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Hand-washing/sanitation between glove changes

hand washing gloves single-use gloves sanitizer GMP cross-contact

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#1 FurFarmandFork

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Posted 30 March 2017 - 04:09 PM

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:

https://atitesting.c...ent/gloves.html

https://www.med.illi...e Technique.pdf

http://www.ast.org/u...and_Gloving.pdf

 

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 

 

https://www.ncbi.nlm...ooks/NBK133371/


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#2 ChefJamesHB

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Posted 31 March 2017 - 07:35 PM

From my limited understanding of it, its not expected for someone to be wearing multiple layers of gloves on their hands.  (I find that pretty funny though.)        

 

With that being said, when a person removes a dirty pair of gloves, they would be contaminating their hands by the action of removing the gloves, even if they technically didn't touch any of the contaminated areas of the gloves. (i.e. the outer part of the gloves that was in direct contact with the food. Although I'm sure there are ways of removing gloves from your hands that prevents contaminating your hands. But in any case, you cant verify or therein validate that a person removes their gloves in that specific way every single time....unless you have a verification log for glove removal for people to fill out every single time they remove their gloves - single layered or otherwise.)  Even if you did have such a log, they would have to wash their hands afterwards anyway after having touched the log/paperwork/pen, etc.     

 

So if someone removes their gloves, then its generally considered that their hands are thereafter contaminated. Therefore it would be okay for someone to pick something up off the floor, or handle cash, since they are expected to wash their hands prior to donning a new pair of gloves anyway.     In order to put on a new pair of gloves, you would have to touch & handle the new gloves in order to put them on. If you are doing so with unsanitary hands, you are simply contaminating the new pair of gloves before you put them on. Hence why you are required to wash your hands before donning a new pair of gloves, and when changing gloves, or when changing gloves to change tasks, etc.      

 

However, in most cases in the Health care industry, especially in cases of medical surgery that involves regulatory compliance with a Bodily Fluid Exposure Control Plan (ECP), the doctor performing the surgery does not touch the gloves in order to put them on at all. Even after having just washed their hands. The doctors assistant, or nurse, is required to hold open the gloves for the doctor so they can just slide their hands in to put them on.   

 

Now, I personally know that the California Retail Food Code says its okay for a person to wear a pair of single use gloves over a pair of personal protection equipment such as protective gloves - such as what butchers wear - so long as it is not done so to handle RTE product, and the product will immediately thereafter be cooked or processed to minimize or prevent any further adulteration, contamination, or hazard. However, the protective gloves have to either be made out of a material that doesn't allow for food to become stuck to them, or have to be able to be cleaned/washed in a way to prevent any cross-contact / cross-contamination. So if this health inspection finding occurred within California, then technically the inspectors findings were correct.....but only technically because the FDA Food Code, and the California Retail Food Code contradict each other at times.  And there is a gray area to which some establishments must be in compliance to both food codes - potentially including the USDA's CFR.  

 

 

 

That's just my 2 cents.


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#3 Ryan M.

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Posted 05 April 2017 - 02:41 PM

In addition to the above, the other risk is puncture of tear of the outer set of gloves.  How does one know when they have multiple sets of gloves on them?  In almost all cases these would be the same color gloves.


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#4 FurFarmandFork

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Posted 06 April 2017 - 06:22 PM

In addition to the above, the other risk is puncture of tear of the outer set of gloves.  How does one know when they have multiple sets of gloves on them?  In almost all cases these would be the same color gloves.

Ah but many of the double-glove articles for surgery also state that doctors should double glove because they don't notice tears when wearing a single pair. I imagine the incidence is the same in the general population. I'd argue that you're just as likely not to notice with one pair as you would with two.

 

I fundamentally disagree with the notion that if your gloves are contaminated, your hands would be when gloves can be removed aseptically. Maybe that's my main hangup with the regs. 


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#5 Ryan M.

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Posted 06 April 2017 - 06:25 PM

Ah but many of the double-glove articles for surgery also state that doctors should double glove because they don't notice tears when wearing a single pair. I imagine the incidence is the same in the general population. I'd argue that you're just as likely not to notice with one pair as you would with two.

 

I fundamentally disagree with the notion that if your gloves are contaminated, your hands would be when gloves can be removed aseptically. Maybe that's my main hangup with the regs. 

 

Contrast in colors make it more easily visible.  Typically, facilities use blue gloves against the bare hands.  This is definitely noticeable if there is a rip or tear in the glove.  Not always at the time it happens, but by the time you remove the gloves.

 

I do agree with you, if done correctly, one can remove gloves aseptically and not contaminate their hands or another set of gloves in the process.


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