A: There are several decisions you’ll have to make first: What is the task? Where is the task being done? How long will the task take? Here are some suggestions:
POLY: Low-cost, loose-fitting gloves for light tasks that require changing gloves often.
Task: Regular Poly: Making sandwiches, bagging bagels, plate garnishing, pizza or taco preparation, silverware wrapping, filling ice buckets, food sampling, display case set-up or breakdown.
Task: Elbow-Length Poly: Mixing large containers of salad, breading chicken, bakery dough handling, reaching into deep food containers, emptying, cleaning, and re-assembling softserve ice milk machine. Do not use at heat source cooking areas—grill, fryer, broiler, oven.
VINYL: More durable, closer-fitting gloves for food processing and medium-duty food tasks requiring good dexterity and/or sensitivity; latex-free and appropriate for use near heat source.
Task:Regular Vinyl: Handling sliced cheese, grill line plating area, breakfast grill, cracking eggs, fresh squeezed juice prep, prep of cream-filled pies, pizzas, salads, tacos, ready-to-eat meats such as ham and tuna.
Task:Blue Vinyl: Seafood prep, sushi prep, peeling or dispensing shrimp, raw meat cutting, trimming produce, handling bone-in hams or smoked chops, meat grinder area, vacuum packaging area. Blue Vinyl gloves (color-coded to avoid cross-contamination, especially when handling raw meats and seafood). Avoid cross-contamination by changing gloves after handling raw meats, poultry and seafood.
LATEX: Ultra-formfitting gloves for tasks requiring ultimate dexterity. Use for delicate work requiring fingertip sensitivity.
Task: Handling, slicing, prep, mixture of ready-to-eat foods, cheese slicing area, grill line plating area, breakfast grill, cracking eggs, cake decorating, dough handling, plate garnishing, preparation of appetizer or veggie platters, vacuum packaging area. In case of a latex allergy consult a physician and use vinyl, nitrile, synthetic or poly gloves when handling ready-to-eat foods.
SYNTHETIC: Formfitting gloves for tasks requiring flexibility and dexterity. Use for delicate work requiring fingertip sensitivity. Feels and acts like latex. Ideal for latex sensitive workers.
Task: Handling, slicing, prep, mixture of ready-to-eat foods, slicer area of cheese, grill line plating area, breakfast grill, cracking eggs, cake decorating, dough handling, plate garnishing, preparation of appetizer or veggie platters, vacuum packaging area.
NITRILE: Synthetic disposable gloves for specific tasks requiring good puncture resistance and a high level of dexterity.
Task: Intricate garnishing, handling delicate foods, sushi preparation, de-boning meats, handling hot peppers or shellfish. Use in meat preparation area as this material is very resistant to breaking down when in contact with animal fats. Nitrile is a synthetic material resistant to snags, abrasions or tears.
GLOVE USE IN ITSELF DOES NOT GUARANTEE FOOD SAFETY. ALWAYS WASH HANDS BEFORE AND AFTER USING DISPOSABLE GLOVES.
A: Absolutely! Let’s start with the criteria from the 2005 FDA Food Code. The hands may become contaminated when the food employee engages in specific activities. The increased risk of contamination requires handwashing immediately after the activities listed. The specific examples listed in this Code section are not intended to be all inclusive. Employees must wash their hands after any activity which may result in contamination of the hands. Food employees shall clean their hands and exposed portions of their arms immediately before engaging in food preparation including working with exposed food, clean equipment and utensils, and unwrapped single-service and single-use articles and:
After touching bare human body parts other than clean hands and clean, exposed portions of arms.
After using the toilet room.
After caring for or handling service animals or aquatic animals.
After coughing, sneezing, using a handkerchief or disposable tissue, using tobacco, eating, or drinking.
After handling soiled equipment or utensils.
During food preparation, as often as necessary to remove soil and contamination and to prevent cross contamination when changing tasks.
When switching between working with raw food and working with ready-to-eat food.
