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From: Food Quality & Safety magazine, December/January 2012

All Hands on Deck

Planners and staff must cooperate to create sound process control for high-touch surfaces and safer hands

by Jim Mann

An observational study conducted by the CDC that 8.6 hand washes by restaurant staff per employee hour were required to comply with the FDA’s Model Food Code.1 Consensus among both operators and regulators is that that is never going to happen. However, the study’s results beg the question: If 8.6 is the ideal safe level, what is the risk when hand washing frequency is, on average, 0.5 times per employee hour? Based on foodborne illness data and the increasing frequency of shuttered restaurants, the risk is higher than desired. We all know that hand washing rates are well below perfection. In most food service operations, they are also well below a safe level.

This gap between reality and 8.6 hand washes per employee hour creates a dilemma for operator and inspector. If the inspector were to enforce the existing code strictly, virtually all restaurants would be closed. It’s left to the inspector to ask: Which touches shall I disregard? How can I tell the operator which parts of the code to ignore?

The answer to poor hand hygiene performance is not expensive—but neither is it an easy fix. Hand hygiene requires a basic change in the behavior of all involved, from managers to entry-level food workers. An easier step toward safer hands and safer food might be to reduce the touches that demand a hand wash. By improving the cleaning process, we reduce the risk of surface-to-hand contamination by rendering surfaces TouchReady for workers and customers.

The investment required to raise surface cleanliness standards is low and easy to manage. It starts with enhanced process control based on the level of at-risk, high-touch surfaces in the facility.

The Risks of High-Touch Surfaces

High-touch surfaces are bacterial and viral transfer stations. Christine Moe, PhD, the Eugene J. Gangarosa Professor of Safe Water and Sanitation and director of the Center for Global Safe Water at Emory University, found in a study that norovirus, restaurants’ most prolific pathogen, can live on inanimate surfaces from three to six weeks.2 Bacterial pathogens can be equally persistent and even more dangerous.

Gloved and bare hands touch risky surfaces frequently. Some touches are riskier than others, but the food code treats them equally, providing little direction for real-world prioritization. Surfaces need to be prioritized, distinguishing between “must wash” and “nice if” incidents—nice if there is time.

If an operator targets risk by attempting to lower it through improved hygiene, without some level of prioritization, service is likely to suffer and costs to rise disproportionately to the degree of risk reduction.

Not All Touches Are Equal, Are They?

If all touches are considered equal, as in the Model Food Code, then all missed opportunities to wash are equal. While this could on occasion be true scientifically, it doesn’t add up intuitively. It violates a basic premise of adult learning: Training must reflect common sense in order to be respected and implemented.

Common sense for pathogens, unfortunately, includes populating those surfaces that are touched frequently by many. Their goal is survival. High-risk surfaces warrant high scrutiny. Touches must trigger a specific response—a hand wash—as part of a defined process.

Lesser touches can be managed by a backup system that establishes a minimum for hand washes, driven purely by the clock. The danger of this well-intentioned safety net is that it can morph into the default standard, creating a false sense of safety as employees lose sight of the connection between their behaviors and the actual risk.

A restaurant’s inventory of thousands of surfaces can be daunting for a company’s hygiene risk assessment team, the temporary cross-functional team charged with creating and implementing any corrective actions arising from their assessment.

Handwashing For Life advocates breaking the facility down into three areas—kitchen, service area, and restrooms—and attacking each one by determining the 12 surfaces in each area most likely to transfer pathogens to the public or staff, either directly or through the food.

Templates designed to help implement this “dirty dozen” approach are available at

Conditions for Success

The foundation for effective and efficient surface cleanliness is design and equipment specifications. Good choices at the drawing board can be paired with winning supplies that make it easier for the staff to do the right thing at the right time in the right way.

Easy-to-clean surfaces are an obvious choice, as are touch-free faucets and dispensers. High-touch surfaces are best considered as a group requiring frequent cleaning. These are surfaces managed by the operating staff, not by another shift or by a contractor conducting periodic cleaning.

Frequent cleaning of high-touch surfaces allows the use of chemicals that are safer for the worker and the surfaces cleaned. A light-duty sanitizer can be sprayed and wiped with a sanitary single-use paper towel. Disposable wipes are an alternative. Pathogen removal is often easier and faster than killing the organisms. Frequent cleaning by confident staff also minimizes the formation of tenacious biofilms between scheduled cleanings.

