According to CDC data, poor personal hygiene of food workers was the second leading cause of foodborne illness in the United States during the five-year period from 1988-1992. The CDC has also reported that hands are the most common means by which enteric viruses are transmitted, and that contamination of food by an infected food worker is the most common mode of transmission of Hepatitis A in foodborne disease outbreaks. In addition, Norwalk-like viruses are the leading cause of foodborne illness in Minnesota according to Minnesota Department of Health. Depending upon the level of contamination of the hands, handwashing alone may not be adequate in preventing the transmission of viral and protozoan microbes from infected food workers to ready to eat foods.


Minnesota Rules 4626.0225, 3-301.11 a-d, (Minnesota Food Code), addresses limiting bare hand contact with ready-to-eat (RTE) food. This policy provides further clarification and guidance on this issue.


Bare hand contact with RTE food is not permitted unless there is no reasonable or practical alternative. Bare hand contact is permitted only if the following procedures are implemented in the foodservice facility:

  1. Identify all procedures in the establishment where bare hand contact with RTE food is occurring.
  2. Consider alternatives to bare hand contact and try them. An alternative to bare hand contact is always the first method of choice when handling RTE food. Alternatives can include, but are not limited to tongs, deli tissues, gloves, scoops, etc.
  3. Wash hand prior to handling RTE food and as often as necessary in accordance with the Minnesota Food Code 4626.0070 (How to Wash) and 4626.0075 (When to Wash).
  4. If a RTE food must be handled with bare hands, a written procedure - to include handwashing as the first step - must be established for the specific food item.

Responsibilities of the foodservice manager or the person-in-charge with respect to limiting direct hand contact with RTE foods are:

  1. Establish and follow policies and procedures regarding employee health to include "Reporting Diseases and Medical Conditions" and "Exclusions and Restrictions of Ill Food Employees" (4626.0040 - 4626.0060).
  2. Check employees' hands daily for cuts, burns, infections, bandages, jewelry, etc.
  3. Provide proper protection in the event of cuts, burns, infections, etc. (4626.0040)
  4. Ensure that handwashing stations are convenient, accessible and properly equipped at all times.
  5. Provide handwashing training and verify that the employees understand handwashing procedures.
  6. Routinely monitor employees' handwashing to ensure they are effectively cleaning their hands (4626.0035 (D)).