Skip to content Skip to navigation

The Mark Twain Solution to Embarrassingly Low Handwashing Rates

Mike Mann's picture

Data-driven continuous improvement for restaurants and hospitals

Hospitals have a great standard for handwashing as does FSMA. It’s Continuous Improvement. Mark Twain agrees, noting that “Continuous improvement is better than delayed perfection.”

Healthcare Kitchens & The Joint Commission

The Joint Commission, healthcare’s performance auditors, encourages a path of measured progress but results are often discouraging because handwash monitoring is limited to observation and no one can afford the luxury of enough observations to make the process mathematically significant. JCAHO does offer a great system to maximize the observational method known as The Targeted Solutions Tool®. Visual observation by caregivers has its advantages and its significance is multiplied when complimented with electronic monitoring.

Observation-only facilities have drifted into a dangerous circumstance by self-reporting a 90% compliance level while the reality is often less than 30%. Electronic handwash monitoring systems expose the fiction perpetuated by observation-only operations.

The FDA Handwashing Standard

The FDA’s recommended standard for handwashing is in their Model Food Code and is not based on Continuous Improvement but rather a series of nine situations calling for a handwash with soap and water (Food Code 2-301.14 When to Wash). This presents a major hurdle for compliance as it is neither based on risk nor measured in any way. There is no weighting of the nine situations. Washing after adjusting your glasses is equivalent to after using toilet facilities.

The Model Food Code's approach is more geared to perfection but their army of local health inspectors end up awarding passing grades to restaurants and healthcare kitchens where handwashing is commonly far less than the existing policies and guidelines. It is common to find handwashing about 30% of the operator's desired goal. The shortfall is so massive, widespread and enduring that a switch to reality is challenging but would clearly be a wise move for public health. This would open the gate to Continuous Improvement.

Here Comes FSMA’s Continuous Improvement Handwashing

FSMA is all about prevention. Continuous Improvement is a natural fit. What was previously considered advice becomes the law. Its view of handwashing represents a cultural shift for operators and their coaches, the cadre of health inspectors.  FSMA’s preventive controls, known by the acronym HARPC (Hazard Analysis and Risk-based Preventive Controls), manufacturers and processors must create and maintain a thorough hygiene discipline throughout their facilities. 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.”  This training includes having hand washing records available for FDA inspection.

FSMA drives a Continuous Improvement culture and is in the best interest of the operator’s goals of public health and brand protection. Continuous Improvement demands data and advanced electronic systems are now available.

“Continuous improvement is better than delayed perfection.” - Mark Twain