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From: Food Quality & Safety magazine, February/March 2006

Getting a Handle on Food Safety and Hand Hygiene

Reinforcing the Importance of Product Selection

by Dan Mcelroy

Your employees’ hands are a critical control point worth your attention. If employees are not washing their hands, it’s possible the food you are manufacturing isn’t safe or will suffer compromised shelf life. Neither are the goals of a quality manufacturer.

Many cases of foodborne illness are unreported, and it is estimated that every year nearly 76 million people in the United States become ill from pathogens in food. More than 5,000 cases are fatal.1 With that said, effective food safety programs are the primary goal of the modern food processor and their quality assurance departments.

Opportunities for cross-contamination are everywhere employees are located, and include natural human behaviors such as scratching and adjusting glasses or a hairnet. If employees are not taught proper hand hygiene, foodborne pathogens could be transferred to the food by hand contact.

Under the threat of cross-contamination, quality assurance professionals have to sort through confusing product choices, employee skin care needs, regulatory requirements, training, and language barriers to build an effective and compliant program. Unaddressed, poor employee hand hygiene could lead to quality degradation, retained product, downtime, litigation and brand damage, which can ultimately cost time, money and customers.

Regulatory Requirements

Up until 1999, the USDA’s Food Safety and Inspection Service (FSIS) was the regulatory body that approved nonfood compounds and proprietary substances for use in meat and poultry establishments. FSIS is responsible for ensuring that the nation's supply of meat, poultry and egg products is safe, wholesome, and correctly labeled and packaged.

After FSIS announced its discontinuation of the approval program, NSF International - a not-for-profit, non-governmental organization - launched a voluntary Nonfood Compounds Registration Program to re-introduce the previous authorization program. All products used in and around food processing establishments (nonfood compounds), such as hand cleaners and sanitizers as well as hard surface sanitizers are now eligible for NSF listing. NSF listing assures inspection officials and processors that the product formulation and labels have been reviewed and meet appropriate food safety regulations.

NSF listing is based on the NSF Registration Guidelines for Proprietary Substances and Nonfood Compounds. This program reflects the formulation, label and use instruction requirements from the USDA Guidelines for Obtaining Authorization of Compounds to be used in Meat and Poultry Plants under the former USDA program.

Using products that are listed with NSF indicates your company’s commitment to compliance with federal guidelines. According to the NSF guidelines, hand hygiene products are divided into the following E-rated categories:

Hand-washing products: Acceptable for use as a hand cleaner in and around food processing areas. Hands need not be pre-washed prior to use, but should be thoroughly rinsed with potable water after using the product.

Hand-washing and sanitizing products: Acceptable for use as a one-step wash and sanitizer in and around food processing areas. Hands need not be pre-washed prior to use, but should be thoroughly rinsed with potable water after the use of the product.

Hand sanitizing products: Product is suitable for use in and around food processing areas as a no-rinse hand sanitizing agent. The product may be used only after thoroughly washing and rinsing hands with soap and water.

Hand creams, lotions and powders: Product is limited to use in restrooms, dressing rooms and common welfare areas (non-processing areas). Employees who handle edible products may use these products only when leaving the processing area. Good manufacturing practices (GMPs) dictates that these products must be located a sufficient distance from the processing line and placed in satisfactory dispensers to preclude accidental food product contamination.

Compliance, Assessing Risk

Ensuring that your employees are practicing GMPs and complying with your HACCP guidelines can be difficult. Compliance implies more than getting the product rating right. You have to have a product that squarely addresses your food safety risk while finding product protocols that employees will use. Meeting the skin care needs is a critical step in compliance. I personally have observed employees in process operations wave their hands under a dispenser then sprinkle their hands with water to avoid the dreaded hand wash.

Manufacturers of ready-to-eat (RTE) products need to be sure employees have clean hands, since consumers are able to eat the products without further cooking. Bacteria on RTE products can survive long enough to make the consumer ill. Baked goods manufacturers should be aware of the increased risk of spoilage organisms transferring to the products after baking.

