Food First Blog | Resources from the May 18 “Food Safety and COVI

Watch our May 18 Top 10 Most-Asked Questions 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.

Watch Recording

Top 10 Most-Asked COVID-19 Questions

We reviewed the many (many) questions you’ve sent over the past 10 weeks and compiled them into your Top 10 Most-Asked Questions. This webinar and blog provide you with a clear and concise summary of what you need to know and how to best apply our recommendations moving forward.

10. Are masks or other PPE required in my facility?

Aside from the PPE already worn in your facility as part of your on-going food safety practices or employee safety gear, additional PPE is not required for additional food safety measures.

• Mask use may though be considered under CFR 117.10 (a), which notes that “management of the establishment must take reasonable measures and precautions to ensure” Disease Control.
• There are also virus prevention measures from OSHA that do recommend masks and other PPE for employee safety during the pandemic. Thus, mask use is best practice.
• Equipment like face masks can limit the spread of the virus by the person wearing the mask. We know from CDC studies that a significant portion of individuals with coronavirus lack symptoms (or are “asymptomatic”) and that even those who eventually develop symptoms (or are “pre-symptomatic”) can transmit the virus to others before showing symptoms. Each make the use of masks important in a setting, like food manufacturing, where close personal contact takes place.
• Further, while mask or other PPE use may not be Federally required, you should also check with your city, county or state, as each may have differing rules.

9. What is the viability of COVID-19 on various surfaces?

According to Doremalen et al. 2020, the virus could survive in droplets for up to three hours after being coughed out into the air.

Additionally, this study found that the COVID-19 virus survives for longer on:

• Copper surfaces for up to four hours;
• Cardboard for up to 24 hours; and;
• Plastic and stainless-steel surfaces, for up to 2-3 days

According to Chin et al. 2020, the virus is highly stable at 4°C, but sensitive to heat.

• They further found that no infectious virus could be recovered from printing and tissue papers after three hours of incubation;
• Whereas, no infectious virus could be detected from treated wood and cloth on day two;
• The researchers noticed that SARS-CoV-2 was more stable on smooth surfaces.
• It was notable though that a detectable level of infectious virus could still be present on the outer layer of a surgical mask on day seven.

The viability of the virus on these various contact surfaces should be considered as you think about how you might modify your facility’s cleaning schedule to address the virus.

8. How can my employees exhibit in-facility social distancing?

While you can’t necessarily add six feet of space between employees on a production line, there are precautionary measures you can take. Visit our “6 Key Questions When Increasing Distancing in Production During COVID-19” blog for our key recommendations.

• Add time between the departure of first shift and arrival of second shift and also lunch breaks, minimizing exposure risk and allowing for adequate sanitation between the two.
• Separate donning and doffing areas/portions of the locker room to minimize contact between teams.

In workforce and visitor areas:

• Think of a blueprint of your facility – note entry and exit locations – create a flow for one entrance, and a separate exit if possible.
• Consider having a separate PPE area for visitors to minimize worker and visitor interaction.
• Where distancing cannot implemented, think about additional mitigation measures you CAN put into place – if not social distancing, social separation and increased sanitation.
• If you’re adding partitions between employees, make sure they’re on your cleaning schedule.

7. Can we host on-site audits? Is there an alternative?

While we know FDA has suspended routine inspections, states may still be inspecting, so be prepared. You should consider how you would handle a state inspector. Have you established a policy and communicated it so your staff is clear on what to do? 

An alternative to an on-site audit is our Hybrid GMP Inspection. In the midst of the pandemic, the Hybrid GMP Inspection works because it starts with a virtual desktop review of your GMP Program, followed by an unannounced site inspection to be performed within 6 months of the desktop review.

Just like our typical GMP Inspection, the Hybrid GMP Inspection is based on our Consolidated Standards for Inspection and aims to provide retailers and consumers with assurance of Good Manufacturing Practices. In this turbulent time, your ability to continue providing safe, high-quality food will build trust with your customers.

6. What areas are considered high-touch and in need of additional cleaning?

Think about and take a walk around your manufacturing facility, breakroom, bathrooms and distribution center/warehouse to observe what areas acre contacted most. Examples include but are not limited to door handles, time clocks, control handles and knobs on production equipment, computer touch-screens, bathroom doors, vending machines, water coolers, PPE holders, badges, and shared equipment such as scanning guns in a warehouse or thermostats/thermometers.

If you haven’t already, update timecard readers to badge scanners instead so there’s no-contact. You should also replace old toilets and faucets in your restrooms with no-touch options.

For distribution centers and warehouses, can you designate individuals for specific roles to limit contact?