Before donning gloves for working with food.
After engaging in other activities that contaminate the hands.
Where to Wash Effective handwashing is essential for minimizing the likelihood of the hands becoming a vehicle of cross contamination. It is important that handwashing be done only at a properly equipped handwashing sink in order to help ensure that food employees effectively clean their hands. Handwashing sinks are to be conveniently located, always accessible for handwashing, maintained so they provide proper water temperatures and pressure, and equipped with suitable hand cleansers, nail brushes, and disposable towels and waste containers, or hand dryers. It is inappropriate to wash hands in a food preparation sink since this may result in avoidable contamination of the sink and the food prepared therein. Service sinks may not be used for food employee handwashing since this practice may introduce additional hand contaminants because these sinks may be used for the disposal of mop water, toxic chemicals, and a variety of other liquid wastes. Such wastes may contain pathogens from cleaning the floors of food preparation areas and toilet rooms and discharges from ill persons. Food employees shall clean their hands in a handwashing sink or approved automatic handwashing facility and may not clean their hands in a sink used for food preparation or warewashing, or in a service sink or a curbed cleaning facility used for the disposal of mop water and similar liquid waste.
A: Absolutely! The hands are particularly important in transmitting foodborne pathogens. Food employees with dirty hands and/or fingernails may contaminate the food being prepared. Therefore, any activity which may contaminate the hands must be followed by thorough handwashing in accordance with the procedures outlined in the 2005 FDA Food Code. Even seemingly healthy employees may serve as reservoirs for pathogenic microorganisms that are transmissible through food. Staphylococci, for example, can be found on the skin and in the mouth, throat, and nose of many employees. The hands of employees can be contaminated by touching their nose or other body parts. Handwashing is a critical factor in reducing fecal-oral pathogens that can be transmitted from hands to RTE food as well as other pathogens that can be transmitted from environmental sources. Many employees fail to wash their hands as often as necessary and even those who do may use flawed techniques. Food employees shall use the following cleaning procedure in the order stated to clean their hands and exposed portions of their arms, including surrogate prosthetic devices for hands and arms:
Rinse under clean, running warm water.
Apply an amount of cleaning compound recommended by the cleaning compound manufacturer.
Rub together vigorously for at least 10 to 15 seconds while: Paying particular attention to removing soil from underneath the fingernails during the cleaning procedure, and creating friction on the surfaces of the hands and arms or surrogate prosthetic devices for hands and arms, finger tips, and areas between the fingers.
Thoroughly rinse under clean, running warm water.
Immediately follow the cleaning procedure with thorough drying using a method as specified in the 2005 FDA Food Code. TO avoid re-contaminating their hands or surrogate prosthetic devices, food employees may use disposable paper towels or similar clean barriers when touching surfaces such as manually operated faucet handles on a handwashing sink or the handle of a restroom door. If approved and capable of removing the types of soils encountered in the food operations involved, an automatic handwashing facility may be used by food employees to clean their hands or surrogate prosthetic devices.
