3.3 Employee Health, Hygiene Policies, & Exclusion/Restriction
Key Takeaways
- The Big 6 foodborne pathogens requiring mandatory notification, exclusion, or restriction under the FDA Food Code are Norovirus, Hepatitis A virus, Shigella spp., Shiga toxin-producing Escherichia coli (STEC), Salmonella Typhi, and Nontyphoidal Salmonella (NTS).
- Exclusion strictly prohibits a food employee from entering any part of a food establishment, whereas Restriction prohibits an employee from working with exposed food, clean equipment, utensils, linens, and unwrapped single-service articles.
- Food employees presenting with jaundice must be immediately excluded from the facility, and reinstatement requires written medical clearance and regulatory approval.
- Handwashing must use potable water at a minimum temperature of 100°F (38°C), incorporate 10–15 seconds of vigorous scrubbing with soap (20 seconds total wash duration), and culminate in drying with single-use towels or heated-air devices.
- The FDA Food Code prohibits bare hand contact with Ready-to-Eat (RTE) foods, requiring single-use gloves, utensils, deli papers, or approved alternative operating procedures with prior regulatory written approval.
3.3 Employee Health, Hygiene Policies, & Exclusion/Restriction
Exam Key: Infected food handlers represent a primary vector for viral and bacterial contamination in food operations. The Person in Charge (PIC) is legally obligated to enforce active managerial control over employee health, including mandatory disease reporting, applying exclusion or restriction controls, and verifying proper handwashing and hygiene practices.
Employee Health Policy & Person in Charge (PIC) Responsibilities
Under Chapter 2 of the FDA Food Code, the permit holder must ensure that the Person in Charge (PIC) is present during all hours of operation. The PIC must demonstrate knowledge of foodborne disease prevention and enforce an explicit Employee Health Policy.
Conditional Employee & Food Employee Reporting Duties
Conditional employees (job applicants offered employment) and active food employees must formally agree to report to the PIC any symptoms, diagnoses, or exposures related to foodborne illness.
The "Big 6" Pathogens
The FDA Food Code designates six high-consequence pathogens—the "Big 6"—that require mandatory notification of the regulatory authority, along with immediate employee exclusion or restriction:
- Norovirus: Leading cause of foodborne illness in the U.S.; highly contagious virus causing acute gastroenteritis with low infectious dose.
- Hepatitis A Virus: Viral pathogen causing severe liver infection, fever, fatigue, and jaundice; long incubation period (15–50 days).
- Shigella spp.: Bacteria causing bacillary dysentery; transmitted via fecal-oral route due to improper hand hygiene.
- Shiga Toxin-Producing Escherichia coli (STEC): Strains producing Shiga toxins (e.g., E. coli O157:H7) causing hemorrhagic colitis and Hemolytic Uremic Syndrome (HUS).
- Salmonella Typhi: Human-restricted bacterium causing typhoid fever, a systemic, life-threatening infection.
- Nontyphoidal Salmonella (NTS): Common foodborne bacterial pathogen associated with poultry, eggs, and cross-contamination.
Exclusion vs. Restriction Definitions
Regulatory actions applied to ill or exposed food handlers fall into two distinct legal classifications:
| Regulatory Action | Formal Definition | Scope of Prohibition |
|---|---|---|
| EXCLUSION | Preventing a person from working as a food employee or entering a food establishment as an employee. | Total Access Ban: Employee cannot enter any operational, storage, office, or break room areas of the facility. |
| RESTRICTION | Limiting the activities of a food employee so that there is no risk of transmitting a foodborne pathogen. | Task-Specific Ban: Employee cannot work with exposed food, clean equipment, clean utensils, clean linens, or unwrapped single-service items. Permitted tasks: Non-food contact roles (e.g., equipment maintenance, office paperwork, cash register without open food handling). |
Decision Criteria: Symptoms, Diagnoses, & Populations
EMPLOYEE HEALTH DECISION MATRIX
Is the Employee Symptomatic?
│
┌────────────────────────┴────────────────────────┐
▼ ▼
[JAUNDICE] [VOMITING / DIARRHEA]
│ │
▼ ▼
EXCLUDE Immediately EXCLUDE Immediately
(Report to Regulatory Authority) (Restricted only under strict
non-HSP SOPs)
Symptom-Based Exclusion Standards
- Jaundice (Yellowing of Skin/Eyes):
- Must be EXCLUDED immediately if jaundice manifested within the past 7 days.
