Hi All
A question for debate
Is the hand sanitizer required to be used inside a Haccp certified kitchens ? if Yes Why ?? and where exactly has to be fixed ?
Regards
hygienic
Posted 03 August 2016 - 05:23 PM
Hi Hygienic,
Is this related to a specific FS Standard or just a random query ?
Kind Regards,
Charles.C
Posted 03 August 2016 - 06:35 PM
Hi All
A question for debate
Is the hand sanitizer required to be used inside a Haccp certified kitchens ? if Yes Why ?? and where exactly has to be fixed ?
Regards
hygienic
Hi, Hygienic;
HACCP is not a certification for facilities, but for individuals charged with the administration of a risk based preventative food safety system. The use of hand sanitizer/soap for hygiene and the location would be established by PRP and GMP policy.
If you wish to include such controls in a food safety plan I would recommend the use of "HARPC"
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Posted 03 August 2016 - 08:26 PM
Hi, Hygienic;
HACCP is not a certification for facilities, but for individuals charged with the administration of a risk based preventative food safety system. The use of hand sanitizer/soap for hygiene and the location would be established by PRP and GMP policy.
If you wish to include such controls in a food safety plan I would recommend the use of "HARPC"
Posted 04 August 2016 - 05:55 AM
Hi Slab
In a simple question , if a soap and twoel are using is it adequate or a sanitizer should be used also ?
IMO it is unlikely that the Sanitation requirements for a HACCP certified kitchen (whatever that means) will omit the use of a sanitizing step (S) following Cleaning © but it might depend on the specific "certification" involved.
If by "Adequate" you mean microbiologically "Safe" food contact surfaces I predict that all FS textbooks will recommend (C+S).
Kind Regards,
Charles.C
Posted 06 August 2016 - 09:33 AM
Hi CharlesIMO it is unlikely that the Sanitation requirements for a HACCP certified kitchen (whatever that means) will omit the use of a sanitizing step (S) following Cleaning © but it might depend on the specific "certification" involved.
If by "Adequate" you mean microbiologically "Safe" food contact surfaces I predict that all FS textbooks will recommend (C+S).
Posted 06 August 2016 - 12:30 PM
Regular hand washing with warm water and soap and especially before starting work, after eating, drinking, smoking, visit the toilet or touching nose etc.
If you wanted to hand sanitize also then that may be a bonus, but I do not see it specified anywhere.
Cheers,
Simon
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Posted 06 August 2016 - 05:13 PM
Hi Charles
Have you seen any food code referred to hand sanitizer that should be available in the kitchens ?
Hi Hygienic,
I assume you are referring to a retail food kitchen.
Try reading the US (Retail) Food Code.
Here is one (local) example of its implementation from, I daresay, a zillion others -
Cleaning and Cleaning Frequency
When designing a sanitation program for a restaurant, objects to be cleaned should have the cleaning frequency designated.
Flatware, dishes, pots, pans, kitchenware and food prep surfaces should be washed and sanitized after each use.Equipment and utensils should be cleaned and sanitized at least every four hours throughout the day, not just at closing if they come in contact with potentially hazardous foods
Sanitizing
Sanitizing is the process of applying a chemical or heat to kill bacteria present on a food contact surface.Improper cleaning of equipment causes nine percent of all foodborne illness.
Cleaning must be performed before sanitizing a surface, or the sanitizer may be ineffective.Cleaning refers to the five step process of: removing gross soils, washing with detergent (110 F water), rinsing with fresh water, sanitizing and air drying.
Sanitizing kills bacteria to reduce the numbers of bacteria present to safe levels.Sanitizing does not necessarily kill all of the bacteria present.
Sanitizing should be done on any surface in a restaurant that contacts food including: counters, plates, flatware, glasses, kettles, mixers, pots, pans and other food preparation equipment. On tables where food is served, sanitizing solution is sprayed onto the tables and the tables are wiped to spread the sanitizer evenly on the table.
