Hand Washing in the Food Industry

Every time you go to the restroom in a commercial establishment, there are signs commanding that “Employees Must Wash Hands Before Returning to Work.” They are present now in office buildings and department stores, not just restaurants. However, in the food service industry, the signs carry (or should carry) more weight. Good hand hygiene is an important way of controlling the spread of foodborne illness. Just as the signage for mandatory hand washing has evolved, ideas about the proper techniques for effective hand washing and hand hygiene have also changed. The question is, though, has the food industry kept up with the changes?

California Standards

If you work in the food service industry, chances are you have received some sort of food handling certification. California law requires every retail food establishment to have at least one employee to be certified in food safety by passing an approved Food Safety Manager Certification and all others involved in the preparation, storage, or service of food to obtain a Food Handler Card. Of course, premises are also inspected and verified by food inspectors to certify that appropriate facilities are present for washing hands and that the ubiquitous signs are in place. All that being said, though, what do these certifications or inspections tell us about how to wash our hands?

The FDA’s Retail Food Protection: Employee Health and Personal Hygiene Handbook says that employees should wash their hands and exposed arm surfaces frequently for at least 20 seconds.  When they leave the restroom, they should use paper towels or some other barrier to avoid skin contact with any surfaces such as the knobs of the sink and the door of the restroom or any other surface until they reach a sanitized area. Moreover, the FDA says that hands should never be washed in the same sink where food preparation occurs. These recommendations are at odds with the California Retail Food Code that requires 10-15 seconds of washing and allows for air dryers (if you do not have paper towels, how can you use them to turn on and off the water and to open the door?) While it may not seem like a huge difference in time, it is significant enough that the FDA has supported mandating it as a requirement for proper food handling. Moreover, most employees think of hand washing as just that — washing the hands. Both California law and federal recommendations stipulate that any part of the bare arm that is exposed to food (including splatter or residue) is supposed to be washed just like the hands.

While it seems to be the epitome of common sense to assume that we all know how to properly wash our hands, it is not necessarily the case. It is incumbent upon the owner or operator or otherwise certified food manager to understand what the requirement to wash hands actually means. Beyond this, when training associates, it is necessary (as strange as it may seem) to make sure that food handlers are actually shown the process and, as time goes on, observed actually washing their hands. While no technique is 100% effective, the smart food service operator needs to understand the risk minimization benefits that having proper hand hygiene programs brings to the table.

Look at the damage that a corporate giant like Chipotle has endured because of injuries caused in large part by improper hand washing techniques and control. Few businesses can absorb hits like that and hope to thrive. There are ways to minimize risk and maximize opportunity that are so simple that people often miss them  Five or 10 additional seconds of hand washing could make a huge difference. There are professionals who know how to analyze your business and align your processes (regarding anything from hiring and HR policies to purchasing to hand washing policies) to help you be successful. The legal and business professionals at De Cardenas Law Group have years of experience helping guide entrepreneurs and food service leaders in the Las Angeles and San Francisco areas to get ahead in the industry. If you are just starting out or you want to optimize how you do business in the food service sector, give us a call at 626-577-6800 (LA) or 415-590-4869 (San Francisco) or click here to set up your initial consultation and see what we can do for your business.