In the SaniTwice process, the target surface is sprayed with a light-duty sanitizer, allowed to sit for 15 seconds, and followed by a friction-aided paper towel wipe. This step removes the soil and germs. The protocol is completed with a second spray application, then allowed to air dry.

The Myth of the Reusable Sanitizer Rag

Away-from-home diners deserve clean tables. Bacteria and viruses such as norovirus survive and thrive on these surfaces for hours. Those that are left behind by one ill customer welcome the next.

Cleaning tables with a reusable rag stored in sanitizer is a long-established procedure that is far from a best practice. The Model Food Code only specifies the sanitizer storage method if a reusable rag is to be used; it does not actually suggest storing rags in a sanitizer-filled pail.

An out-of-spec sanitizer level at the source is the first breakdown of this intervention. Sometimes sanitizer is too strong, causing skin irritation for users; most often it’s too weak, and germs are merely pushed around the table, then moved to the next surface.

The best-practice solution is to pitch the pails, remove the rags, and replace them with a spray bottle of cleaner-sanitizer and single-use paper towels or a disposable wipe—both renewable and more controllable resources.

SaniTwice for Surfaces

Another tactic that cleans surfaces effectively with glove-free, skin-friendly cleaners is a process called SaniTwice, originally used as a hand hygiene intervention.

The target surface is sprayed with a light-duty sanitizer, allowed to sit for 15 seconds, and followed by a friction-aided paper towel wipe. This step removes the soil and germs. The protocol is completed with a second spray application, then allowed to air dry, providing the maximum of label-claimed effectiveness. SaniTwice is only recommended for surfaces where final dry times do not interfere with customer comfort.

Train to Standards

Workers must be held accountable for the real-time cleaning of the high-touch “dirty dozen” surfaces in their assigned zone. They own their zones. Visible soils and invisible pathogens are dealt with regularly. Failure to comply with the proper processes must have consequences that include job loss for repeat offenders.

Cleaning procedures are best taught with the support of ATP (adenosine triphosphate) technology, providing the worker with a visible numeric definition of clean within 25 seconds. Standards are set in relative light units (RLUs) as the energy from organic matter is converted to light.

Commitment vs. Compliance

Knowing that surfaces are being monitored for cleanliness underscores the value that management places on the cleaning task and is a source of professional pride: “If my restaurant cares enough to supply me with best practices solutions, the least I can do is execute as a confirmation of my professionalism.”

Clean to sight and touch is not an acceptable standard. Our eyes are our windows on the world, but unfortunately, they are poor tools for assessing the existence of pathogens or determining if a surface has been recently cleaned and is safe to touch. Microbiological swab testing is the fail-safe tool to test for pathogens, but results take days, coming too late both for training and for good decision making in a high-pressured food service operation.

ATP (adenosine triphosphate)
Cleaning procedures are best taught with the support of ATP (adenosine triphosphate) technology, providing the worker with a visible numeric definition of clean within 25 seconds.

ATP technology dramatically reduces the risk of spreading contamination by expanding our ability to ensure that surfaces have been cleaned and are TouchReady.

Logging results extends the value of the RLU data by first reminding us of the value these surfaces represent in serving safe food and providing performance feedback for the professionals involved. Secondly, trends are easily spotted and serve as an early alert for both staff and external auditors.

Another simple and low-cost measurement technique is to mark target surfaces with an invisible UV-sensitive “ink” and track its removal with a pocket UV disclosure lamp. This system can provide a base to give the cleaning team a scorecard by reporting the percentage of targets eliminated (see Mark ’n Monitor at

Commitment to standards drives compliance. Documented results maintain the focus.

Celebrate Success

Success motivates more success. Once the process to control high-touch surface cleanliness is defined, agreed upon, taught, implemented, and verified, share that success with both the team of planners and the staff who carry out the tasks—the owners of the TouchReady zones. Weekly reports are posted for the staff, with periodic summaries provided to risk management, training, and the ownership.

Remember: Repeated success sustains new behaviors and surface-cleanliness standards.

Jim Mann is the founder of Handwashing For Life and the Handwashing Leadership Forum, an alliance of best practice technologies for Overcoming Underwashing across the spectrum of away-from-home food preparation and service locations. Further information on implementation of a HandsOn System is available at


  1. Green LR, Selman CA, Radke V, et al. Food worker hand washing practices: an observation study. J Food Prot. 2006;69(10):2417-2423.
  2. Moe CL, Liu P. Studies of norovirus infectivity, persistence and reduction. Center for Global Safe Water. Rollins School of Public Health. Emory University. Available at: Accessed Oct. 23, 2011.



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