In the kitchen, large equipment and food prep tables are cleaned and sanitized using the five step procedure.
When manually sanitizing a hard surface, a chemical is applied to the surface at a certain concentration for a certain amount of time.In a three compartment sink system, pots, pans, utensils and ware may be washed by hand.
Washed and rinsed objects are placed in the sanitizing solution before allowing to air dry. In 2001, the FDA added a temperature requirement for the detergent solution used in washing in a three compartment sink. The detergent solution must be at least 110 F.If the sanitizer is a chemical, like a 50 ppm solution of chlorine bleach or a 200 ppm solution of a quaternary ammonium chloride (quat), the object must be immersed for a minimum of 60 seconds in sanitizing solution of at least 75 F.
Test strips are required to monitor the level of chemical sanitizer present. If sanitizing is being done by hot water in a three compartment sink, the object must be immersed for 30 seconds in 171 F+ water.In both cases the object being sanitized must be allowed to air dry.
Towel drying can cause cross-contamination and thus is unsanitary. Towel drying does not remove bacteria, towels just move the bacteria around.Many restaurants will polish previously sanitized and air dried flatware and glasses. This is an acceptable practice as long as clean, dry cloths are used which are dedicated for this purpose. However, both the ware and the cloth must be clean, dry and sanitary.
Kind Regards,
Charles.C
Posted 06 August 2016 - 05:25 PM
Hi Charles, the OP is talking about hand sanitizers in a kitchen.
Regards,
Simon
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Posted 06 August 2016 - 05:36 PM
You are correct.
Was just going to add this -
-301.16 Hand Antiseptics.
(A) A hand antiseptic used as a topical application, a hand antiseptic solution used as a hand dip, or a hand antiseptic soap shall:
(1) Comply with one of the following:
(a) Be an approved drug that is listed in the FDA publication Approved Drug Products with Therapeutic Equivalence Evaluations as an approved drug based on safety and effectiveness; Pf or
(b) Have active antimicrobial ingredients that are listed in the FDA monograph for OTC Health-Care Antiseptic Drug Products as an antiseptic handwash, Pf and
(2) Comply with one of the following:
(a) Have components that are exempted from the requirement of being listed in federal food additive regulations as specified in 21 CFR 170.39 - Threshold of regulation for substances used in food-contact articles;Pf or
(b) Comply with and be listed in:
(i) 21 CFR 178 - Indirect Food Additives: Adjuvants, Production Aids, and Sanitizers as regulated for use as a food additive with conditions of safe use, Pf or
(ii) 21 CFR 182 - Substances Generally Recognized as Safe, 21 CFR 184 - Direct Food Substances Affirmed as Generally Recognized as Safe, or 21 CFR 186 - Indirect Food Substances Affirmed as Generally Recognized as Safe for use in contact with food, Pf and
(3) Be applied only to hands that are cleaned as specified under § 2-301.12. Pf
(B) If a hand antiseptic or a hand antiseptic solution used as a hand dip does not meet the criteria specified under Subparagraph (A)(2) of this section, use shall be:
(1) Followed by thorough hand rinsing in clean water before hand contact with food or by the use of gloves; Pf or
(2) Limited to situations that involve no direct contact with food by the bare hands. Pf
© A hand antiseptic solution used as a hand dip shall be maintained clean and at a strength equivalent to at least 100 mg/L chlorine. Pf
But, from a brief look, i do not see a statement anywhere that the above is MANDATORY.
A haccp CERTIFIED kitchen remains to be defined.
Kind Regards,
Charles.C
Posted 06 August 2016 - 05:49 PM
addendum -
When can hand sanitizers be used in a food service setting?
The FDA Food Code and the Minnesota Food Code allow the use of hand sanitizers by foodworkers after proper hand washing.