- Must report the case to the regulatory authority.
- Reinstatement requires written medical clearance from a licensed physician AND approval from the regulatory authority.
- Vomiting or Diarrhea:
- Must be EXCLUDED immediately from all food establishments.
- Reinstatement Standard: Asymptomatic for at least 24 hours without anti-diarrheal or anti-emetic medications, OR medical release from a physician.
- Sore Throat with Fever:
- In General Population Facilities: RESTRICT the employee.
- In Highly Susceptible Population (HSP) Facilities (e.g., nursing homes, daycares, hospitals): EXCLUDE the employee.
Pathogen Diagnosis Rules (General Population vs. HSP)
| Pathogen Diagnosis | General Population Facility | Highly Susceptible Population (HSP) Facility |
|---|---|---|
| Norovirus | EXCLUDE | EXCLUDE |
| Hepatitis A | EXCLUDE | EXCLUDE |
| Salmonella Typhi | EXCLUDE | EXCLUDE |
| Shigella spp. | EXCLUDE (or RESTRICT if asymptomatic based on local code) | EXCLUDE |
| STEC | EXCLUDE (or RESTRICT if asymptomatic based on local code) | EXCLUDE |
| Nontyphoidal Salmonella | RESTRICT (if asymptomatic) or EXCLUDE (if symptomatic) | EXCLUDE |
Removal of Exclusion/Restriction for Diagnosed Pathogens
Reinstatement following diagnosis with S. Typhi, Hepatitis A, STEC, or Shigella typically requires written medical release by a physician AND negative laboratory clearance (e.g., two consecutive negative stool cultures taken at least 24 hours apart, and at least 48 hours after cessation of antibiotics).
Personal Hygiene & Handwashing Protocols
Proper Handwashing Procedure (FDA Food Code § 2-301.12)
Handwashing is the single most effective barrier against pathogen transmission. The complete procedure must take at least 20 seconds:
- Water Temperature: Clean running potable water at a minimum temperature of 100°F (38°C).
- Soap Application: Apply manufacturer-recommended quantity of cleaning compound.
- Vigorous Scrubbing: Friction scrub hands, wrists, arms, under fingernails, and between fingers for 10 to 15 seconds.
- Rinsing: Rinse thoroughly under clean running warm water.
- Drying: Dry hands using individual single-use paper towels or an approved heated-air / high-velocity air hand-drying device.
- Faucet/Door Barrier: Use paper towel as a barrier to turn off manual faucet handles and open restroom doors.
Hand Antiseptics (Sanitizers): Hand sanitizers can only be used after proper handwashing; they are never a substitute for washing hands.
Preventing Bare Hand Contact with Ready-to-Eat (RTE) Foods
Bare hand contact with RTE foods is strictly prohibited under FDA Food Code § 3-301.11. Suitable single-use gloves, tongs, spatulas, or deli paper must be used.
- Exception / Alternative Operating Procedure (AOP): Bare hand contact with RTE foods is only allowed in non-HSP facilities if the establishment maintains written SOPs approved by the regulatory authority, including double handwashing, employee health monitoring, and specific sanitation controls.
Gloves, Hair Restraints, & Jewelry Restrictions
- Single-Use Glove Protocol: Wash hands before donning gloves. Change gloves immediately when torn, contaminated, switching tasks, or after interruptions.
- Hair Restraints: Food employees must wear effective hair restraints (nets, caps, beard snoods) that cover all exposed head and facial hair.
- Jewelry Restriction: Food handlers may wear only a plain smooth band ring (such as a wedding band). All other jewelry—including watches, medical alert bracelets on wrists, decorative rings, and exposed body piercings—is prohibited on hands and arms.
Which of the following pathogens is included in the FDA Food Code 'Big 6' that require mandatory reporting and management action?
What is the legal difference between EXCLUSION and RESTRICTION of a food employee?
A food handler presenting with jaundice must be subjected to which mandatory regulatory action?
What is the minimum required water temperature and friction scrub time for proper employee handwashing under the FDA Food Code?