Calling for Stronger Glove Regulations at the 2025 Conference for Food Protection

In New Zealand, glove compliance for food handling is largely based on FDA Title 21 CFR 177, which regulates gloves only for chemical migration.¹ FDA food-compliant gloves are not tested for microbial contamination or holes and defects. This means that gloves used across New Zealand’s food industries can be legally imported and used, even if they could contain harmful pathogens and physical defects.

At Eagle Protect, we believe this is a critical gap in food safety—and one that puts New Zealand producers, exporters and consumers at risk. Our submission to the 2025 Conference for Food Protection calls for a review of current glove regulations and the adoption of stronger compliance standards, including microbial and physical testing, third-party manufacturing verification, and greater import oversight. With peer-reviewed research confirming the presence of dangerous pathogens like Listeria monocytogenes and Staphylococcus aureus on new unused gloves, it's time to change glove compliance standards to truly protect New Zealand’s food and public health. 

The issue to consider:

Glove contamination risks, due to lax manufacturing and import regulations, are a food safety and public health risk.

The FDA Title 21 Part 110 - Good Manufacturing Practice (GMP 21 CFR 110.10) states gloves must be in an “intact, clean, and sanitary condition” and made from “impermeable” material.²

However, current FDA (21 CFR 177) compliance for food handling only includes chemical migration testing. It does not test for microbial contamination (bioburden) nor performance or defects—in other words, FDA compliance does not regulate gloves to be intact, clean, sanitary or impermeable.

The ease of importing fraudulent, used and repackaged, reject quality gloves was highlighted during the Pandemic. Because of the lack of manufacturing, regulatory and import requirements, this continues to be both a food safety and public health risk.

Public Health Significance: Microbial Contamination of Disposable Gloves

A recent peer-reviewed article in the Journal of Food Protection, “Potential for Glove Risk Amplification via Direct Physical, Chemical, and Microbiological Contamination” highlights the significance of lax disposable glove regulatory oversight and the consequences of this to food safety and public health.³

“Additional research is also needed to understand the hazards represented in the viable microorganisms that come to contaminate gloves during the production process.
Here, we report enterotoxigenic strains of Bacillus cereus and B. anthracis, along with the presence of Listeria monocytogenes, Clostridoides difficile, Staphylococcus aureus, Pseudomonas aeruginosa, and Streptococcus pneumoniae, isolated from unused, disposable gloves.”

Following the high-profile listeriosis outbreaks in 2024, the U.S. Department of Agriculture, Food Safety and Inspection Service (FSIS) is adding broader Listeria species testing to all samples of Ready-to-Eat (RTE) products, environmental samples, and food contact surface samples (including gloves), effective January 2025—to better protect the public from L. monocytogenes.

FSIS Compliance Guideline: Controlling Listeria monocytogenes in Post-lethality Exposed Ready-to-Eat Meat and Poultry Products: ⁴

“For example, employees’ gloves should be identified as FCSs if employees directly handle the product with their gloves.”

Recommended Solutions 

Recommendations for food-handling gloves include:

1. The review and inclusion of bioburden and structural integrity testing (strength, durability, pinhole defects) of food handling gloves, as well as specific toxic chemicals such as phthalates, BPA and PFAS
2. Increased due diligence of manufacturing certifications, including third-party QA verification
3. The review of glove importation regulations, including New Zealand Customs Service (NZ Customs) spot checks of structural integrity and microbial contamination

As part of this submission, Eagle Protect requests that a committee be formed to review the current manufacturing regulations for FDA food-compliant gloves and report back to the 2027 Conference for Food Protection with recommendations, as highlighted in #1, 2, and 3 above.   

 

At Eagle Protect, we’re committed to raising food safety and glove integrity standards in New Zealand and beyond. Our Delta Zero™ testing program is already setting the benchmark for quality, cleanliness, and performance—far beyond current compliance requirements.

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 References:

1. U.S. Food and Drug Administration (FDA). Title 21 CFR Part 177 – Indirect Food Additives: Polymers.
   
   

2. U.S. Food and Drug Administration (FDA). Title 21 Part 110 – Current Good Manufacturing Practice in Manufacturing, Packing, or Holding Human Food.

3. B. S. Michaels, T. Ayers, J. Brooks-McLaughlin, R. J. McLaughlin, K. Sandoval-Warren, C Schlenker, L Ronaldson, S. Ardagh. Potential for glove risk amplification via direct physical, chemical, and microbiological contamination. Journal of Food Protection. 2024; 87(7):100283.

4. U.S. Department of Agriculture, Food Safety and Inspection Service (FSIS). Controlling Listeria monocytogenes in Post-lethality Exposed Ready-to-Eat Meat and Poultry Products.