The greatest concentration of microbes exists around and under the fingernails of the hands. The area under the fingernails, known as the “subungal space,” has by far the largest concentration of microbes on the hand and this is also the most difficult area of the hand to decontaminate. Fingernail brushes, if used properly, have been found to be effective tools in decontaminating this area of the hand. Proper use of single-use fingernail brushes, or designated individual fingernail brushes for each employee, during the handwashing procedure can achieve up to a 5-log reduction in microorganisms on the hands. There are two different types of microbes on the hands, transient and resident microbes. Transient microbes consist of contaminating pathogens which are loosely attached to the skin surface and do not survive or multiply. A moderate number of these organisms can be removed with adequate handwashing. Resident microbes consist of a relatively stable population that survive and multiply on the skin and they are not easily washed off the hands. Resident microbes on the hands are usually not a concern for potential contamination in food service. All aspects of proper handwashing are important in reducing microbial transients on the hands. However, friction and water have been found to play the most important role. This is why the amount of time spent scrubbing the hands is critical in proper handwashing. It takes more than just the use of soap and running water to remove the transient pathogens that may be present. It is the abrasive action obtained by vigorously rubbing the surfaces being cleaned that loosens the transient microorganisms on the hands. Research has shown a minimum 10-15 second scrub is necessary to remove transient pathogens from the hands and when an antimicrobial soap is used, a minimum of 15 seconds is required. Soap is important for the surfactant effect in removing soil from the hands and a warm water temperature is important in achieving the maximum surfactant effect of the soap. Every stage in handwashing is equally important and has an additive effect in transient microbial reduction. Therefore, effective handwashing must include scrubbing, rinsing, and drying the hands. When done properly, each stage of handwashing further decreases the transient microbial load on the hands. It is equally important to avoid recontaminating hands by avoiding direct hand contact with heavily contaminated environmental sources, such as manually operated handwashing sink faucets, paper towel dispensers, and rest room door handles after the handwashing procedure. This can be accomplished by obtaining a paper towel from its dispenser before the handwashing procedure, then, after handwashing, using the paper towel to operate the hand sink faucet handles and restroom door handles. Handwashing done properly can result in a 2-3 log reduction in transient bacteria and a 2-log reduction in transient viruses and protozoa. With heavy contamination of transient microbial pathogens, handwashing may be ineffective in completely decontaminating the hands. Therefore, a further intervention such as a barrier between hands and ready-to-eat food is necessary.
A: Follow this chart in determining your responsibilities as a Person in Charge. CHART IMAGE HSP – Highly Susceptible Populations RA – Regulatory Authority Food employees diagnosed with hepatitis A virus are always excluded if diagnosed within 14 days of exhibiting any illness symptom, until at least 7 days after the onset of jaundice, or until medically cleared as specified under subparagraphs 2-201.13(B)(1) – (4). Food employees diagnosed with hepatitis A virus are always excluded if diagnosed within 14 days of exhibiting any illness symptom, until at least 7 days after the onset of jaundice, or until medically cleared as specified under subparagraph 2-201.13(B)(1)-(3).
A: It is necessary to exclude food employees symptomatic with diarrhea, vomiting, or jaundice, or suffering from a disease likely to be transmitted through contamination of food, because of the increased risk that the food being prepared will be contaminated such as with a pathogenic microorganism. However, if the food employee is suffering from vomiting or diarrhea symptoms, and the condition is from a non-infectious condition, Crohn’s disease or an illness during early stages of a pregnancy, the risk of transmitting a pathogenic microorganism is minimal. In this case, the food employee may remain working in a full capacity if they can substantiate that the symptom is from a noninfectious condition. The food employee can substantiate this through providing to the person in charge medical documentation or other documentation proving that the symptom is from a noninfectious condition.
A: If a conditional employee reports a disease or symptom listed in the Food Code and shows that the disease or symptom makes the conditional employee an individual with an ADA disability, the employer may withdraw the job offer only if:
The job involves food handling
The employer determines that either there is no reasonable accommodation that would eliminate the risk of transmitting the disease through food, or any such accommodation would be an undue hardship to the business
There is no need to offer the conditional employee a vacant position not involving food handling as a reasonable accommodation.
It should be noted that the information provided here about the ADA is intended to alert employers to the existence of ADA and related CFR requirements. For a comprehensive understanding of the ADA and its implications, consult the references listed in Annex 2 that relate to this section of the Code or contact the U. S. Equal Employment Opportunity Commission. See the Equal Employment Opportunity Commission’s How to Comply with the Americans with Disabilities Act: A Guide for Restaurants and Other Food Service Employers, found at www.eeoc.gov/facts/restaurant_guide.html or www.eeoc.gov/facts/restaurant_guide_summary.html for detailed information about the interaction between the FDA Food Code and the ADA. The information required from applicants and food employees is designed to identify employees who may be suffering from a disease that can be transmitted through food. It is the responsibility of the permit holder to convey to applicants and employees the importance of notifying the person in charge of changes in their health status. Once notified, the person in charge can take action to prevent the likelihood of the transmission of foodborne illness. Applicants, to whom a conditional offer of employment is extended, and food employees are required to report their specific history of exposure, medical symptoms, and previous illnesses. The symptoms listed in the Food Code may be indicative of a disease that is transmitted through the food supply by infected food employees.
