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Food Service Safety Facts May 2003 |
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The Food and Drug Administration (FDA) and the Centers for Disease Control and Prevention (CDC) are working together to control the transmission of pathogens that can result in foodborne illnesses. Transmission of pathogenic bacteria, viruses and parasites from raw food or from ill workers to food by way of improperly washed hands continues to be one of several major factors in the spread of foodborne illnesses.
FDA's Food Code contains the Federal recommendations for preventing foodborne illness in restaurants, grocery stores, institutions and vending locations. Local, state and federal regulators use the FDA Food Code as a model to help develop or update their own food safety rules and to be consistent with national food regulatory policy. The Food Code contains specific hand hygiene guidance for retail and food service workers describing when, where, and how to wash and sanitize hands. Hand sanitizers, meeting specific criteria described in section 2-301.16 of the Food Code, may be used after proper hand washing in retail and food service.
CDC recently issued "CDC Guideline for Hand Hygiene in Healthcare Settings" (Morbidity and Mortality Weekly Reports, October 25, 2002). The guidance document recommends alcohol-based hand gel as a suitable alternative to handwashing for health-care personnel in health-care settings. These guidelines were not intended to apply to food establishments. This exclusion is based on the differences in controlling common nosocomial pathogens in health-care settings and common foodborne pathogens in retail and food service settings. Some significant differences between health-care settings and retail/ food service settings include:
TYPES OF PATHOGENS
The pathogens most commonly transmitted by hands in health-care settings differ from those
in retail and food service settings. In health-care, nosocomial bacterial pathogens and
lipophilic viruses predominate, while in food service and retail establishments we are
primarily concerned with a different set of fecal pathogens. Common nosocomial pathogens are
typically transmitted from person-to-person in health-care settings. In retail and food
service settings, foodborne pathogens are transmitted through the fecal-oral route from
contaminated hands to food items. Controlling the transmission of fecal bacteria, enteric
non-lipophilic viruses, and protozoan oocysts, which can contaminate hands with a very high
titer, is a particular concern. CDC estimates the non-lipophilic virus, Norovirus
(Norwalk-like virus) to be the leading cause of foodborne illness in the United
States.
EFFICACY AND APPROVAL OF ALCOHOL-BASED HAND GELS
All alcohol-based hand gels applied to human skin are drugs, and must be covered by FDA's
Over-the-Counter (OTC) Drug Review or by an FDA-approved new drug application to be legally
marketed in the United States. Further, all ingredients, including emollients and perfumes
that are constituents of alcohol hand gels used in retail and food service operations must be
approved as indirect food additives.
Some in vitro and in vivo published studies suggest that alcohol-based hand gels are highly effective against nosocomial bacterial pathogens of major concern in health-care settings. However the antimicrobial efficacy of alcohol-containing handwashes for use in any setting remains under review by FDA. Some published studies also indicate that moisture on the hands may interfere with alcohol efficacy. In addition, alcohol has been shown to be ineffective against protozoan oocysts and, depending on the alcohol concentration, time, and viral variant, alcohol may not be effective against hepatitis A, or other non-lipophilic viruses.
SOIL ON HANDS
The types and levels of soil on the hands of health-care workers differ from food
service/retail workers. The type of activities conducted in retail and food service may lead
to increased potential for fatty and proteinaceous materials to be on the hands. The fatty
and proteinaceous materials may or may not be visible on the hands. Proteinaceous material is
known to interfere with and neutralize alcohol efficacy. Fatty substances can coat and protect
pathogens from the action of alcohol. Soap, friction, and running water effectively remove
the proteinaceous and fatty materials, and reduce pathogens of concern.
Existing data do not demonstrate that alcohol-based hand gel effectively reduces important infectious foodborne pathogens at levels that occur on food workers' hands, especially if the hands are soiled with fatty and proteinaceous materials. Even in health-care settings, the CDC guidelines recommend soap and water handwashing on hands that are visibly soiled, or contaminated with proteinaceous material, rather than using the alcohol-based sanitizers.
Proper handwashing, as described in the Food Code continues to serve as a vital and necessary public health practice in retail and food service. Using alcohol gel in place of handwashing in retail and food service does not adequately reduce important foodborne pathogens on foodworkers' hands. Concern about the practice of using alcohol-based hand gels in place of hand washing with soap and water in a retail or food service setting can be summarized into the following points:
Alcohols have very poor activity against bacterial spores, protozoan oocysts, and certain nonenveloped (nonlipophilic) viruses; and
Ingredients used in alcohol-based hand gels for retail or food service must be approved food additives, and approved under the FDA monograph or as a New Drug Application (NDA); and
Retail food and food service work involves high potential for wet hands and hands contaminated with proteinaceous material. Scientific research questions the efficacy of alcohol on moist hands and hands contaminated with proteinaceous material.
FDA and CDC continue to work together to review new data and assure the best public health measures are in place for retail and food service establishments
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