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Conference for Food Protection 2020 Issue Form Issue: 2020 I-019 Council Recommendation: Accepted As Submitted Accepted As Amend

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Conference for Food Protection 2020 Issue Form Issue: 2020 I-019 Council Recommendation: Accepted As Submitted Accepted As Amend Conference for Food Protection 2020 Issue Form Issue: 2020 I-019 Council Accepted as Accepted as Recommendation: Submitted Amended No Action Delegate Action: Accepted Rejected All information above the line is for conference use only. Issue History: This issue was submitted for consideration at a previous biennial meeting, see issue: 2018- I-031; new or additional information has been included or attached. Title: Storage in Toilet Rooms Issue you would like the Conference to consider: Amend Food Code 3-305.12(B). 4-401.12(A)(2), and 4-903.12(A)(2) from Core to the appropriate Priority Foundation designation. Public Health Significance: Currently, storing food in a toilet room has the designation as a 'Core' violation. We have the opportunity to address potential contamination from the top source of Food borne Illness in a more proactive manner. By changing the way food and single-service items are stored, we are shutting down a major pathway of pathogenic contamination. Norovirus, which as you know is the leading cause of Foodborne illness (58% of cases) in the United States. CDC states that by 5 years of age, an estimated 1 in 287 of children will be hospitalized, 1 in 14 will visit an emergency room, and 1 in 6 will receive outpatient care for norovirus illness; costing an average of $2 billion per year. (https://www.cdc.gov/norovirus/trends-outbreaks/burden-US.html) 22% of those are directly tied to a commercial kitchen. (https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6361381/) It is a highly contagious virus that requires as few as 10-18 particles to get a person sick. It has the ability to re-infect by remaining on hard surfaces, many weeks after initial contamination. It states directly from the Food Code Annex : "A recent study has also shown that the bathroom environment was identified as a major reservoir of human Norovirus, even in the absence of an ill individual on site. Studies have shown that Norovirus can survive on fomite surfaces for up to at least 5 days at room temperature and that routine cleaning, without a disinfectant specifically to address Norovirus, may be ineffective in eliminating its presence on fomite surfaces and can even serve as a means of spreading the virus to other fomites." The first place a sick person will retreat to (if they are so lucky) will be the toilet room. If this bathroom is a shared bathroom with customers and employees, management might not be privy to outside use by customers who are sick. Research shows that asymptomatic individuals may play more of a role in the transmission than previously thought. (https://www.thelancet.com/journals/eclinm/article/PIIS2589-5370(18)30026-9/fulltext) Employees may not know they have the virus initially, as most do not have sick time pay. Should disinfection of the contaminated area not occur immediately, one study show that the virus particles associated with "toilet plume" be spread even after 6 flushes. (https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4692156/) Storing food, sanitized equipment, linens, single-service and single-use articles in these areas would be directly affected. A proactive approach to preventing further contamination would be designating the aforementioned violations as Priority Foundation. This will accomplish two objectives directly related to food safety. It communicates the importance of minimizing risk to managers and employees. Also, it gives regulators leverage to have these violations corrected sooner than 90 days, although realistically most cores will be addressed during the next routine inspection. If the issue still isn't fixed, it can take up to 3 repeats, which is up to 1.5 years after the initial time it was observed and noted during inspection. A Priority Foundation designation will require a fix within 10 days. 2-501.11 Clean-up of Vomiting and Diarrheal Events requires establishments to have written procedures to address vomiting or diarrheal events. If having the mere written documentation to minimize exposure of consumers, food, and surfaces is a Priority Foundation, then minimizing risk of initial exposure surely would be the same. The following are priority violations that would be supported: 2-201.11 Responsibility of Permit Holder, Person in Charge, and Conditional Employees. 