(Procedure)
NOTE:
Your employee hygiene policy should include handwashing procedures, plus guidelines for hand sanitizer use, and exclusion of foodworkers who have symptoms of diarrhea and/or vomiting.
http://www.health.st...handsanifs.html
The interesting point of course is when (if ever) the use of hand sanitizers is recommended.
Kind Regards,
Charles.C
Posted 06 August 2016 - 07:29 PM
Regular hand washing with warm water and soap and especially before starting work, after eating, drinking, smoking, visit the toilet or touching nose etc.
If you wanted to hand sanitize also then that may be a bonus, but I do not see it specified anywhere.
Cheers,
Simon
Posted 06 August 2016 - 07:34 PM
name="Charles.C" post="104641" timestamp="1470504977"]You are correct.
Was just going to add this -
But, from a brief look, i do not see a statement anywhere that the above is MANDATORY.
A haccp CERTIFIED kitchen remains to be defined.
It's really interesting but as you said nothing mandatory except offcourse and no doubt for using anti bacterial hand soap.
Posted 07 August 2016 - 01:18 AM
Hi Hygienic,
Based on a quick survey it seems that in the food industry the inter-relationship between handcleaning and the use of hand sanitizers is rather confused from a scientific POV.
Yr query is the typical one for food contact equipment surfaces, but interest in hand "sanitising" is further complicated due interest by health authorities in using hand sanitizers to replace hand cleaning. There is overlap between authorities in areas like health care and food safety but unfortunately applications / requirements of hand sanitizers in these areas may be dissimilar so that conclusions/data/methods are not directly transferable. The general result seems to be that considerable confusion exists in the food industry regarding (a) the general, quantitative, effectiveness of “hand cleaning”, (b) the general, quantitative, effectiveness of “hand sanitizers”.
In view of the route by which, I think, hand sanitizers have developed, I have included an intro regarding hand cleaners versus hand sanitizers which analyses some of the applicational differences.
The only comments I have seen on the use of hand sanitizers used additionally to hand cleaning in the Food Industry (eg FDA Food Code) appear to imply that “authorities” believe hand cleaning may be useful but not generally necessary (the Food Code itself is fiendishly complicated to read). Food-related data to validate the ability of hand cleaning alone to adequately reduce microbial "contamination" on hands may exist but i haven't seen it yet.
I have added some more food comments following this intro. which is an extract from a 2005 publication (reviewed 2016).
How to Determine which Hand Washing Method to Use
Recommendations for hand washing and hand sanitation for different groups of people can vary depending on their job functions and their personal health requirements. Research has shown that hand sanitizers can be as effective as hand washing only in certain situations. The type of soil which may be present on hands can significantly alter the effectiveness of hand sanitizers. Because dirt, food, or anything else on your hands can make the alcohol in sanitizers less effective, it is important to first wash your hands with soap and water.
Some confusion occurred when the Centers for Disease Control and Prevention (CDC) released the 2002 guidelines "recommending alcohol-based gel as a suitable alternative to hand washing for health-care personnel in health-care settings.” Many healthcare workers must routinely clean their hands multiple times per hour while moving between patients. The use of alcohol gels by staff has been shown to favorably impact hand-cleansing adherence due to time saved over traditional hand washing methods. However, the guidelines apply only to hospitals and clinics. These are not appropriate for and do NOT apply to those people working in foodservice settings or with the general public. The primary reason is that the types and levels of soil on the hands are quite different between these different settings.
