760-1412 General, Facilities and Equipment

This section does not address body art establishments but presents commercial food establishment regulations copied from Article 13 as if they applied, which they don’t.

Under examination of the requirements for food establishments to protect the health of the food supply and body establishments, one finds there are almost no similarity between the two types of establishments except one point we can agree on: they both must be kept clean and in good repair.

Below is the comparison, word for word.
Body Art Article 14 is in bold type, the source document Article 13 760-1360 is in italics for comparison.
Comments are not formatted and are left margin.

Nobody would argue with the opening sentence.
Body Art Establishments must be kept clean and in good repair.

1. Floors, Walls and Ceilings

All floors, walls and ceiling in body art establishments, including doors, windows,
All  floors, walls  and  ceiling  in    food establishments,        including   doors,  windows,

skylights and similar closures and attached equipment such as light fixtures, vent
skylights  and  similar  closures  and  attached  equipment  such  as  light  fixtures,  vent,

covers, wall mounted fans and decorative materials, shall be kept clean and in
covers  wall  mounted  fans  and  decorative  materials,  shall  be  kept  clean and  in

good repair.
good  repair.

Why the elaborate list, but so far so good. 
The following sentence begins the specific food processing standards.

(Body Art Article 14)   compared to  (Article 13)
Studs, joints and rafters, and metal framework shall not be left exposed in the
Studs, joints  and  rafters   and  metal  framework  shall  not  be  left  exposed  in

workstation area.
food preparation or utensil washing areas.

Univ of Florida writes

"The sanitary objectives for interior building design and construction are to:

Minimize potential harborages of pests and microorganisms: maximize cleanability; and maximize the protection of the food products from contamination.

"To design and build in features that protect the food product from contamination should be the ultimate goal of planners and designers."
"Ceilings should meet the same objectives mentioned for walls."
Ceilings serve the purpose of preventing contaminants—dust, condensate, paint chips, etc. –from falling...into the product in process or on finished product.

University of Florida Sanitary Design and Construction of Food Processing and Handling Facilities. http://edis.ifas.ufl.edu/FS120

The dangers that threaten the food supply do not bear any resemblance to body art, for example: dripping grease from the ceiling.

If left exposed in other parts of the establishment, they shall be finished as to
If left  exposed  in  other parts  of the  establishment,  they  shall  be  finished as  to

provide an easily cleanable surface.
provide an easily  cleanable  surface.

 2. The floor surfaces in the workstation area and toilet rooms shall be made of
a. The floor surfaces in food storage and preparation areas... utensil areas,... shall be

smooth, nonabsorbent materials and constructed so as to be easily cleanable.
Smooth  nonabsorbent   materials  so   constructed    as  to   be  easily  cleanable...

The floor of the body art establishment shall be of impervious material. The workstation and toilet room(s) shall be wet-mopped with an approved sanitizer daily.

Whereas Article 14 prohibits carpeting in any area of the body art establishment it does allow carpeting in areas in food establishments.

760-1412(3.c) Properly installed carpeting is permitted in public areas of food establishments, such as vestibules, dining rooms, powder rooms, hallways and lobbies. "The floor of the body art establishment shall be of "impervious material.

CDC Writes June 6, 2003 / 52(RR10);1-42
Guidelines for Environmental Infection Control in Health-Care Facilities
Recommendations of CDC and the Healthcare Infection Control Practices Advisory Committee (HICPAC) Recommendations ---Environmental Services

III. Carpeting and Cloth Furnishings

1. Vacuum carpeting in public areas of health-care facilities and in general patient-care areas regularly with well-maintained equipment designed to minimize dust dispersion (280). Category II
2. Periodically perform a thorough, deep cleaning of carpeting as determined by facility policy by using a method that minimizes the production of aerosols and leaves little or no residue (44). Category II
3. Avoid use of carpeting in high-traffic zones in patient-care areas or where spills are likely (e.g., burn therapy units, operating rooms, laboratories, or intensive care units) (44,305,306). Category IB

Follow appropriate procedures for managing spills on carpeting.

FSM writes

Floors. Floors are the most abused surface in a food processing facility...Food processing areas should have floors covered with an appropriate type of coating...floors can be rinsed, foamed, rinsed, sanitized and still show positive microbial swabs. These organisms can be splashed onto equipment and can be tracked around the facility by processing personnel...As such, floor coverings should be smooth, non-absorbent and easily cleanable." Food Safety Magazine-04,2006

Floors in body art establishments are not exposed to mechanical abuse, chemical abuse, temperature abuse or microbial contamination that are likely to find their way into a tattoo or piercing as compared to food processing facilities.

FSM Writes

Walls. Although not as critical as floors, walls also require a smooth, non-absorbent surface to prevent microbial growth (mold, yeast, bacteria) and absorption of materials containing dust from allergen materials...The more sensitive the product being processed, the more attention must be paid to the wall surfaces. FSM OpCit

Back to Body Art Article 14

3. All walls in the workstation area and walls in toilet rooms shall be easily cleanable,
a. All walls or rooms or areas in which food is prepared, or utensils or hands washed, and walls in toilet rooms shall be easily cleanable

light colored and shall have nonabsorbent washable surfaces.
light  colored  and  shall  have  nonabsorbent  washable  surfaces.
a. Concrete blocks or other masonry used in wall construction shall be finished, covered

3c. Concrete blocks or  other  masonry  used  in  wall  construction  shall  be  finished
and/or sealed so as to provide an easily cleanable surface.
so as to provide a nonabsorbent, easily cleanable surface.

