Feeding America continues to be a critical role for the food industry. But, whether operating from your manufacturing or retail site, or your home office (or kitchen table!), you are likely finding that the COVID-19 situation is continually drawing you away from what previously had been your primary duties. Whether it’s contending with a reduced workforce, developing and implementing pandemic-related policies, or simply trying to stay on top of all the new science and restrictions, today’s added duties and stresses are impacting every facet of the food industry. Despite that, it is critical that food safety remain a top priority, which, unfortunately, means one more COVID-19-related duty: assessing the impacts to ensure you are aware of any gaps in food safety that are arising, and ensuring against the temptation to “cut corners” on food safety pre-requisites and preventive controls – both within your establishment and throughout your supply chain. Some of the areas on which to focus are an assessment of the impacts of: 1. Increased absenteeism. Do you have access to temporary workers? Can you cross-train employees? Can part-time or seasonal workers be moved to full-time? Are you actively seeking workers? 2. Food safety training. Bringing in new or cross-trained workers means ensuring that they have a full understanding of your food safety requirements and are focused on applying them. Building out your food safety culture may not be top of mind – or even very easy – during the pandemic, but it is all the more critical that everyone ensure it receive as much focus as worker safety. 3. Worker safety. COVID-19 has brought a number of new employee health and safety issues to the forefront. One advantage of the food industry is its long-held requirements for hygiene and handwashing – two of the key protections against coronavirus infections. A key disadvantage is the difficulty of enacting a six-foot “social distancing” barrier between employees. In some facilities, it will be a significant challenge, in others it will not be possible. Just last week, FDA addressed that issue, citing the CDC updated recommendation for the use of simple cloth face coverings as a voluntary measure where other social distancing measures are difficult to maintain. Additionally, food industry workers who don’t typically wears masks as part of their jobs are recommended to maintain the face coverings in accordance with FDA’s Model Food Code sections 4-801.11 Clean Linens and 4.802.11 Specifications and launder reusable face coverings before each daily use. Note, as well, that CDC recommends against the use of surgical masks or N-95 respirators, as they are critical supplies that must continue to be reserved for healthcare workers and other medical first responders. (For more information, see CDC’s additional information on the use of face coverings, including washing instructions and how to make homemade face covers. 4. Cleaning and sanitation. Like employee hygiene, the food industry has always had extensive and essential cleaning and sanitation requirements, with FDA-regulated food manufacturers required to follow Current Good Manufacturing Practices (CGMPs), have food safety plans, and implement preventive controls – all of which included requirements for maintaining clean and sanitized facilities and food contact surfaces. Retailers and foodservice providers have similar sets of requirements from their health departments and the Food Code. In many facilities, what has always been done will be enough to mitigate coronavirus risk, particularly since there is no evidence of food or food packaging being associated with transmission of the coronavirus. However, if an employee is confirmed positive with COVID-19, or becomes ill at work with any illness, it is advisable to further disinfect areas in which that employee worked or contacted, using EPA-registered “disinfectant” products for COVID-19 (see EPA’s Disinfectants for Use Against SARS-CoV-2 list). Additionally, as a general safety net, food facilities may want to consider a more frequent cleaning. 5. Supply chain. Going beyond your facility, supplies chains are getting stretched and difficult, and even more so today it is essential to conduct a critical assessment of your supply chain. Do you have multiple approved suppliers, particularly for essential ingredients, packaging materials, and other critical supplies? Discuss availability of commodities with your suppliers, particularly in areas hard-hit by the virus, and determine alternate options wherever possible. Due to the pandemic, FDA has suspended all domestic routine facility inspections and most foreign facility inspections, which makes it that much more important that you increase your supply chain surveillance and ensure that you are receiving the same high quality, food-safe products and ingredients despite the current challenges. 6. Leverage Technology. With greater risks and likely fewer people, now is the time to be thinking about how to better leverage technology to help you analyze all the data you are getting. This includes within your operation and from your suppliers. While cash flow may be difficult right now, I encourage you to at least be thinking about how to use data analytic tools more to save you time, save you people, and reduce risks. If you are having difficulties in any of these areas, would like assistance assessing any food safety gaps, or have any questions on maintaining food safety through the coronavirus pandemic, please give TAG a call. We have both a dedicated COVID-19 team and business continuity team to ensure we are able to provide full support to all in the food industry. About The Acheson Group (TAG) Led by former FDA Associate Commissioner for Foods Dr. David Acheson, TAG is a food safety and public health consulting group that provides guidance and expertise worldwide for companies throughout the food supply chain. With the advent of the COVID-19 pandemic, TAG’s public health and infectious disease expertise has been brought to the forefront to assist food businesses weather the increased challenges of employee protection, food safety, and business continuity. With in-depth industry knowledge combined with real-world experience and advanced virtual technologies, TAG’s team of experts helps companies assess their unique situation, address gaps, and deploy best practices to more effectively mitigate risks, improve operational efficiencies, and protect their brand. www.AchesonGroup.com