In a food service setting, fecal bacteria and enteric viruses, such as Norovirus, are more of a concern. Food workers often have wet hands and hands contaminated with food high in proteins and/or fatty materials. Food proteins and fatty materials can significantly reduce the effectiveness of an alcohol gel. Therefore, soap, friction, and running water still remain the most effective way to remove the types of pathogens food workers might encounter. The FDA Model Food Code Rules and Regulations make the provision that hand sanitizers may be used by food workers in addition to, but not in place of proper hand washing. Because hand sanitizers are considered to be a food additive, only products approved by the FDA may be used.Hand washing guidelines for healthcare workers should not be confused with recommendations for food workers or the general public. For everyone, washing hands with soap and water is sufficient and is still a must. For the general public at home, plain soap and water is adequate for most consumer uses. Dr. Elaine Larson recommends taking the extra precaution of using an alcohol gel or antibacterial soap only in situations such as:
coming in close physical contact with persons at high risk for infection (such as newborns, the very old, or immunosuppressed);
having direct physical contact with someone with an upper respiratory infection, skin infection, or diarrhea; and working in settings where infectious diseases are commonly transmitted, such as food preparation, and/or crowded living areas (child-care centers, preschools, prisons, or chronic-care residences).
edis - hand hygiene,hand sanitizers.pdf 1004.12KB
21 downloads
(TBH i find the inclusion of the general term "food preparation" in last paragraph above rather questionable)
Some of the validatory-related aspects of hand sanitizers are apparently under recent US scrutiny, eg –
http://barfblog.com/tags/sanitizer/
http://www.infection...sanitizers.aspx
http://www.cbc.ca/ne...y-fda-1.3055377
Specifically to yr OP, the results (mainly from US publications relating to foodservice applications) generally considered that hand sanitizers were "acceptable" to be used (typically referenced to FDA), eg files hsg1,2 below. However I did see one definite exception, hsg3 which considered that hand sanitizers definitely not useful due their ineffectiveness as detailed in the file below.
hsg1 - SSOP-HACCP Retail Manual.pdf 320.04KB
23 downloads
hsg2 - Food handler's Manual.pdf 2.06MB
30 downloads
hsg3 - Foodservice Certification Manual.pdf 933.73KB
20 downloads
I find it strange that sanitizers are consistently recommended for food contact equipment surfaces but not for hands but then again, IIRC the other typical interpretation of US Food Code is a necessity to prevent bare hands from contacting RTE food. So some pragmatism is involved perhaps ?.
I guess if yr local situation has no particular regulatory preference and there is no addditional environmental risks to influence the decision, the US viewpoint suggests sanitizers are not required for yr specific context**. Customers might have a different opinion of course. It might also relate to Management's confidence in the implementation of employee handcleaning techniques ?
Interesting to hear any experiences from people in related occupations.
** PS - the above text focuses mainly on general "handcleaning" but "kitchens" may vary in their risk potential for cross-contamination via "hands". Risk assessment is always / inevitably involved.
PPS - antibacterial hand soaps are themselves a contentious issue, eg using triclosan, but that is another topic.
P3S - Note that the above text does not relate to food "Plants" which may have their own requirements regarding hand sanitizers. For example this article -
Kind Regards,
Charles.C
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Posted 13 August 2016 - 10:27 PM
Hi Hygienic,
I recently noticed the document (2009) attached and thought it might be of interest, both from a Foodservice POV and in the context of yr OP.
Serving it Safe - NFSMI workbook.pdf 3.9MB
104 downloads
This is a Course Workbook (145 Pgs) developed by the (US) National Food Service Management Institute (NFSMI) for Foodservice Operatives. Focuses on Food Safety / Sanitation Requirements
It is intended, I think, as a self-training Course/Manual (starting from a basic level) and is presented in, IMO, a highly practical/readable style but also including a wealth of technical (eg Micro.) info. to support the numerous Example Procedures/SOPs, Quizzes (with answers) and Case Studies.
2-3 demo. videos were originally combined with the Course but their absence does not significantly detract from understanding/using the material shown.
In the context of the OP, the text follows a similar style as in some other references.
No mention is made regarding any particular benefit/reason for using hand sanitizers but the Handwashing “Procedure” includes this “Step” –
9. Follow FDA recommendations when using hand sanitizers. These recommendations are as follows:
• Use hand sanitizers only after hands have been properly washed and dried.