3-101.11 Safe, Unadulterated and Honestly Presented 3-301.11 Preventing contamination from Hands 3-307.11(C)(D) Discarding or Reconditioning Unsafe, Adulterated, or Contaminated Food Recommended Solution: The Conference recommends...: A letter be sent to FDA requesting amending the following sections of the most current addition of the Food Code from Core designation to Priority foundation (Pf) designation: 3-305.12(B), Food Storage, Prohibited Areas to (B) In toilet rooms Pf; 4-401.11 Equipment, Clothes Washers and Dryers and Storage Cabinets, Contamination Prevention (A)(2) In toilet rooms Pf; 4-903.12 Prohibitions (A)(2) In toilet rooms Pf : Submitter Information: Name: Brandon Morrill Organization: Great Lakes Conference on Food Protection Address: 705 North Zeeb City/State/Zip: Ann Arbor, MI 48103 Telephone: 7343691062 E-mail: [email protected] Supporting Attachments: "Quantitative Risk Assessment of Norovirus Transmission" It is the policy of the Conference for Food Protection to not accept Issues that would endorse a brand name or a commercial proprietary process. Risk Analysis, Vol. 37, No. 11, 2017 DOI: 10.1111/risa.12758 Quantitative Risk Assessment of Norovirus Transmission in Food Establishments: Evaluating the Impact of Intervention Strategies and Food Employee Behavior on the Risk Associated with Norovirus in Foods Steven Duret, Regis´ Pouillot, Wendy Fanaselle,∗ Efstathia Papafragkou, Girvin Liggans, Laurie Williams, and Jane M. Van Doren We developed a quantitative risk assessment model using a discrete event framework to quantify and study the risk associated with norovirus transmission to consumers through food contaminated by infected food employees in a retail food setting. This study focused on the impact of ill food workers experiencing symptoms of diarrhea and vomiting and potential control measures for the transmission of norovirus to foods. The model examined the behav- ior of food employees regarding exclusion from work while ill and after symptom resolution and preventive measures limiting food contamination during preparation. The mean num- bers of infected customers estimated for 21 scenarios were compared to the estimate for a baseline scenario representing current practices. Results show that prevention strategies ex- amined could not prevent norovirus transmission to food when a symptomatic employee was present in the food establishment. Compliance with exclusion from work of symptomatic food employees is thus critical, with an estimated range of 75–226% of the baseline mean for full to no compliance, respectively. Results also suggest that efficient handwashing, handwash- ing frequency associated with gloving compliance, and elimination of contact between hands, faucets, and door handles in restrooms reduced the mean number of infected customers to 58%, 62%, and 75% of the baseline, respectively. This study provides quantitative data to evaluate the relative efficacy of policy and practices at retail to reduce norovirus illnesses and provides new insights into the interactions and interplay of prevention strategies and compli- ance in reducing transmission of foodborne norovirus. KEY WORDS: Discrete event model; microbial risk assessment; norovirus; retail food establishment 1. INTRODUCTION cause of foodborne illness globally and within the United States.(2–4) Restaurants are the most com- Noroviruses are often spread through person-to- mon setting (64%) of food preparation reported person contact; however, foodborne transmission can in outbreaks in the United States.(1) Most food- cause widespread exposures and presents important borne norovirus outbreaks linked to food establish- prevention opportunities.(1) Norovirus is the leading ments are traced to contamination of food that is not cooked or otherwise treated before consumption U.S. Food and Drug Administration, Center for Food Safety and (“ready-to-eat” [RTE] food).(4–7) Applied Nutrition, College Park, MD, USA. ∗ The disease is characterized by a sudden onset of Address correspondence to Wendy Fanaselle, U.S. Food and Drug Administration, Center for Food Safety and Applied Nu- vomiting, diarrhea, and abdominal cramps, with a du- trition, 5001 Campus Drive, College Park, MD 20740, USA; tel: ration of one to three days before reaching a full res- 240-402-1561; [email protected]. olution of symptoms.(8) Large numbers of virus are 2080 0272-4332/17/0100-2080$22.00/1 C 2017 The Authors Risk Analysis pub- lished by Wiley Periodicals, Inc. on behalf of Society for Risk Analysis. This is an open access article under the terms of the Creative Commons Attribution-NonCommercial-NoDerivs License, which permits use and distribution in any medium, provided the original work is properly cited, the use is non-commercial and no modifications or adaptations are made. Quantitative Risk Assessment of Norovirus Transmission in Food Establishments 2081 Food Contact Surface (FCS=3) General sengs Nonfood Contact Surface (NFCS=3) Time per Visit Restroom = 5 minutes Time Sequence Serving = 5 minutes Time Sequence Preparaon = 5 minutes Store loop For 1:1000 Disinfecon (QUAT 0.6; chlorine 0.4) Store sengs Food employee 1: Sick, defecate(nDefec), vomit(nVomit) Food employee 2: nonsick (1- PShedders), asymptomac (PShedders), defecate(2) Food employee
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