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May-05-2009 04'08 PM Jack In the Box 658 ,2116 2/6 y XC 19 'Cel 00140PM CS HEALTH FOOD DRUG P.214 stas9 of Callforniz Depzrtmant of Health Servl Memorandum Date: December 13,2000 To: Allen Stzo>x,KESS ' From: Jeff Lineberry Subject= Review of the revised Jack-in-the-Box Eggpreparadon pzceedures Jack-in-the-Box,Inc. (71:8)prepares sandwiches made from fried,fresh,shall egga in their restaurants in California. JIB operates ptusuant to a Hazard Analysis Critical Control Point (ld'ACCP)plan in their restaurants. The plan was prepared in accordance with the requirements of Section 124055 of the California Uniform Retail Food Facllities Law (CURFfL). Grill operators break epgs into cooking zings on calibrated griddles at 350 degrees F Grill operators thea use a cloth towel soaked in a sariitizer solution to wipe their Angus before touching ready to eat foods With their bare hands. CURFFL Section 114020(c)(4)requires a thorough hand washing after handling raw foods and before handling ready-to-eat foods. JIB has submitted documentation in support of their HACCP plan procedure in lieu of the CLWI- . handwashing requirement,saying that operational constraints snake a thorough hand wash after cracking each egg impractical, and their procedure offers results equivalent to handwashing. I As a general rule, good sanitary practices do not recognize the use of a sanitizes alone as a j substitute for thorough cleaning. Sanifters generally are not designed to penetrate grease or soil on hands. Where bacteria lurk on hands under grease or soil deposits on hands,sanitizers may not be effective. The mechanical action of rubbing the hands and fingers to'r,cther in combination with warm water and a surfactant is considered to be effective for removal of soil and bacteria from the hands. Additionally,the use of sanitizers on hands is not required by,nor recognized in CURF'FL. However, several key factors work-in favor of acceptance of the JIB procedures. Egg handling must be considered in the context of the oveFall JIB I ALM food safety management system. J1B food handlers are required to wash their hands at least every 60 minutes during their work period, and additionally upon revarning from the toilet,if their hands becomo soiled,after tour- ing their,hair or other parts of their body,etc. The PP procedure does not rely on a simple dip into hand sanitizer,but instead combines wiping of the fingertips with a sanitizes soaked towel. The,mechanical•action of the towel on the fingertips can be expected to add to the effectiveness of the procedure_ 11B has a model program for egg producors and distributors, cmployxng standards that have bean shown to reduce the incidence of S. enre7idW3 in fresh, shell eggs.Studias have shown that the number of pathogenic bacteria in a single fresh,intact, egg is generally a low number,especially in the albumen. JIB does not pool eggs. Pooling of tggs hag be,:n shown to be a major factor outbreaks caused by S. enteriditU. SM managere are trained, and monitor implementation of the HACCP Plan and food safety practices,including pro-car handwashing. Docurnentatibn provided to FDB in support of M procedures used the.bacteria Serratia lnarascens to challe-nge the sanitizer. FDB feels that substitutior,of this Gram negative z9LZ00