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FSMA Comment Time on Handwashing

Jim Mann's picture

Any operator with the time and patience to page through regulations will find a few references to handwashing at the farm level within the Food Safety Modernization Act. The window to comment on the proposed rules has been extended from its original May 16th deadline to mid September, 2013:


We submitted this comment for field use as it solves several issues and should be an approved option in a variety of situations.

A Dual Hand Sanitizer Protocol

Alcohol hand sanitizer can be deployed effectively in field situations by using a two-step protocol developed for the USA military. For purposes of communication, the system has been dubbed as SaniTwice®.

Step one is a cleaning step, using a full or double dose of sanitizer. Hands are scrubbed vigorously for 20 seconds as if washing. The loosened soil and pathogens are wiped away with a single-use paper towel. Step two is a reapplication of the hand sanitizer, allowing it to dry per label instructions.

SaniTwice can be used in periods where water quality may be in question and under test. It is also a procedure untethered from sinks and water storage, making it more available exactly where you need it and when. This procedure has proven effective even on greasy raw hamburger which is more challenging to remove than dirt.

Effectiveness of the dual sanitizer protocol has been peer reviewed and published in the Journal of Food Protection: SaniTwice »

It has been used successfully for a few years by the Clark County (NV) School District during boil-water advisories.

It is also an easily trained, language-free, procedure which can be further dramatized by doing a visually convincing demonstration using a portable UV light with a tracer chemical like GlitterBug.

Wherever gloves are used, SaniTwice can be used between glove changes.

This hygienic, user friendly protocol also avoids the dangers of the bacteria-challenged open-top soap dispensers and the poor rinsing afforded by restricted quantities of water. Poor rinsing of hands is a common cause of worker dermatitis.


HandsOn™ System

HandsOn System

5 steps to convert underwashing to under control. Set and track your risk-based ServeReady® Hands and TouchReady® Surface standards.

SaniTwice® for Catered Events

SaniTwice for Catered Events

Uncompromised hand cleanliness for those serving food at venues without running water.

Teaching Videos

Teaching Videos

Globally recognized for their ease of use in any language. Available in DVD and MP4 file download.