A: NO! Title I of the Americans with Disabilities Act of 1990 (ADA) prohibits medical examinations and inquiries as to the existence, nature, or severity of a disability before extending a conditional offer of employment. In order for the permit holder and the person in charge to be in compliance with this particular aspect of the Code and the ADA, a conditional job offer must be made before making inquiries about the applicant’s health status. When the conditional offer is made to the prospective employee you may then ask them detailed health questions. See Form 1-A in Annex 7. For more detailed information about the interaction between the FDA Food Code and the ADA, consult: How to Comply with the Americans with Disabilities Act: A Guide for Restaurants and Other Food Service Employers, found at www.eeoc.gov/facts/restaurant_guide.html or http://www.eeoc.gov/facts/restaurant_guide_summary.html
A: Yes! The development and effective implementation of an employee health policy based on the provisions in Subpart 2-201 may help to prevent foodborne illness associated with contamination of food by ill or infected food employees. The person in charge and food employees should be familiar with and able to provide the following information through direct dialogue when interviewed by facility managers or regulatory officials. When designing and implementing an employee health policy, the following information should be considered and addressed:
Does the establishment have an Employee Health Policy? If so, are the food employees aware of the employee health policy, and is it available in written format and readily available for food employees?
Does the establishment require conditional employees and food employees to report certain illnesses, conditions, symptoms, and exposures?
Are the reporting requirements explained to all employees?
What are the reporting requirements for conditional employees, food employees, and the food establishment manager?
Are conditional employees asked if they are experiencing certain symptoms or illnesses upon offer of employment? If so, which symptoms or illnesses?
If a food employee reports a diagnosis with one of the 5 listed pathogens in the Food Code, what questions are asked of the food employee? (The first question every food manager should ask a food employee who reports diagnosis with a listed pathogen is if the employee is currently having any symptoms.)
Who does the establishment notify when a food employee reports a diagnosis with one of the listed pathogens?
What gastrointestinal symptoms would require exclusion of a food employee from the food establishment?
What history of exposure is a conditional employee or food employee required to report?
If a food employee reports a gastrointestinal symptom, what criteria are used to allow the employee to return to work?
These questions will certainly help you in establishing an employee health policy in your facility. If you have further questions, see the 2005 FDA Food Code, Annex 7, Forms, Guides and Other Aids for assistance.
A: Yes! Some food employees or conditional employees may report a possible exposure to an agent. For example, a food employee may have attended a function at which the food employee ate food that was associated with an outbreak of shigellosis, but the employee remains well. Such individuals fall into the category of having had a potential exposure and present a lower risk to public health than someone who is either symptomatic or who has a definitive diagnosis. They present a level of risk to public health that is greater than if they had not had the exposure. The approach taken in the Food Code to food employees who have had a potential exposure is based on the incubation times (time between exposure and the onset of symptoms) of the various agents. The times chosen for restriction are the upper end of the average incubation periods for the specific agents. The reasoning is that this will restrict food employees only up to the time when it is unlikely they will develop symptoms. As a further protection to public health, it is recommended that such exposed food employees pay particular attention to personal hygiene and report the onset of any symptoms. This situation describes the fourth level of risk (lowest level of risk) in transmitting pathogens to food. Risk Levels 1, 2 and 3 will be discussed over the next few months. For further information on determining a restriction of an employee see Decision Tree 2 — Annex 3 page 334 in the 2005 FDA Food Code.