You won’t find a more debated or controversial topic between food safety inspectors and the restaurant industry than bare hand contact with ready-to-eat foods. According to the FDA, you can’t do it. This results in many chefs having to wear gloves. As an inspector myself, I’ve heard all the arguments:
“I don’t have to wear gloves because I wash my hands so often.
“I can’t prepare the food properly with gloves on.”
“If I can’t feel the fish while cutting it, then I’ll cut my hand!”
“The plastic in the gloves changes the taste of the food.”
For the most part, none of these arguments get very far during an inspection. The food industry either needs to provide better ways to prevent bare hand contact with food or train staff better to prevent it, because it’s critically important.
What’s the Rule for No Bare Hand Contact?
“Except when washing fruits and vegetables, food employees shall not contact exposed ready-to-eat food with their bare hands and shall use suitable utensils such as deli tissue, spatulas, tongs, single-use gloves, or dispensing equipment.” (2009 FDA Food Code)
As you can see, there are other alternatives to gloves, but in many cases wearing gloves is the only option.
Bare Hand Contact = Viruses
There is one very important reason the no bare hand contact rule was put in place—viruses. Recently, I had a discussion with a fellow inspector about this topic and he didn’t seem to know why a rigorous hand washing policy wasn’t good enough. Good hand washing is no defense against persistent viruses. One resilient virus in particular is norovirus. It has quickly jumped to the front as the most prolific foodborne illness today. It is highly contagious. Sick employees can shed the virus through their hands even after they wash them.
According to the CDC, “norovirus is recognized as the leading cause of foodborne-disease outbreaks in the United States. Nearly half of all illnesses associated with foodborne-disease outbreaks reported to CDC during 2006–2007 were attributed to norovirus.” Norovirus can also have a two-day incubation period, making it possible to have an infected food handler spreading the disease without even knowing it, if he or she is directly handling food with infected hands.
Learn more about norovirus on these links:
We Don’t Cover Norovirus Enough
Surveillance for Norovirus Outbreaks
Best Practices to Avoid Bare Hand Contact
Now that we know why the no bare hand contact rule is important, how can we best manage it? Gloves are expensive, cumbersome, high maintenance, and very uncomfortable. It’s understandable why people in the food industry don’t want to wear them. What I tell my clients is to find other ways to prepare food without using hands. Remember, the FDA’s rule lists many other options to gloves: deli tissue, tongs, spatulas, etc. Here are some solutions in use today:
- Putting lemons/limes on drinks: Use toothpicks
- Cutting bread: Stab bread with a large fork and then slice
- Preparing toast: Use deli tissue
- Working on the cook line: Use tongs and spatulas as much as possible
Once these practices are in place, make sure you thoroughly train employees on them. This should be part of a larger food safety training program in your restaurant. It’s very important to change the bad habits of the past and keep moving forward with the best practices you have implemented. It’s a battle every day, but if you don’t stay focused on making proper changes, your staff will always revert back to bad habits of the past and therefore put your business at risk.
The FDA’s rule on bare hand contact will always pose a problem for the food industry. It’s important that the industry continues to find innovative ways to cheaply and efficiently control it. If it can’t, norovirus will continue to be the number one foodborne illness, costing the food industry millions every year. But don’t take my word for it, ask Trostel’s Greenbriar Restaurant and Bar in Johnston, Iowa: Iowa Couple Sues Restaurant After Rehearsal Dinner Sickens Wedding Party
For further help, please feel free to contact me with any food safety needs: dennis@resprofsp.com.
For more information on preventing bare hand contact, the Colorado Department of Public Health and Environment has a good resource:
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