Food workers should use suitable utensils such as single-use gloves, tongs, deli tissue, spatulas, or dispensing equipment to prevent bare hand contact with ready-to-eat food. The FDA Food Code is clear: employees may not touch exposed ready-to-eat food with their bare hands unless a narrow set of exceptions applies. This rule exists because contamination from infected food workers through bare hand contact is one of the leading contributing factors in foodborne illness outbreaks.
Barriers That Prevent Bare Hand Contact
The FDA Food Code lists five categories of acceptable barriers between a food worker’s hands and ready-to-eat food:
- Single-use gloves: The most common barrier in food service. These are disposable and must never be washed or reused.
- Tongs: Useful for grabbing items like bread rolls, deli meats, or salad ingredients.
- Deli tissue or wax paper: Often used when assembling sandwiches, handling baked goods, or placing items in bags and containers.
- Spatulas and scoops: Used for portioning and plating foods like rice, salads, or spreads.
- Dispensing equipment: Machines or containers designed to portion food without hand contact, such as soft-serve machines or condiment pumps.
The key principle is simple: something must always sit between your skin and food that won’t be cooked again before it’s served. Ready-to-eat food includes anything a customer will eat in the form you’re handling it, from sliced fruit and salads to cooked meats and sandwiches.
Why Bare Hand Contact Is So Risky
CDC data from outbreak investigations between 2014 and 2022 found that contamination from an infectious food worker through bare hand contact accounted for 16.5% of all outbreaks with an identified contributing factor, making it the second most common cause overall. The problem is especially pronounced with viral illnesses like norovirus. During the earliest period studied (2014–2016), bare hand contact by an infectious worker was the single most common contributing factor in viral outbreaks, responsible for 47.1% of cases.
The trend has been improving over time, dropping from 20.5% of outbreaks in the first period to 8.9% in the most recent, likely because of better enforcement of barrier and handwashing rules. But the numbers confirm why the FDA treats this as a priority violation: hands carry bacteria and viruses that no amount of rinsing fully eliminates, and ready-to-eat food gives those pathogens a direct path to the person eating it.
When and How to Change Gloves
Wearing gloves only works if you change them at the right times. Gloves that have been on too long or used across different tasks can spread contamination just as effectively as bare hands. You need to change your gloves:
- As soon as they become dirty or torn
- Before starting a different task
- After any interruption, such as answering a phone or touching a door handle
- After handling raw meat, seafood, or poultry and before touching ready-to-eat food
Wash your hands before putting on a new pair of gloves every time. Gloves are not a substitute for handwashing. They’re an additional layer of protection.
Handwashing as the Foundation
Every barrier method depends on proper handwashing underneath it. The FDA requires washing with warm water and soap for at least 20 seconds. You need to wash your hands before starting food preparation, after touching raw animal products, after using the restroom, after sneezing or coughing, and after handling garbage or cleaning chemicals.
Hand sanitizer is not a replacement for handwashing in food service. The FDA and CDC both position sanitizers as an option only when soap and water aren’t available. In a food establishment, sinks should always be accessible and stocked with soap and paper towels, so there’s no reason to rely on sanitizer alone.
Separating Ready-to-Eat Food From Raw Products
Barriers between hands and food are only part of the picture. Cross-contamination also happens when raw meat, poultry, or seafood comes into contact with ready-to-eat items during storage or prep. Raw animal products should always be stored below ready-to-eat foods in the refrigerator, sealed in containers or bags so juices can’t drip onto anything else. During preparation, use separate cutting boards, knives, and work surfaces for raw and ready-to-eat items.
The 2022 FDA Food Code also added specific temperature rules for ready-to-eat produce and hermetically sealed foods that become temperature-sensitive once they’re cut or opened. These items must start at 70°F (21°C) or below and stay there for no more than four hours. Keeping ready-to-eat food at proper temperatures is another essential layer of protection beyond physical barriers.
The Narrow Exception for Bare Hand Contact
The FDA does allow bare hand contact with ready-to-eat food under very specific conditions, but the requirements are strict enough that most operations don’t pursue them. The establishment must get prior written approval from its regulatory authority, maintain detailed written procedures listing exactly which foods will be touched by bare hands, and document employee training on handwashing, fingernail maintenance, jewelry restrictions, and hygiene practices. Workers must also use at least two additional safety measures, such as double handwashing or nail brushes.
This exception never applies when serving highly susceptible populations, including hospitals, nursing homes, preschools, and similar settings. For most food service operations, it’s far simpler and safer to stick with gloves, tongs, and other utensils than to navigate the documentation and approval process required for bare hand contact.