While there are many differing opinions on how to address food safety and the risks of bare-hand contact, the National Restaurant Association has always promoted a balanced approach to this issue. Simple, “silver bullet” remedies such as mandatory glove use or the banning of bare-hand contact altogether may seem attractive to some, but they generally prove to be ineffective and impractical in day-to-day applications.
In the real world, improved hand washing compliance, restriction of ill employees and effective hand-washing management are the only solutions that can be realistically expected to address bare-hand contact issues and meet the industry’s needs.
The importance of effective education and training programs highlighting hand washing, the restriction of ill employees and clean-hand management cannot be overstated. Many educational materials already exist in programs such as the National Restaurant Association Educational Foundation ServSafe® food safety education program.
The absolute prohibition of bare-hand contact and mandatory glove rule first surfaced in the 1993 FDA Food Code. The issue has been addressed in numerous regulatory meetings and state and local government hearings since that time. As a result of the increased attention, many in the restaurant industry, as well as state and local regulatory officials, have implemented effective hand-washing interventions and regulatory strategies.
In 1999, the FDA Food Code recognized effective hand-washing management in Annex 3 of the Food Code. However, the code language in the main body of the document, which absolutely prohibits bare hand contact, was not changed to reflect this current public health reasoning regarding hand washing compliance and management.
Since 1993, and particularly after the 1997 version of the FDA Food Code, states began adopting the FDA Food Code and its provisions. Many incorporated realistic changes to the bare-hand contact prohibition section 3-301.11. The three most notable examples are Texas, California and Florida, which have been able to effectively work with industry to improve hand-washing compliance, protect public health and allow limited bare-hand contact at retail.
It’s clear from their actions that these states have determined that there is no conclusive evidence that the mandatory use of gloves or utensils affords any greater level of protection in a restaurant setting than clean, washed hands. Furthermore, their solutions recognize that there are many circumstances in foodservice settings in which it is logistically impossible to avoid all bare-hand contact with ready-to-eat foods. Common tasks such as peeling shrimp, filling tacos, peeling fruit and steadying hot foods all potentially require direct hand contact.
Clearly, the current FDA regulatory scheme to absolutely ban bare-hand contact is impossible to comply with and not supported by scientific data (Fendler at al, Part I, 1998). It’s clear our belief that food contact with unwashed, contaminated hands or gloves can be a source of foodborne illness (Torok et al., 1997), and that responsible and effective action should be taken to effectively address this problem.
However, rather than the unrealistic prohibition of all bare-hand contact, we believe the solution lies in a balanced approach which promotes improved hand-washing compliance, restriction of ill employees and effective hand- washing management (Sattar and Springthorpe, Cambridge Univ Press, 1996).
Furthermore, not all bare-hand-to-food contacts involve the same level of risk as those that involve greater intimacy, regularity or volume of exposure. The key to improved food safety is proper hand- washing focus and the elimination of dirty, bare-hand contact where appropriate. Simple, silver bullet solutions like mandatory glove use or banning bare-hand contact may be attractive to many, but the practical application must be fully considered before an effective solution can be realistically developed and implemented (Fendler at al, Part II, 1998; Docket RPT-1).
Additionally, there is no evidence that glove use has reduced the transmission of foodborne illness or lowered the number of foodborne illnesses in the few states that have implemented mandatory glove laws over those that have not (CDC, FoodNet 1998). From 1995 through 1998, epidemiological data developed through CDC’s FoodNet data has also shown significant reductions in foodborne illness pathogens per 100,000 individuals nationwide. Clearly, the reductions in illnesses since 1995 are a reflection of the effective implementation of strategies incorporated at various steps by the food industry.
In previous reports (CDC summary, 1988 to 1992) CDC has cited “poor personal hygiene” as a cause of illness less than 25 percent of the time when the cause was identified. Improper holding temperatures were cited as the number one cause in all years 35 percent of the time. Since the CDC term “personal hygiene” may encompass many practices, of which hand-contact is only one, the real percentage due to dirty-hand contact is likely to be significantly smaller. In any case, the absolute number of illnesses associated with dirty-hand contact is probably declining and clearly does not represent a growing or out of control problem.
We continue to believe that the ultimate solution to reducing poor personal hygiene and dirty-hand contact associated illnesses is an effective education and training program highlighting hand-washing and hand-washing management. The NRA Education Foundation and others are delivering this training today through programs such as ServSafe®. We challenge others to join with us in the expansion and delivery of food safety education and to greatly increase the 1,000,000 restaurant managers we have already trained and certified. Through consistent training, we can improve handwashing compliance, restrict ill employees effectively and manage handwashing better.
The NRA is not opposed to appropriate glove use and the reduction of bare-hand contact. We have consistently supported a balanced approach that calls for effective handwashing and the use of gloves for high-risk situations. This philosophy recognizes that there are no quick fixes in this debate and that no one strategy is totally appropriate for all restaurant situations (Fendler at el, Part I, 1998).
The FDA and others have noted some of the failings of the current levels of hand washing compliance and management on many occasions and we find ourselves in agreement. It is evident that more work needs to be done to improve handwashing compliance and management; however, the issue must be addressed directly. We should not expect any real improvement in handwashing compliance if we continue to cover the real problem with gloves (Bardell, 1995) or attempt to simply eliminate bare-hand contact with an ill-conceived policy.
Research has clearly shown that glove use does not establish an absolute barrier to contamination and may even contribute to the problem (Larson et al., 1989, Ehrenkranz, 1992, DeGroot-Kosolcharoen, et al, 1989, and Fendler et al., Part I, 1998). Sole reliance may only complicate the existing compliance issues.
Steven F. Grover is with the Health and Safety Regulatory Affairs of the National Restaurant Association.
1998 FoodNet Surveillance Results. Preliminary Report. Atlanta: Centers for Disease Control and Prevention; 1999.
Bardell D. Herpes simplex virus type 1 applied experimentally to gloves used for food preparation. J Food Protect 1995; 58: 1150-1152.
California, CURFFL, 1999.
Centers for Disease Control and Prevention Surveillance for Foodborne-Disease Outbreaks- United States, 1988-1992.
Fendler EJ, Dolan MJ, Williams RA, Paulson DS. Handwashing and gloving for food protection part II: Effectiveness. Dairy, Food Environ Sanit 1998; 18(12);824-829.
Fendler EJ, Dolan MJ, Williams RA. Handwashing and gloving for food protection part I: Examination of the evidence. Dairy, Food Environ Sanit 1998; 18(12); 814-823.
Industry Guidelines for 61C-4.010 (1) (d-g) FAC. Alternative to 1997 FDA Food Code 3-301.11 Preventing Contamination from Hands. Florida Department of Business and Professional Regulation, Division of Hotels and Restaurants.
Satter SA, Springthorpe VS. Transmission of vital infections through animate and inanimate surfaces and infection control through chemical disinfection. In: Hurst CJ, ed. Modeling disease transmission and its prevention by disinfection. Cambridge University Press; 1996. P.224-257.