As the North American food manufacturing industry continues to be under the scrutiny of the United States Department of Agriculture, the Food and Drug Administration and the Canadian Food Inspection Agency, food processors must introduce and reinforce “preventive controls” — measures to reduce the spread of food contamination, disease and infection. According to the Infection Prevention and Control Canada, when performed correctly, hand hygiene is the single most effective way to prevent the spread of communicable diseases and infections. However, despite personal hygiene remaining a pre-requisite of any food safety plan, the Food Safety Modernization Act of 2010 (FSMA), doesn’t specifically address hand hygiene in the FDA Good Manufacturing Practice (GMP) regulations updated in 2016.
GMP regulations identify the need for hand-washing facilities that are adequate and convenient, with adequate lighting and running water at a suitable temperature; however, there remain significant information gaps that require food processors to think beyond the quality management system[i]. While the GMP and complementary guidelines from the FDA, Safe Quality Food Institute and the United States Food Code provide guidelines for necessary hand-washing systems and environments, there are few to no instructions focused on the proper method of hand washing. In addition, the GMP regulations do not address the microbiological risks associated with using and cleaning specific equipment such as soap dispensers, towel rolls and hand dryers.
As a result of these information gaps, and in addition to following the GMP requirements, all food processing stakeholders must step-up their hand hygiene procedures:
- To reduce the potential for contamination, and potential water leakage leading to pathogenic microbiological growth, food processors should introduce modernized equipment specifically designed to minimize those risks. This could be accomplished through use of select modern equipment like Tork Foam Skincare Dispenser with Intuition Sensor and Elevation Design with a washdown-ready, touch-free and water-resistant design. Mitigate the potential for further cross-contamination by introducing a touch-free towel dispenser like the Tork Washstation Dispenser.
- It must not be assumed that all employees understand how to practice proper hand hygiene. Management must identify and teach proper hygiene procedures, while monitoring employees to ensure they are properly washing hands, in addition to following other GMP rules throughout their shifts.
The need for proper hand hygiene training and compliance over and above what is outlined in the GMP regulations is made even stronger with the FDA's 2015 update that mandates required training in the principles of food hygiene and food safety, including the importance of employee health and personal hygiene[ii]. As such, food processors must consistently reinforce hygiene procedures while introducing modernized equipment to maximize cleaning effectiveness and minimize potential for contamination.