Your employees’ hands are a critical control point worth your attention. If employees are not washing their hands, it’s possible the food you are manufacturing isn’t safe or will suffer compromised shelf life. Neither are the goals of a quality manufacturer.
Many cases of foodborne illness are unreported, and it is estimated that every year nearly 76 million people in the United States become ill from pathogens in food. More than 5,000 cases are fatal.1 With that said, effective food safety programs are the primary goal of the modern food processor and their quality assurance departments.
Opportunities for cross-contamination are everywhere employees are located, and include natural human behaviors such as scratching and adjusting glasses or a hairnet. If employees are not taught proper hand hygiene, foodborne pathogens could be transferred to the food by hand contact.
Under the threat of cross-contamination, quality assurance professionals have to sort through confusing product choices, employee skin care needs, regulatory requirements, training, and language barriers to build an effective and compliant program. Unaddressed, poor employee hand hygiene could lead to quality degradation, retained product, downtime, litigation and brand damage, which can ultimately cost time, money and customers.
Up until 1999, the USDA’s Food Safety and Inspection Service (FSIS) was the regulatory body that approved nonfood compounds and proprietary substances for use in meat and poultry establishments. FSIS is responsible for ensuring that the nation’s supply of meat, poultry and egg products is safe, wholesome, and correctly labeled and packaged.
After FSIS announced its discontinuation of the approval program, NSF International – a not-for-profit, non-governmental organization – launched a voluntary Nonfood Compounds Registration Program to re-introduce the previous authorization program. All products used in and around food processing establishments (nonfood compounds), such as hand cleaners and sanitizers as well as hard surface sanitizers are now eligible for NSF listing. NSF listing assures inspection officials and processors that the product formulation and labels have been reviewed and meet appropriate food safety regulations.
NSF listing is based on the NSF Registration Guidelines for Proprietary Substances and Nonfood Compounds. This program reflects the formulation, label and use instruction requirements from the USDA Guidelines for Obtaining Authorization of Compounds to be used in Meat and Poultry Plants under the former USDA program.
Using products that are listed with NSF indicates your company’s commitment to compliance with federal guidelines. According to the NSF guidelines, hand hygiene products are divided into the following E-rated categories:
Hand-washing products: Acceptable for use as a hand cleaner in and around food processing areas. Hands need not be pre-washed prior to use, but should be thoroughly rinsed with potable water after using the product.
Hand-washing and sanitizing products: Acceptable for use as a one-step wash and sanitizer in and around food processing areas. Hands need not be pre-washed prior to use, but should be thoroughly rinsed with potable water after the use of the product.
Hand sanitizing products: Product is suitable for use in and around food processing areas as a no-rinse hand sanitizing agent. The product may be used only after thoroughly washing and rinsing hands with soap and water.
Hand creams, lotions and powders: Product is limited to use in restrooms, dressing rooms and common welfare areas (non-processing areas). Employees who handle edible products may use these products only when leaving the processing area. Good manufacturing practices (GMPs) dictates that these products must be located a sufficient distance from the processing line and placed in satisfactory dispensers to preclude accidental food product contamination.
Compliance, Assessing Risk
Ensuring that your employees are practicing GMPs and complying with your HACCP guidelines can be difficult. Compliance implies more than getting the product rating right. You have to have a product that squarely addresses your food safety risk while finding product protocols that employees will use. Meeting the skin care needs is a critical step in compliance. I personally have observed employees in process operations wave their hands under a dispenser then sprinkle their hands with water to avoid the dreaded hand wash.