These standards are appropriate for food establishments not body art establishments.
The why:

"3.b...so as to leave no cracks which would permit accumulations of grease or debris or provide harborage for insects, rodents or vermin."
"4. Materials used on ceilings in areas exposed to grease and water shall be finished so as to provide a nonabsorbent, easily cleanable surface." 

Food preparation generates grease, steam, spills, splattering, splashing, aerosolization, food particles and allergens that are transferred to every part of a food establishment. Cleaning, sanitizing and controlling the buildup of food processing residues is a major activity.  Food attracts rodents, insects, mold, mildew and a host of living hazards that are a threat to the health of patrons and safety of the food. There is no rational application of food establishment standards to body art.

The CDC writes

E. Keep housekeeping surfaces (e.g., floors, walls, tabletops) visibly clean on a regular basis and clean up spills promptly (279). Category II

FSM writes

Anything hung on the facility's walls should be hung with a minimum of one inch of space between the back of the item and the wall surface. This allows for improved cleaning access and keeps areas behind electrical boxes and equipment hangers from becoming a habitat for insects or niches for microbial growth and allergen residues to reside. FSM OpCit

DSP writes

Environmental surfaces such as floors, walls and related objects are not associated with transmission of infections to patients or health-care workers and therefore, extraordinary attempts to disinfect these surfaces are not necessary.  Cleaning to remove gross filth and contamination is sufficient.
Environmental surfaces such as adjustment knobs, handles, buttons, instrument trays and carts and lights though never coming in direct contact with clients may frequently become contaminated with client material by being touched, often repeatedly and so require cleaning and disinfection.
p628 Disinfection, Sterilization and Preservation, Block

CDC writes

"CDC's Guideline for Handwashing and Hospital Environmental Control...(Exs. 6-188;6-153)...Specifically, CDC states that while extraordinary attempts to disinfect or sterilize environmental surfaces such as walls and floors are rarely indicated, routine cleaning and removal of soil are recommended." Summary p.79

E. Keep housekeeping surfaces (e.g., floors, walls, tabletops) visibly clean on a regular basis and clean up spills promptly (279). Category II

1. Use a one-step process and an EPA-registered hospital detergent/disinfectant designed for general housekeeping purposes in patient-care areas where

1) uncertainty exists as to the
    nature of the soil on the surfaces (e.g., blood or body fluid contamination versus routine dust or dirt); or
2) uncertainty exists regarding the presence of multidrug resistant organisms
    on such surfaces (272,274,280,281). Category II
2. Detergent and water are adequate for cleaning surfaces in nonpatient-care areas (e.g., administrative offices). Category II
3. Clean and disinfect high-touch surfaces (e.g., doorknobs, bed rails, light switches, and surfaces in and around toilets in patients' rooms) on a more frequent schedule than minimal-touch housekeeping surfaces. Category II
4. Clean walls, blinds, and window curtains in patient-care areas when they are visibly dusty or soiled (270,282--284). Category II

ID writes

In general, environmental surfaces such as floors and walls are not hazardous. Remote surfaces are unlikely to present a problem unless they accumulate dust that can harbor organisms
P115, Infectious Diseases, OpCit

HEIC writes

Environmental sites may become contaminated from infected or colonized patients rather than the other way around. Routine surveillance cultures of the hospital environment, therefore, are unjustified, and environmental cultures made during outbreaks should be interpreted with care.
p1244, Hospital Epidemiology and Infection Control, Mayhall

OSHA writes

"The record...contains evidence that the hepatitis B virus can survive for at least one week dried at room temperatures on environmental surfaces...Transmission of HBV infection as a result of exposure to contaminated environmental surfaces has been documented ...(in)  hemodialysis units. OSHA Section 9 - IX Summary p.3

Regulations requiring certain types of walls, ceilings and floors to decrease infection rates are an unsupported expense, a waste of taxpayer money spent in enforcement and inspection, have no foundation in fact, and are based on misunderstanding the role environmental surfaces such as floors and walls play in infection control.

CDCDC writes

B.      Do not use carpeting in hallways and patient rooms in areas housing immunosuppressed patients (e.g., PE areas) (37,44). Category IB

C.      Avoid using upholstered furniture and furnishings in high-risk patient-care areas and in areas with increased potential for body substance contamination (e.g., pediatrics units) (37). Category II

No recommendation is offered regarding whether upholstered furniture and furnishings should be avoided in general patient-care areas. Unresolved issue.

There is no support for the premises regulations for body art establishments as described in this section.

4. All equipment shall be installed in conformance with federal, state and local plumbing, electrical, fire, and building regulations.

Since businesses are required already, it would seem inappropriate for the Department to take the burden of inspections for conformance to these regulations as well as their own.

5. All body art establishments shall be completely separated by solid partitions or walls extending from floor to ceiling, from any room used for human habitation, any food establishment or room where food is prepared, any hair salon, spa, health club facilities or any other operation or activity that could cause potential contamination of the body art instruments, supplies of equipment for body art procedures, artist work areas and work surfaces.

These are personal views and opinions of Wes Wood and do not necessarily represent the views and opinions of Unimax Supply Co Inc.
Copyright 2006