• Use only hand sanitizers that comply with the Food Code. Confirm with the manufacturers that the hand sanitizers used meet these requirements.
• Use hand sanitizers in the manner specified by the manufacturer.
I haven't validated this prediction but i anticipate that FDA-regulated Foodservice scenarios in US are expected to implement hand sanitizers (somehow) as per above paragraph. I daresay most State requirements are based on the US Food Code but no idea of actual scope and associated degree of Food Code Text uptake.
It would be useful to see the particular logic/data which justified any hand sanitizing-related comments within the Food Code but so far elusive IMEX.
PS - I noticed the document referenced this other major NFSMI text in the Resources section - National Food Service Management Institute, (2005) - HACCP-based Standard Operating Procedures. This is also attached within this forum (somewhere).
Kind Regards,
Charles.C
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Posted 03 September 2016 - 08:30 AM
Hi Hygienic,
I recently noticed the document (2009) attached and thought it might be of interest, both from a Foodservice POV and in the context of yr OP.
Serving it Safe - NFSMI workbook.pdf
This is a Course Workbook (145 Pgs) developed by the (US) National Food Service Management Institute (NFSMI) for Foodservice Operatives. Focuses on Food Safety / Sanitation Requirements
It is intended, I think, as a self-training Course/Manual (starting from a basic level) and is presented in, IMO, a highly practical/readable style but also including a wealth of technical (eg Micro.) info. to support the numerous Example Procedures/SOPs, Quizzes (with answers) and Case Studies.
2-3 demo. videos were originally combined with the Course but their absence does not significantly detract from understanding/using the material shown.
In the context of the OP, the text follows a similar style as in some other references.
No mention is made regarding any particular benefit/reason for using hand sanitizers but the Handwashing “Procedure” includes this “Step” –
I haven't validated this prediction but i anticipate that FDA-regulated Foodservice scenarios in US are expected to implement hand sanitizers (somehow) as per above paragraph. I daresay most State requirements are based on the US Food Code but no idea of actual scope and associated degree of Food Code Text uptake.
It would be useful to see the particular logic/data which justified any hand sanitizing-related comments within the Food Code but so far elusive IMEX.
PS - I noticed the document referenced this other major NFSMI text in the Resources section - National Food Service Management Institute, (2005) - HACCP-based Standard Operating Procedures. This is also attached within this forum (somewhere).
Hi Charles
sorry for the delay in reply but I have read the course , its really interested , as you said nothing mentioned to sanitizer to be used , and the Hand washing steps mentioned in details in the attached document based on US food code .
So thanks for sharing the information and good documents .
Regards
Hygienic
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Posted 08 September 2016 - 06:07 AM
Hi Hygienic,
JFI I have added some related comments (some Production oriented) which i found later and seemed of interest.
However i have still not found any scientific study supporting the (occasionally) substantial claimed microbiological benefits of hand sanitising additional to handcleaning.
http://www.ifsqn.com...oom/#entry70969
(hand sanitisers required in high care/risk food production by BRC/SQF/IFS Food Standards, and “where required” by FSSC22000)
CFR 110.37
Hand-washing and, where appropriate, hand-sanitizing facilities at each location in the plant where good sanitary practices require employees to wash and/or sanitize their hands.
https://www.accessda...h.cfm?fr=110.37
Hand Sanitizers. Although regulations state that hand sanitizers are not to be used in place of handwashing, risk of contamination can be further reduced by the use of sanitizers after handwashing. “If you just spray hand sanitizer on dirty hands, it won’t have much effect,” Reeder said. The act of rubbing the hands together with soap and water is essential to the removal of surface dirt, after which a sanitizer can act to reach the underlying bacteria as well as any areas that were not throoughly scrubbed. The highest percentage of germs on hands tends to be underneath the nails and cuticle, with the second highest proportion being between the fingers. Using sanitizer after handwashing can help ensure these areas are reached.
http://www.qualityas...tion-practices/
Hand sanitizers are not intended to replace soap in the hand washing process. They are not effective in removing dirt or other organic materials. However, if used after proper hand washing procedures, they can reduce the number of bacteria and viruses that may remain on your hands. The Minnesota Food Code does not require the use of hand sanitizers.
http://www.mda.state...and-gloves.aspx
Washing hands with soap and water is the best way to reduce the number of microbes on them in most situations. If soap and water are not available, use an alcohol-based hand sanitizer that contains at least 60% alcohol.
