Issue link: http://psai.uberflip.com/i/1026878
P AGE 3 Question of the Week: Hand Sanitizer vs Soap and Water KOS HAND - WRINGING CONTINUED FROM PAGE 2 The critical issue then is this: can we demonstrate that one or the other of these methods is more likely to have a positive im pact on public health? At this point in time, the scientific community does not yet agree on whether hand sanitizer delivers the same results as soa p and water. For example the US Centers for Disease Control (CDC) say hand sanitizers don't kill all kinds of germs, and they might not remove other substances from hands that would be detrimental to health. Meanwhile, a study from the National Institutes of Health (NIH) says hand sanitizers are sometimes more effective than soap and water. Because of the absence of scientific consensus — and the sluggish nature of lawmaking in general — whether it is "le gal" to use hand sanitizer instead of soap and water varies from circumstance to circumstance and jurisdiction to jurisdiction. I n the United States, the US Code of Federal Regulations addressing sanitation on construction sites provides language that is quite specific about requiring hot and cold running water (see for example 29CFR 1926.51(f)(3)(ii) here ). This same section does suggest that hand s anitizer could be used in lieu of soap (29CFR 1926.51(f)(3)( iii), but the presences of sanitizer does not eliminate the need for hot and cold running water. Laws for sanitation in agricultural settings are even more precise, and as with all US guidelines, states, counties, and municipalities may require more than the federal minimum. In Canada the laws are set provincially and they vary. Ontario, for example, also specifically requires hot and cold running water while Nova Scotia sim ply requires some provi sion for hand washing. There are no federal - level laws in the US or Canada regarding sanitation at events of which the PSAI is aware. FEMA provides non - binding guidance to its local - level planners that includes language about "hand - washing stations" and " sinks" but does not address the issue of water vs sanitizer. One could not be blamed for inferring that the language implies the need for soap and water, but it is not specifically stated. All that said, the use of hand sanitizers is widespread. Because t he portable sanitation industry has found that hand sanitizers simplify many parts of providing service - - and there are no federal laws about hand cleansing at events in North America -- they have proliferated. In addition, many northern providers of port able sanitation on work sites have gone over to providing hand sanitizer in lieu of the required hot/cold running water, especially during cold weather, because the alcohol base of th e sanitizer doesn't freeze. The PSAI is aware of a few providers that hav e been called on the carpet about this (usually in Canada or in the US when a union is involved), but so far we are not aware of any fines or other operating consequences that have been levied. Apparently you cannot argue with the practical nature of unfro zen sanitizer versus the alternative in very cold weather. Until this is all sorted out, operators are advised to know what their local law requires and to be aware of the possible consequences should they choose to deviate from it. In instances where loc al law doesn't exist or apply (e.g., special events in North America) hand sanitizer can be a workable alternative. Please note, though, that laws for food service workers are ofte n different than those for event attendees. If the sanitation provider will also be providing facilities for food service workers, it will be important to know those requirements as well and to bid the job with whatever additional equipment may be required to meet their needs. -- kk W EEKLY EDITION SEPTEMBER 12, 2018