Let's do a collaborative risk assessment.
I read this article on FSN today where a county restaurant inspector was reviewing observations and made this one:
...I was standing in the kitchen when I observed a chef take off a pair of single use gloves only to expose another pair underneath – a definite food safety violation! When I questioned him, he explained that the sink was “too far away to keep running over there to wash my hands”. I was stunned. As it turned out, he was wearing five pairs of single use gloves simultaneously...
I was nerd sniped, here's where I have some cognitive dissonance with her position.
Legally: absolutely right in it being a violation of many schemes, while it's left ambiguous in the actual FDA food code, FDA has associated guidance covering this issue:
When should food employees wash their hands?
They should do this immediately after engaging in activities that contaminate the hands and:
- When entering a food preparation area;
- Before putting on clean, single-use gloves for working with food and between glove changes;
I have no compliance quandary to argue other than guidance is technically non-enforceable. *eyeroll*
However, from a food safety standpoint, other than you having handled the soiled gloves, I struggle with the idea that there isn't space for this practice in an appropriate context. 5 gloves may be excessive, but I can certainly see an employee donning two pairs so that if they had to jump to a cash register (or pick something off the floor, or press buttons on equipment, or climb a ladder), they could doff the outer pair in a sanitary manner and return to a product contact task.
I can't find any studies to support transmission rates for this activity. However, I struggle with FDA's conclusion here given that in aseptic practices for surgery, surgeons both remove and replace contaminated gloves without rewashing their hands in a sterile field, and some guidance states that they should "remove the outer pair before applying sterile dressing" indicating that the inner pair is cleaner and appropriate for the next sensitive task.
Surgery aseptic technique references:
My brain struggles to agree with the practice being sufficiently clean for surgery, but not food handling in non-aspeptic processing environments.
Areas I'm envisioning where this procedure might be applicable:
- Brewery employee carries a bucket of ingredient up a conveyor and first sanitizes the hatch covering the opening to the fermenting tank. They apply and dry sanitizer to the hatch, remove the outer pair of gloves and then open the hatch and pour the ingredient in using their under pair of gloves. Alternatively, they change gloves between these activities but without a handwash.
- A production employee is stacking cases of product at the end of the line. They notice that an overflow bin is near capacity upstream. They remove their outer pair of gloves or change gloves and enter the product contact area to pour it back onto the line.
- An fruit inspection employee drops something on the floor. They pick it up and throw it away, and quickly change into clean gloves before resuming, or peel off an outer pair.
Does anyone else have data to support or refute this? Only thing I can think of is making a blanket statement that handwashing prior to surgery is held to a higher standard...but then I remember the handwashing compliance rates in healthcare facilities.
An FDA study published in 2004 found food establishments were frequently out of compliance with the Food Code requirements for proper and adequate handwashing. In the study, the percent of food establishments observed to be out of compliance with handwashing requirements ranged from 34% in hospitals to 73% in full-service establishments.
Compliance with hand hygiene practices among health care workers has historically been very low, averaging 39 percent.5