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Bare Hand Contact Exemption for Pizza Making

Welcome to “my world”. In the wholesaly food industry everyone who touches any product is wearing plastic gloves. Every frozen pizza that you see can make the claim “untouched by human hands”. You are trying to make sense out of a decree issued by your city, county, and state health departments. As you have noticed, it is a VERY rare occasion when a state official will over rule a local health official. The plastic glove is coming to a health department near to you too and probably sooner than later, and trust me, there isn’t much that you can do about it. Fight it if venting makes you feel better, but I’m betting that you won’t being about any change in their attitude. I once tried (in vain) to fight an inspector who made us refrigerate “creme” filled donuts. The donut wasn’t perishable, the “creme” filling was an RTU product, non-refrigerated, there was no dairy product in the “creme” filling what so ever. If it had contained dairy or eggs it would be spelled “cream” filling, and then it would need to be refrigerated, but that was not the case. Even went to the state, and they sided with the local official…we started selling our creme filled bismarks from a new refrigerated display case. Go figure!
When you go with plastic gloves, be sure to have your people trained in their use. Sounds silly, but it is important. The gloves are to protect your customer from YOU, not your employees from the food. They are singly use only, if you put on the gloves, then handle food not a problem, but as soon as you pick up a box and open it, you need to put on a fresh pair of gloves. Making pizza with the gloves on, anster the phone, new gloves again, handle money, yep, new gloves. The purpose of the gloves is to just make it easier to clean your hands. Un-gloved hands are difficult to clean properly, but a gloved hand is pretty easy to clean, so you can wash your hands when wearing gloves, not a problem. The biggest benefit is that it will help to instill consumer confidence in the safety of your food, and it will keep you on the friendly side of your local health department, cross them and they can make life, shall we say “difficult” for you.
Tom Lehmann/The Dough Doctor
 
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Click. Click. BOOM!

PizzaChop, my inspector showed up today and gave me the lowdown that our discussion no longer held, and we are now required to use plastic gloves on the pizza line. OUCH! My only recourse is to file with the State Department of Human Resources an application for a waiver. I’ll start the process pretty soon and see how it goes. I think I have an arguable case to present, just need to structure it and put a procedure plan into a cohesive language they speak.

So. I got a 99 A on my inspection . . . and have the ethical quandary of complying with the glove rule . . . . or feeling froggy that the inspector isn’t due back for 6-12 months and go “bareback”. I am dead certain of the food safety of the procedures we use, and the level of risk is minimal even by the ServSafe as well as the other health code standards . . . but rules are rules. It is simply that definition of “ready-to-eat” that gets it all mucked up.

I’ll let people here know once I get a final application to send to the State agency fora waiver. PJ here in the county is also going to be doing the same waiver application thing. We’ll see who gets a good argument accepted.
 
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Nick it matters little whether you are right or wrong…You may win your case, however, if your customers are bothered by the “no gloves” then you have still lost…
 
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royster13:
Nick it matters little whether you are right or wrong…You may win your case, however, if your customers are bothered by the “no gloves” then you have still lost…
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Absolute agreement there. Win the battle and could still lose the war. Our customers’ consensus through the years has been that they find pizza guys in gloves unnecessary effort. They see everything in the alleys and the other parts of the store to maintain food safety and cleanliness . . . so it appears the carry-over effect of trusting we do clean work in the back is helping at least this far.

I just cannot afford to buy another kitchen staff member to deal with slow-down and work-flow disruption that will happen in our kitchen because right now of the glove thing.
 
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Nick,

I had a lengthy conversation with a food safety industry expert yesterday (was referred by director of Ga Restaurant Assoc) and it sounds like Tom L. is right. This thing is not going away and it is a national issue being driven by the FDA. (It goes even above the state)

I had originally decided on filing a HAACP plan in requesting a waiver but am not sure it is worth the time and effort. (The trademark process was involved, this one looks even more so.) Data must be collected by a 3rd party to prove that pathogens are destroyed during the baking process.

Single use gloves are not required for dough handling, just RTEs on the makeline. (One might argue that the veggies are not RTEs, therefore may be able to get by with bare hand contact, if you’re using two on the makeline.)

It’s too bad as we can all see the ridiculousness of it, but given the public outcry for SAFETY (in view of some recent incidents involving E-coli), it’s somewhat understandable.

I like the earlier suggestion of presenting an unbaked pizza to the inspector as Ready to Eat! (Better yet, send one to the state director.)

Of course, at the end of my conversation yesterday with the food safety expert, she asked me whether I really wanted to become well known among the Health inspectors. I guess I don’t.
 
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pizzachop:
Of course, at the end of my conversation yesterday with the food safety expert, she asked me whether I really wanted to become well known among the Health inspectors. I guess I don’t.
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That is a very pragmatic view. The pendulum is swinging. Get out of its way.

Take hair restraints. There is no real sanitation reason for using them. Seriously. But the perception of sanitation dictates using them.

Now, from a sanitary point of view, Tom pointed out in class that oftentimes gloves cause the wearer to actually behave in an UNsanitary manner. After all, they feel SO clean with those gloves on that they miss the point that the gloves are not there to protect them but to protect the food. So they cross-contaminate.
 
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I will have to ponder the issue some more. It may well be worth being known as the guy who initiates the conversation into the reality of the decision versus the public “warm fuzzy” of it. I could very well find out that my understanding of the microbiology and heat protection are incorrect, and that a 180F pizza doesn’t kill the pathogens in the oven. I could find out that pathogens placed on surface of a frozen chicken fritter due to brief hand contact are not killed in microseconds in 350F oil in my fryer. Done professionally and with reasoned & documented argument, it could be a welcome change from the often shrill outcry and innuendo government agencies often face.

One linchpin to the overall argument is that manufactured, hermetically sealed products (like topping pellets and IQF chicken products) need only be reheated to 135F for immediate service (but 165F for hot holding) . . . cannot see the argument failing at that point, only in the bacteriological study. I want to focus on the actual, real public health risk and continuity of the policy if it seems possible to do without wrenching the policies down harder and more stringent. That last part may not be completely possible. They offer a waiver/variance process, so it is worth considering, especially if it might improve the policy.

No matter how you squint and tilt your head . . . vegetables on a make line that are suitable for immediate consumption in their pre-cooked state are defined as RTE. If it is safely consumed raw, then it is RTE: frozen cookie dough, tomatoes, ham, spinach, Parmesan cheese, canned pineapple, pepperoni, canned jalapenos, salt cured anchovies, pepperoncini peppers . . . even if pathogens are more likely to survive on Mars than the food item, it is legally classified as RTE. Really boggles my mind as I review my pantry of food goods.

Actually, this starts the process of innovation and creativity for someone to develop an affordable product or process for the marketplace that makes this a more viable thing for pizza makers. Some glove, sleeve, chemical treatment of the skin, tool, whatever. Those automated pizza topper thingies from the Big3 shop may become more valuable.
 
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I guess I have had enough battles in life or am closer to my expected mortality than others. I just don’t want to fight ignorance in government or the public. I just want to enjoy my family and business. But if you have the fight in you, pursue it. Hopefully you will help to improve the system.

I have seen so many kitchens that were plain nasty that bare hands were the last thing I worried about. The whole place needed to be fire-sterilized.

How many of you have asked to see the kitchen of the places you like to eat at? It is a real eye-opener. Ask during the slow part of the day. See if they refuse.
 
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