Be sure your company’s reputation is not at stake by ensuring your employees comply with GMPs. Here are some items to consider:

Training: Employees need to learn the proper way to wash and sanitize their hands. Your hand hygiene program should include a training program that teaches employees why, when and how to properly wash and sanitize hands.

Language barriers: A language-neutral program is helpful, particularly if you have employees who speak foreign languages.

Soap and Sanitizer Types: Employees are less likely to wash their hands if they have dry skin issues. Moisturizing hand soaps and sanitizers can help address this issue. Another emerging trend that people seem to like is foam soap; they like that the product is pre-lathered when they dispense the soap. (Plus, foam soap is usually more cost effective than liquid or bulk soap.)

Lotions: While lotions are not approved for use with direct food contact, if damaged skin conditions exist, lotions are an effective compliance tool. Remember, cold, harsh conditions exist all year in some process operations.

Gloves: Employees should be aware that even though gloves are worn, hands should still be washed and sanitized.

Company culture: Employees’ behaviors are shaped by the behaviors of management. It’s important to instill the importance of hand hygiene into the culture of your company. Be sure your hand hygiene program is included in office and non-production areas.


As you are ordering products and dispensers for your hand hygiene program, keep in mind three main areas of the plant:

Production Areas: In order to reduce cross-contamination, be sure you have the right hand hygiene products available for use by your employees. Products listed with NSF International indicate your commitment to compliance with federal regulations. Skin-friendly products help encourage use by your employees. Products that have a high efficacy (germ kill) rate ensure that your employees' hands are cleaned properly. Each process in a food processing plant should be evaluated individually, and the correct product for the job should be implemented. For example, if an area requires high-frequency washing, a mild hand-wash is recommended so employees’ hands do not dry out. If hands are irritated by the soap, employees are less likely to wash. If an area is deemed a higher risk for cross-contamination area, such as packaging RTE products, d both a hand cleaner and recommended.

Office: There is an emerging trend among companies to offer employees programs that address smoking, diabetes, fitness, prenatal care and stress. But, a simpler wellness program should include hand hygiene, which can help stop the spread of germs in the work environment. Germs can live on desktops for several days, and, if your office is like most, it isn’t cleaned and disinfected every evening.Germs that may cause illness are spread when one worker uses another workers’ phone or when employees share work spaces.

The best defense against germs in the workplace is handwashing. However, this is not always convenient. A supplement to a handwashing initiative is an alcohol-based instant hand sanitizer. A recent study has shown that proper hand hygiene products can reduce absenteeism by 21 percent.2


Skin disease is the leading cause of occupational illness and one of the most costly and rapidly expanding medical conditions in the U.S.3 Occupational skin disease, also known as contact dermatitis, is a common condition found in manufacturing plants where workers’ hands come in contact with harsh chemicals, water, solvents and other skin irritants. The best strategy for preventing occupational dermatitis is to maintain the skin’s natural barrier. The first step in prevention is to find and reduce skin risks. The second step is providing workers with appropriate skin care products. Depending on the job, the mildest yet effective cleaner should be used. Each area within the plant should be evaluated based on the skin irritants present. A professional skin conditioner should be placed as allowed throughout the plant. Placement of the products and dispensers is key to getting workers in the habit of using them.


  1. Mead PS, Slutsker L, Dietz V, McCaig LF, Bresee JS, Shapiro C, et al. Food-related illness and death in the United States. Emerg Infect Dis 1999; 5:607-17.
  2. FedEx Outcome Study Executive Update: Interim Report, July 27, 2004, (unpublished) GOJO Industries, Inc., 90.3% confidence interval.
  3. Bureau of Labor Statistics, U.S. Department of Labor, December 2004.

Dan McElroy is the market development director for food processing at GOJO Industries, Inc. He is a food safety professional with 25 years experience in developing hygiene systems for Food & Beverage processors. Most recently, he served as the 2005 president of the Ohio Chapter of the International Association for Food Protection. He can be reached at 800-321-9647, ext. 6286 or



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