FSMA and Hand Washing. Yes, Hand Washing

Embedded in the myriad rules and regulations of the Food Safety Modernization Act (FSMA) is a significant cultural shift in food manufacturing.

How so? The new law requires the food industry (and its many suppliers) to provide day-to-day management of all aspects of food safety, or suffer the consequences of government fines and public opprobrium. This represents a dramatic change from the largely voluntary approach of decades past amid a patchwork of vague, sometimes conflicting laws and regulations.

A perfect example of this transformation involves a simple procedure long associated with public health: hand washing. It’s long been standard practice (and a health code regulation) that employees working around or with food, whether in a restaurant, a growing field, or on a food manufacturing production line must wash their hands – thoroughly and regularly – while on the job.

handwashingPractically speaking, however, various studies over the years indicate that proper hand washing doesn’t occur as regularly or as thoroughly as needed or required. Even the ubiquitous hand sanitizer dispensers don’t offer the germ protection necessary to prevent contamination. Just as problematic is sketchy enforcement of hygiene. For food manufacturers and processors, hygienic requirements have always been nebulous. Many producers and processors have adopted the hand washing procedures outlined in the FDA Food Code or similar procedures. Yet the Food Code is only a set of recommendations and doesn’t carry the force of law.

With FSMA, these recommended procedures now become mandatory. Under FSMA’s required preventive controls,known by the acronym HARPC (Hazard Analysis and Risk-based Preventive Controls), manufacturers must create and maintain a thorough hygiene discipline throughout their facilities. Specifically, the new law says “management of covered facilities must ensure that all employees who manufacture, process, pack or hold food have the necessary education, training, and/or experience and ensure they receive training in the principles of food hygiene, food safety, and employee health and hygiene.” Such training includes thorough and regular briefings on proper hand washing protocols, as well as hand washing records available for FDA inspection.

Regulatory overkill? Perhaps. Hand washing seems like a such a small issue in the midst of a wholesale re-direction of food safety regulations under the Food Safety Modernization Act. Yet hand sanitation is a critical frontline technique to prevent the spread of harmful bacteria that can lead to outbreaks of Hepatitis and other illnesses. This has been the FDA’s intention for decades; now, with FSMA, proper hand washing carries the force of law.

That’s a clear cultural shift that will impact workers, managers, and manufacturers all along the food supply chain.