Alcohol-based hand sanitizers can quickly reduce the number of microbes on hands in some situations, but sanitizers do not eliminate all types of germs.
Hand sanitizers may not be as effective when hands are visibly dirty or greasy.
Swallowing alcohol-based hand sanitizers can cause alcohol poisoning.
Hand sanitizers might not remove harmful chemicals, like pesticides and heavy metals, from hands.
http://www.cdc.gov/h...-sanitizer.html
(the above are all sub-categories on web-page which individuallly expand into details/refs when clicked)
So, after reading all of this, you might be telling yourself, “well, at least hand sanitizer kills all the germs on my hands right? That at least makes it worth it.” Well, unfortunately, it’s not as clear cut as you’d think.
While certain hand sanitizers (specifically, those that contain at least 60% alcohol) are great at killing off microbial life, they can also remove naturally produced oils and beneficial bacteria present on your skin, which, ironically, reduces your body’s defenses against disease.
Not only that, but studies (linked to CDC page above) have also shown that traditional soap and water is more effective at washing away certain kinds of dangerous bacteria. Therefore, unless you have no access to soap and running water, stick to the standard hand-washing method. If you have no other option, then alcohol-based hand sanitizers with no added fragrance are your best bet — just be sure to have some sort of lotion on hand so that you don’t dry your skin out.
Kind Regards,
Charles.C
Posted 10 September 2016 - 12:38 PM
Hi Hygienic,
JFI I have added some related comments (some Production oriented) which i found later and seemed of interest.
However i have still not found any scientific study supporting the (occasionally) substantial claimed microbiological benefits of hand sanitising additional to handcleaning.
http://www.ifsqn.com...oom/#entry70969
(hand sanitisers required in high care/risk food production by BRC/SQF/IFS Food Standards, and “where required” by FSSC22000)
https://www.accessda...h.cfm?fr=110.37
http://www.qualityas...tion-practices/
http://www.mda.state...and-gloves.aspx
http://www.cdc.gov/h...-sanitizer.html
(the above are all sub-categories on web-page which individuallly expand into details/refs when clicked)
Hi Charles :
Fantastic ,so the discussion of the Hand Sanitizer closed and clearly understood , one more thing which I noticed also while I was reading some researches in hand soap, all topics ,articles ,or even guidelines talking about washing hands with Hand Soap , whithout going in deep to talk abut the kind of soap , now most of the chemical companies to gain customers and raise their sales are saying Anti bacterial soaps which are effective and give a good result , but in fact I don't think that there is any microbiological different results , I want to reach that is not important the kind of soap whether antibacterial or normal , the important is to give a good micro result when there is a hand swap test .
Are you agree with this ??
Regards
Hygienic
Posted 11 September 2016 - 06:53 AM
Hi Hygienic,
Agreed in the context of above food literature references and particularly inasmuch as I cannot find any publications/validations which validate a contrary opinion. Maybe someone else can ?
Again, I can envisage various scenarios which might (rightly or wrongly) promote "conservative" employee handwashing procedures to be employed. For example if faced with a Regulatory situation that detection of certain pathogens in one’s end product (or an Employee's swabbed hands) would result in a Lot Rejection/Public Health issues. A question of Risk Assesssment (eg History/Product/Process/Environment)/financial Loss perhaps.
Kind Regards,
Charles.C
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