Hand hygiene is one of the most effective ways to prevent foodborne illness, which is why regulatory bodies, like the U.S. Food and Drug Administration (FDA), have established clear rules for food service workers. These rules are designed to interrupt the transmission of harmful pathogens, such as Norovirus and Salmonella, from hands to food. While frequent washing is the safest practice, exceptions exist for activities that pose a low risk of contamination or where other safety measures are used. Understanding the difference between mandatory washing events and low-risk activities is essential for maintaining a safe food environment.
The Critical Mandates: When Handwashing is Non-Negotiable
The FDA Food Code, which serves as the foundation for most local and state health regulations, details specific situations where handwashing is mandatory and cannot be skipped or delayed. These mandates are triggered by events that carry a high likelihood of transferring microorganisms to the hands. Using the restroom, for instance, is a universally recognized contamination event that requires immediate and thorough handwashing before returning to any work area.
Handling raw animal products, including meat, poultry, and seafood, is another high-risk situation that demands immediate handwashing due to the presence of pathogens like E. coli or Campylobacter. Workers must also wash their hands after:
- Touching the face, hair, or any exposed part of the body other than clean hands.
- Sneezing, coughing, or using a tissue.
- Engaging in activities like smoking, eating, or drinking.
How Barriers Replace Direct Hand Contact
In many food service operations, the requirement is to prevent bare hand contact with ready-to-eat (RTE) foods. RTE foods are items that will not undergo further cooking to eliminate pathogens, making them vulnerable to contamination. In these contexts, the use of physical barriers effectively replaces the need for continuous handwashing between handling different RTE items.
Approved barriers include single-use gloves, tongs, spatulas, deli tissue, or other dispensing equipment. For instance, a worker can use tongs to place salad greens on a plate and then immediately use deli paper to pick up a sandwich roll without washing hands in between, provided the utensils remain clean. Single-use gloves are not a substitute for handwashing; hands must be washed thoroughly before donning a fresh pair. Gloves must be changed immediately if they become torn, soiled, or if the worker switches from handling raw food to RTE food.
Tasks That Do Not Require Immediate Washing
A worker is not required to wash their hands immediately when performing non-food contact tasks that do not involve a significant contamination event. These tasks typically shift the worker away from the food preparation area or involve handling items that are not food.
Examples include:
- Handling money or taking customer orders at a register.
- Delivering food to a table.
- Wiping down non-food contact surfaces, such as a dining table.
- Taking out the trash.
In these cases, the regulatory focus shifts from immediate washing to washing before the next food-contact activity begins. The worker must thoroughly wash their hands before touching any food, clean equipment, or utensils, ensuring that any contaminants picked up are removed.