure all employees will be able to wash at peak times, such as the beginning of shifts or returns from breaks or meals.

A survey of sanitation professionals during preparation of this article indicated there should be one sink for every 10-20 employees working in processing operations. It’s also vital to locate hand-wash sinks at various convenient locations on the production floor, especially in operations that manufacture products prone to contamination or spoilage. Food plant workers must wash their hands, but the importance of washing varies with the type of operation. The emphasis on hand washing should be much greater in plants manufacturing foods such as ready-to-eat (RTE) products, meats and poultry than for those producing soft drinks, aseptic products or canned foods, since the potential for contamination in closed systems is negligible. Therefore, when developing hand-washing programs, it never hurts to conduct a risk assessment. The assessment should address type of products, soaps, the need for sanitizers and the process systems being used.

Each processor should install the hand-washing facilities noted above. Next, all plant personnel, including managers, must be trained on how to wash their hands, and training must be documented. The use of tools such as Glo-Germ can make this exercise both germane and fun for participants.

When validating cleaning procedures, processors can swab surfaces or test rinse water (CIP cleaning) following cleaning regimens to verify cleanliness. While following validated procedures ensures cleanliness, surface swabbing using ATP, allergen swabs or microbiological testing on a regular basis verifies the results. Some plants randomly swab workers’ hands, but these programs don’t address every employee.

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Recent Articles by Richard Stier, Contributing Editor

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