Foodborne Illness Risk Factors & Risk Control Plan Tool
Risk Factor: Poor Personal Hygiene Data Item #2: Employees Do Not Contact Ready-to-Eat (RTE) Foods With Bare Hands
Why Do You Need a Risk Control Plan? A Risk Control Plan can reduce your risk of causing a foodborne illness outbreak. The process has three parts: 1) identify your chronic issues, 2) determine the root causes, and 3) create a food safety management system. This guidance document can be used to complete an agreement between you and your local regulator to plan for long-term food safety success. PART 1: Identify continuous or chronic out-of-compliance issues • List all the bare hand contact with RTE food issues from previous inspection reports • Identify any pattern or similarity among the citations • List the corrective actions that have already been tried PART 2: Use the table below to determine the root causes • Chronic issues can have multiple root causes • Identify all the people, equipment, economic, or procedural factors that play a role in your recurring issues • This table includes a few examples, but it might not include your specific root cause
What’s the Risk? Viruses such as norovirus can be spread when contaminated hands touch food. Even thorough handwashing might not adequately remove viruses. Since RTE foods receive no further cooking before they are eaten, bare- hand contact must be avoided to prevent passing viruses on to the consumer.
PEOPLE
EQUIPMENT
ECONOMICS
PROCEDURES
What's the Rule? Do not touch RTE
Insufficient budget for necessary volume of gloves and other utensils Insufficient budget for stocking all appropriate sizes of gloves Impermeable gloves not provided for use below cutting glove
People not trained on procedures to avoid bare-hand contact
Insufficient amount of gloves available
Written procedures not clear or correct
foods with bare hands. Single-use gloves or utensils such as tongs, spatulas, and deli papers are acceptable alternatives.
Insufficient stock of properly fitting glove sizes Insufficient stock of utensils: tongs, spatulas, or deli papers
People not trained to recognize RTE foods
Written procedures not followed
Refer to FDA Food Code: 3-301.11
Physical discomfort from frequent glove use People using bare hands based on their cultural or culinary background Person in charge is not a trained food protection manager
Procedures are not monitored, monitoring is not documented No process for taking and documenting corrective actions
Insufficient time committed to train staff on procedures
Utensils not stored conveniently for use
Utensils not appropriate for food handling
Workers incentivized for speed over food safety
Procedure not posted at the point of use
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