Watch our May 11 Top 5 Actionable Recommendations webinar recording now or download the accompanying PDF. Please share these resources with your colleagues – you never know when that shared expertise will be beneficial.
Top 5 Actionable Recommendations
To help convey priorities for what you should be doing in your facility right now, we surveyed our team of AIB International Food Safety Professionals for their key insights and distilled their feedback into our Top 5 Actionable Recommendations.
5. Manage Visitors and Employees
Have you increased production significantly and now you have more frequent deliveries of ingredients and materials? Are they from new transportation suppliers who are unfamiliar with your procedures or you’ve altered procedures to include new policies? How do you manage those visitors, employees and service providers?
- Review Visitor Policy - Review your current visitor policy and make temporary changes during these times. Reviewing the policy and then communicating any changes with your employees, visitors and others will help ensure that it is followed.
- Health Checks - Temporarily add in requirements for health checks like temperature checks before entry and the required use of face masks and social distancing requirements that you feel are important to maintain personnel safety. Read our “6 Key Questions When Increasing Distancing in Production During COVID-19” blog to learn more.
- Document Temperatures - You need to consider the devices utilized for taking temperatures, who will take and document this procedure if required and training needed to conduct these functions.
- Postpone Unnecessary Activities - Determine what critical services such as IPM, janitorial, maintenance, and service deliveries are necessary and which can be postponed.
- Alternating Deliveries/Services -Consider whether alternating times of service or deliveries would minimize potential risks. Schedule service at a different time of the day, when fewer people are on site.
- Educate Your Team - Work with your temporary/part-time employee agency on training and duration of the employment, with the goal of reducing or eliminating daily turnover.
- Open Communication - Communicate with your sanitation personnel on each shift to have continual wipe-downs of door handles, tables, chairs, computers, desks, stair hand-rails and other high touch surfaces. They’ll also need to know about any special policies you have in place.
- Read our “Four Key Questions When Increasing Production to Meet Demand During COVID-19” to learn more about what other considerations you should take when increasing production.
For unplanned visitors, establish best practices and policies:
- One Entry Point - This should include a single point of contact upon arrival.
- State Inspections - Consider how you will handle a state inspector showing up – we know FDA has suspended routine inspections, but states may still be inspecting, so be prepared. Have you established a policy and communicated it so your staff is clear on what to do?
- Screening Questionnaire - Develop a basic screening questionnaire for use in asking about their travels and potential exposure to the virus, while also taking non-contact temperatures at arrival and departure, and then documenting your findings.
- Communicate Changes - When changes are made, even if temporary, they should be included in the current policies and procedures, and then well-communicated to these audiences so they’re not a surprise.
When establishing best practices for PPE use:
- Establishing Your Plant's "New Normal" - As with other viruses, this is a respiratory virus and it spreads through close contact. Food plants may have to operate under the “new norm” of having all the proper PPE, questionnaire screening and monitoring the health of all employees on a shift-by-shift basis, while doing the same for incoming visitors and service providers.
- Social Distancing at Work - Look at whether “social distancing” is an option for various areas of your operation, such as breakrooms, locker rooms and meeting rooms. If not, what additional mitigation strategies are possible?
- Free Webinar - Watch or read about our April 13 webinar “Food Safety and COVID-19: What Businesses Need to Know” webinar for additional employee, visitor and PPE considerations.
Each of these may be a significant change in how your facility operates, so you may need to convene your crisis management team to develop a plan. You’ll then need to communicate with and train your managers/employees and visitors on such changes, implementing these changes broadly across shifts or the organization.
4. Train Frontline Workers
Frontline workers may be feeling the brunt of the current crisis, seeing their colleagues or frontline workers in other facilities getting sick, which is leading to plant closures. They may also be feeling stressed by the whole situation, which may lead to errors in their work.
- Training vs. Education - Understand the difference between training and education. Training is simply informing individuals what the must or should do. Education is including why that action is important. Including both of these elements within a training session is important to conveying information that will be understood, retained and implemented.
- GMPs - There has never been a better time for training or re-training to reinforce Good Manufacturing Practices in the production of your products. As a reminder, these are not just practices, but the law, so anything you can do to maintain compliance is beneficial. In your training, beyond just providing your employees with “do this” and “don’t do that” instruction, also focus on why those rules are in place and important to the safety of your products and brand. Including the why can also assist in reducing the stress by educating doing these things can reduce exposure and other product safety issues.
- Verify Comprehension - You should then verify comprehension and compliance through testing and even in-facility demonstrations to confirm that your frontline workers are applying that learning as they were trained.
- Virtual, Online & Private In-Plant Training - Take a look at our virtual seminars, online training and private training options for how to improve your team’s training throughout the COVID-19 pandemic.
3. Implement Sanitation Best Practices
A component of training for frontline workers could be the implementation of enhanced sanitation practices.
- Sanitation Training for Employees - Read our May 1 “Tip of the Week: Following COVID-19, What Sanitation Training Will My Employees Need?” for insight into how you can help employees follow proper sanitation procedures in the future.
- FDA's Changing Expectations - We believe the FDA will be expecting improvements and upgrades to the food industry’s cleaning and sanitation practices and will challenge you to defend them. This may be especially applicable as you change current procedures and practices to best meet increased demand, changing consumer preferences or other changes to production.
