An observational study conducted by the CDC that 8.6 hand washes by restaurant staff per employee hour were required to comply with the FDA’s Model Food Code.1 Consensus among both operators and regulators is that that is never going to happen. However, the study’s results beg the question: If 8.6 is the ideal safe level, what is the risk when hand washing frequency is, on average, 0.5 times per employee hour? Based on foodborne illness data and the increasing frequency of shuttered restaurants, the risk is higher than desired. We all know that hand washing rates are well below perfection. In most food service operations, they are also well below a safe level.
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This gap between reality and 8.6 hand washes per employee hour creates a dilemma for operator and inspector. If the inspector were to enforce the existing code strictly, virtually all restaurants would be closed. It’s left to the inspector to ask: Which touches shall I disregard? How can I tell the operator which parts of the code to ignore?
The answer to poor hand hygiene performance is not expensive—but neither is it an easy fix. Hand hygiene requires a basic change in the behavior of all involved, from managers to entry-level food workers. An easier step toward safer hands and safer food might be to reduce the touches that demand a hand wash. By improving the cleaning process, we reduce the risk of surface-to-hand contamination by rendering surfaces TouchReady for workers and customers.
The investment required to raise surface cleanliness standards is low and easy to manage. It starts with enhanced process control based on the level of at-risk, high-touch surfaces in the facility.
The Risks of High-Touch Surfaces
High-touch surfaces are bacterial and viral transfer stations. Christine Moe, PhD, the Eugene J. Gangarosa Professor of Safe Water and Sanitation and director of the Center for Global Safe Water at Emory University, found in a study that norovirus, restaurants’ most prolific pathogen, can live on inanimate surfaces from three to six weeks.2 Bacterial pathogens can be equally persistent and even more dangerous.
Gloved and bare hands touch risky surfaces frequently. Some touches are riskier than others, but the food code treats them equally, providing little direction for real-world prioritization. Surfaces need to be prioritized, distinguishing between “must wash” and “nice if” incidents—nice if there is time.
If an operator targets risk by attempting to lower it through improved hygiene, without some level of prioritization, service is likely to suffer and costs to rise disproportionately to the degree of risk reduction.
Not All Touches Are Equal, Are They?
If all touches are considered equal, as in the Model Food Code, then all missed opportunities to wash are equal. While this could on occasion be true scientifically, it doesn’t add up intuitively. It violates a basic premise of adult learning: Training must reflect common sense in order to be respected and implemented.
Common sense for pathogens, unfortunately, includes populating those surfaces that are touched frequently by many. Their goal is survival. High-risk surfaces warrant high scrutiny. Touches must trigger a specific response—a hand wash—as part of a defined process.
Lesser touches can be managed by a backup system that establishes a minimum for hand washes, driven purely by the clock. The danger of this well-intentioned safety net is that it can morph into the default standard, creating a false sense of safety as employees lose sight of the connection between their behaviors and the actual risk.
A restaurant’s inventory of thousands of surfaces can be daunting for a company’s hygiene risk assessment team, the temporary cross-functional team charged with creating and implementing any corrective actions arising from their assessment.