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Bare Hand Contact with Ready
to Eat Food
Section 114020 of the California Uniform Retail Food Facilities Law
(CURFFL) specifies that employees may not contaminate food, food contact surfaces, or
utensils. The section further specifies a number of actions employees must take to prevent
contamination.
This notice is being issued in an effort to clarify the requirements of
Section 114020 and as a guide to local enforcement agents in implementation of this
section.
The potential for contamination of food by food handlers has been
realized on too many occasions, sometimes resulting in foodborne illness. Pathogenic
bacteria from infected employees may be transferred from the nose or mouth to the hands
and then to food. Cuts and sores may contain harmful bacteria or toxins which are carried
into food. Lack of proper handwashing following use of the toilet may result in viral or
bacterial food contamination. Microorganisms from some raw animal food products (e.g.
poultry, hamburger) may cross-contaminate cooked ready-to-eat foods if proper handwashing
is not perform between food preparation steps. Food servers who contact customers, dirty
dishes, or soiled surfaces with their hands may transfer contaminates to other foods just
before serving.
Basic Requirements
All employees must wash their hands and arms before beginning work and
after using the toilet. This includes food preparers, dishwashers, buspersons, servers and
anyone else who has contact with food, food utensils, or food equipment.
All employees must wash their hands and arms whenever they become soiled
for whatever reason. This includes all those listed above.
Use of Gloves by Food Employees
Glove use by persons in contact with food or food contact surfaces is
mandated when there are cuts, sores, or rashes on the hands or arms and when the hands and
arms are not cleanable because of the presence of artificial fingernails, dirty
fingernails, intricate jewelry, or orthopedic support devices (casts, braces, ace
bandages, etc.) which cannot be adequately cleaned.
It is extremely important that persons using gloves be properly trained
in the safe use of gloves. Hands and arms must be washed before donning gloves. Care must
be taken to avoid contamination of gloves through deliberate or inadvertent contact with
unsanitary surfaces. Gloves should be changed frequently. Gloves which are to be reused
after removal must be carefully stored to avoid contamination. Some examples of
unacceptable places to store gloves are pockets, the floor, in the waistband or under a
belt, on soiled counters or cutting boards, or in a hat. Gloved hands are subject to the
same handwashing requirements as ungloved hands. Food handlers who work in moist
environments and wear gloves should take care to avoid skin irritation and subsequent
rashes which may develop.
Bare Hand Contact with Ready to Eat Food
As a general rule, bare hand contact with ready-to-eat food
should be avoided to the extent possible by all employees. This is most often
accomplished through the use of utensils such as tongs, tissues, forks, scoops, or gloves.
Food preparers may touch ready-to-eat food with their bare hands when necessary provided
they strictly adhere to the handwashing requirements specified in Section 114020. Servers
are specifically prohibited from touching ready-to-eat food with their bare hands. This is
because servers, while they are subject to the basic handwashing requirements, have
contact with customers, dirty dishes, etc. in the normal course of their duties. It is not
reasonable that they wash their hands after each occurrence. Therefore, they must use a
utensil when handling ready-to-eat food.
Examples
In a quick service restaurant there are a number of employees with
specific work stations.
What are the rules on bare hand contact?
Employees assembling sandwiches or salads may contact ready-to-eat foods with their bare
hands (provided they have no cuts, sores, artificial nails, etc.), but should take
advantage of utensils where available. This includes paper wraps and packages, tongs,
scoops, etc. Placing of condiments such as tomatoes, onions, pickles, etc. with bare hands
is acceptable. Other employees (cashiers, beverage servers, servers) may not touch
ready-to-eat food unless they wash their hands prior to contact. If the food preparer
fills in at a server position he or she must wash their hands before returning to a food
preparation station.
What about the roving supervisor or manager who fills in
at various places in the operation? The manager/supervisor who fills orders,
makes sandwiches, accepts money and cooks must adhere to all handwashing requirements. He
or she must wash hands and arms or make sure to avoid bare hand contact with ready-to-eat
food after serving customers or handling used trays or customer utensils.
What about servers who have responsibility for food
preparation activities such as salad assembly, making toast, etc.? Servers who
assemble salads, make toast, cut fruit, fill bread baskets, or cut pies, cakes, and other
desserts must avoid any bare hand contact with these foods by using tongs, tissues, or
other utensils unless they wash their hands before each occasion they prepare these foods.
When customers request that uneaten food be placed into a "take home" container
the server must avoid bare hand contact with the food.
What about the single employee operation? When a
single employee is responsible for taking orders, preparing food, and serving it bare hand
contact with ready-to-eat food must be avoided through the use of gloves or utensils or
hands and arms must be washed between each order.
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