- Look to Other Models - FDA may look at other models for cleaning and sanitation, such as what is included in 9 CFR 416 for USDA facilities, to adopt cleaning requirements similar to USDA for certain food products or areas that may be high risk.
- Self-Regulation - To a large extent, the industry regulates itself, as many of the requirements for food plants come from customers and are more demanding than regulatory itself. Especially when it comes to GFSI requirements – these come from customers, not the FDA. So what best practices will you put in place to meet these increased expectations for maintaining production for your customers?
- Free Webinar - Watch or read about our April 27 webinar “Food Safety and COVID-19: What Businesses Need to Know” webinar for information on how COVID-19 may prompt changes in how the industry cleans and sanitizes facilities.
2. Develop Re-Opening Procedures
Whether only a few production lines or your entire facility has been closed, before re-opening your facility, first look at regulatory resources and recommendations.
- Reference Available FAQs - The FDA, CDC, and USDA have each maintained COVID-19 FAQs that may be beneficial. They include best practices for screening procedures, protective equipment (such as masks) and social distancing guidelines.
- Review Sanitation Procedures - Review your resources and capabilities that include sanitation, preventive maintenance, resources for production, and available staff. Once these items have been reviewed and assessed, you and your team can better determine a safe course of action to re-open your facility.
- Review Crisis Management Plan - Bring your crisis management team together to objectively discuss what targets would initiate a closure or reduced production. This could include increased positive cases in your facility.
- Free Webinar - Watch or read about our April 6 webinar “Food Safety and COVID-19: What Businesses Need to Know” webinar for additional re-opening considerations.
Build Your Team & New Procedures
Once a course of action has been identified, assign roles and responsibilities for the various tasks required.
- Train New Leaders - This may require training and education for these leaders before they can develop and implement these new actions.
- Develop New Procedures - Once qualified, they can develop policies and procedures and train and educate the workforce on these new procedures.
- Implement Procedures - Once developed, and you’ve trained your team for implementation, you will want to monitor for compliance. This will support tracking comprehension to the new procedures, while documenting gaps so corrective actions can be implemented.
Follow Your Plan
Once the opening process has begun, you want to manage the situation to ensure all actions are following the defined plan.
- Review/Verify - It is best practice to assemble your team and review/verify program compliance. This could include reviewing documented employee, visitor, contractor health screening results. You should also review those who may have been ill and determine when they may return to work and whether they may need accommodations.
- Identify Gaps in Your Plan - Through this process, you may also identify potential gaps in your established programs that require corrective actions and changes or additions to current policies.
- Routine Reviews - These reviews should continue until the crisis management team decides the situation is clear.
Additional Re-Opening Considerations
Furthermore, before successfully re-opening your facility, you’ll want to take a look at a few additional areas, including:
Conduct a detailed inspection for pest activity and signs. Utilize your IPM provider to inspect your facility and confirm that it is clear of pests, so you’re ready to start up again and there’s nothing that will cause a delay or quality issues.
You can also conduct an assessment with your IPM professionals – AIB International requires an annual assessment to ensure that all of the necessary pest management programs are in place.
Pathogen or Microbial Development
Sanitation of food contact surfaces is critical – While COVID-19 is not a food borne pathogen, a good and detailed cleaning and sanitation of food contact surfaces is necessary.
You’ll also want to do validation testing for contact surfaces and inspection for product zones – These are things we can do in the facility to make sure the re-opening of your facility goes smoothly.
1. Prepare for a Future Crisis
While we're not sure anybody could have accurately predicted the scope and scale of the current pandemic, or its impact on the food supply chain, there are measures you can put in place to protect your business from the next crisis or disruption. And if using the current situation as a guide for future preparedness, you’ll be prepared for just about anything the future brings.
Benefits of Planning Ahead
Pre-planned strategies also allow team members to contain the damage, respond to those impacted, restore customer confidence, and return to normal operations quickly. A structure that defines responsibilities and how to accomplish assignments leaves nothing to guesswork. This doesn’t mean that adjustments to the plan won’t be needed to address a unique situation, but the framework is established. A planned response is also a focused response. Crises always cause stress and chaos, but planning helps maintain a sense of calm while working to resolve the issue.
Developing a Crisis Plan
There are several steps in the process used to develop a crisis plan that best fits your operation or organization.
- Online Training - Take our Crisis Management Online course to help optimize your response time and get your business back to normal quickly after crisis strikes.
- Crisis Management Team - Establish your Crisis Management Team.
- Risk Assessment - Conduct a risk assessment to determine what events you can reasonably assume may or could happen to the business and prioritize the likely events.
- Decision Trees - A flow diagram or decision tree is useful to guide team decisions related to the plan.
- Roles & Responsibilities - All actionable items need to be defined and assign roles and responsibilities for their management.
- Open Communication - Communicating requirements to keep all stakeholders informed of the event is necessary to mitigate risks.
- Document Key External Contacts - Before an event occurs, you need to know who to contact outside the company to request help to regain a state of control.
- Crisis Conclusion - Finally, establish how it will be determined that a crisis is concluded and the danger has been effectively contained.
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