What Foodservice Workers Need to Know About the FDA Final Rule on Consumer Antibacterial Soaps

Earlier this month, the FDA issued its Final Rule on antibacterial soap products marketed to consumers or made available for use in public settings. This ruling excludes antibacterial soaps used in foodservice settings, as well as hand sanitizers. In addition, while this rule only applies to a subset of active ingredients and products used outside of healthcare and food handling industries, there might be some confusion as to the regulation’s impact on the foodservice industry. 

The Important Role of Hand Hygiene Plays in Foodservice
Handwashing with soap and water is the first and most important step any restaurant worker can take to ensure the safety of food and reduce the risk of getting sick or making others sick. 

Whether it takes place on the farm where the food is being grown, or in the kitchen (at home or in a restaurant), hand hygiene is vital to preventing our food from becoming contaminated. Also, when people think about hand hygiene in the foodservice industry, they typically think about handwashing with soap and water. 

Antibacterial Soaps and the Foodservice Industry
While the FDA does not specify what type of soap – bland or antibacterial – for foodservice industry workers to use, antibacterial soaps are common.  

Antibacterial soaps are often used because they contain ingredients designed to kill germs on the skin, adding an extra level of protection from microbial contamination. In fact, a 2011 study, published in the Journal of Food Protection, compared bland and antibacterial soaps and found that antibacterial soaps did provide a statistically significant greater reduction in bacteria.

In addition, handwashing technique plays a critical role in reducing the transient, or illness-causing germs, on hands. Yet, oftentimes, handwashing technique is incorrect, and using an antibacterial soap helps kill germs missed by an ineffective washer. 

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All in all, hand hygiene and using the right hand hygiene products play a critical role in food safety.

Risk-Based Handwashing

Changing behaviors within your current culture

The challenge of handwashing in foodservice is rooted in basic human behavior. If the would-be washer can see no reward, he or she becomes a non-washer; this is even true for managers. Handwashing simply becomes a matter of custom, comfort or convenience with no connection to the actual risk. The complexity of a sustainable solution results in operators attacking one barrier at a time, but a holistic approach has a much better chance of success.

Real issues abound. Barriers of language, culture, turnover, absenteeism, productivity, hand sink location, empty dispensers, skin irritation and training time frequently come up as challenges to handwashing at key moments. However, the reality is there is no measurement for a clean hand, no standards for frequency and seldom are employees disciplined for not washing their hands. These barriers actually protect the status quo and endanger the life of the customer, staff and the very business itself.

Handwashing competes with the highly valued indicators of productivity on which managers and staff are measured and rewarded. The risk of a foodborne outbreak is already high but getting much higher by virtue of the current trends in rising punitive damages and threatened executive jail time. Advancements in science like Whole Genome Sequencing (WGS) have equipped the CDC Pulse-Net labs with the capability to identify outbreaks previously missed by first-generation systems. 

Measuring Handwashing
Risk management must play a larger role in fixing the time-hardened handwash behaviors. The answer is in process control for which numbers are needed -numbers to reach and sustain goals via the built-in employee Performance Review structure. The steps for a sustainable solution are to first assess the risk, set standards, set the conditions for success, train and finally monitor to motivate the needed behavior change.

The Handwashing For Life Institute has developed tools to help change handwashing behavior. All of these lead to measurement as a way to motivate and sustain hand cleanliness levels and the behaviors required. 

High-touch surfaces frequently harbor pathogens. High levels of pathogens remain invisible but are more likely to cross-contaminate than those surfaces frequently cleaned and measured with either ATP or UV tracing systems. The measurement increases the cleaning frequency.

Handwashing effectiveness can be given a number by using invisible tracing lotion and scanning with a UV light to illuminate areas missed. This training method adds visual impact that helps a workforce better understand the need for a thorough wash. 

A safe-level frequency of washing hands is an important standard to engage the staff in setting. The number is always imprecise, but it is reached through collaboration with peers and their managers. The most dramatic improvement in handwash frequency occurs with the addition of electronic logging of actual washes and comparing them to the employee-agreed safe level standard. In addition, some firms have developed electronic monitoring solutions to help measure and ensure compliance.

Data converts randomness to a process and drives a sustainable handwashing solution. Handwashing becomes clearly understood as a critical risk-based behavior. Now success can be calibrated, celebrated and perpetuated.

Factory-sealed Dispensing Systems vs. Bulk Soap – What’s the Difference?

Having a good hand hygiene regimen – washing your hands with soap and water or using an alcohol-based hand sanitizer with at least 60% alcohol when soap and water are not available – is one of the most important measures we can all take to help reduce the spread of germs that may cause illness. This is why it is critical for us to ensure we are using the most effective hand hygiene products and dispensing systems.

Soap and hand sanitizer dispensers play a key role in reducing the spread of infection. For example, touch-free dispensers help to prevent the spread of germs and allow for easy access to hand hygiene products. 

Yet, there is one dispensing system to avoid - an open, refillable bulk soap dispenser. Open, refillable bulk soap dispensers are those that are refilled by pouring soap into an open, partially filled reservoir. Continuing to use these types of dispensers actually works against efforts to create a healthy environment. Contaminants can easily enter the dispenser when it is being refilled and through use. Also, the bulk soap container itself can get dirty, spill, or be punctured, depending on where it is stored. 

One way to overcome this challenge is to switch to factory-sealed soap systems, which provide the safe, smart and sustainable solution to reducing contamination risks. Refills sealed at the factory help eliminate the possibility of outside contamination, foreign object ingress and vandalism. These dispensers not only help to keep hands cleaner – they also reduce maintenance and help give your restaurant a cleaner, more professional look. 

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