5. Do I need to implement increased sanitation measures?

In thinking on how this question applies to your facility, take a look at our blog and webinar on sanitation for our key recommendations. Also consider any recent changes you may have made to your production schedule and how this may impact sanitation. Have you increased production? Decreased? Stopped/slowed using some ingredients so they’re now being stored longer?  It’s also important to consider two of the previous questions addressed above regarding surface viability of the virus and high-touch areas in your facility. How do each of these questions impact your cleaning schedule?

In planning, you can then better understand how to:

• Provide sufficient time for sanitation, (remember those Lexan partitions we added earlier? They have to be cleaned!);
• Provide effective training for sanitors;
• Ensure collaboration with maintenance and production to maximize cleaning; and,
• Visit our “Following COVID-19, What Sanitation Training Will My Employees Need?” blog for key considerations.

4. What measures do I take following an employee testing positive for COVID-19?

Visit our “An Employee Tested Positive for COVID-19. What Do I Need to Do?” blog for key considerations. Foremost, sanitation is needed, especially for common areas/high-touch areas – a few things to consider to do it correctly:

• Have HR communicate to employees – For more guidance on steps to take with Employee communication, please refer to the FDA FAQ website as it has several items to consider (things like HIPPA, local health department notification, etc .) We recommend being proactive with communication to help your workforce understand the procedures that will take place should it be necessary. Share what the company is doing to ensure worker health and safety – cleaning best practices and appropriate PPE use (which we will cover in more detail in a few minutes)
• Clean, clean, clean – Clean their work station, common areas, high touch areas, and ALL other areas they may have been in contact with. Zoning, traffic mapping can be beneficial – even if you know where they’ve been, you’ll need to do a full clean. You may want to reference the EPA’s List N: Disinfectants for Use Against SARS-CoV-2 with contact times listed.
• Communicate some more – And then communicate with employees/service providers what has been done to ensure their health and safety and why it will keep them safe – you cannot over-communicate. This will assist with workforce morale, as they’ll want to know that everything has been cleaned thoroughly.

3. How do I handle on-site visitors?

Maybe your facility has increased production significantly and now you have more frequent deliveries of ingredients and materials, some from new transportation suppliers who are unfamiliar with your procedures or you’ve altered procedures to include new policies. What do you do to manage those visitors and service providers?

It may be necessary to 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.

This could include temporarily adding 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. You would need to consider the non-contact devices utilized, who would take and document this procedure if required and training needed to conduct these functions.

You should also determine what critical services such as IPM, janitorial, maintenance, and service deliveries are necessary and which can be postponed. Additionally consider if alternating times of service or deliveries would minimize potential risks. For example, telling your pest company just not to come is not a best practice. Maybe consider service at a different time of the day, when fewer people are on site. Temporary and Part-time employees need consideration as well. Work with your agency on training and duration of the employment with the goal of reducing or eliminating daily turnover. 

Maybe you’ve added sanitation personnel to 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.

For unplanned visitors, establish best practices and policies:

• This could include a single point of contact upon arrival;
• You should also consider how you would handle a state inspector showing up;
• We know FDA has suspended routine inspections, but states may still be inspecting, so be prepared; and,
• Have you established a policy and communicated it so your staff is clear on what to do?

For all of these visitors, you can also develop a basic screening questionnaire for use in asking about their travels and potential exposure to the virus. You might also consider taking non-contact temperatures at arrival and departure, and then document your findings as mentioned earlier. Additionally, you may consider requiring visitors and service providers to notify you if identified with COVID-19.

It is important that your policies are well-communicated to these audiences so they’re not surprised and are more likely to comply. If changes are made, even temporary they should be included or added into the current policies and procedures. Then if they will be removed or no longer necessary you can remove them and update your policies. Remember, training and education is a must when changes are made for all to understand what is needed.

2. Have there been any substantial changes to rules or regulations? Any foreseen?

Remember, FDA has suspended routine inspections. They have also provided guidance on suspending the on-site audit requirements for supply chain preventive controls and the Foreign Supplier Verification Program if other verification activities can be implemented.

Regarding labeling, there have not been any changes to labeling regulations because of the pandemic. However, FDA and USDA did provide policies and allowances for short term exceptions to certain labeling so that food service items could be redirected into the retail markets. These allowances are set to expire at different times. FDA states that these changes are allowed during the time of the public health emergency. USDA set time periods of 60 days from March 23, so those are close to ending. 

FDA is also using their enforcement discretion for an additional 6 months (through 2020) for compliance with the new nutrition regulations.  Large companies had until July 1 of this year, but they have now moved it to January 1, 2021.

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?

1. Is COVID-19 a food safety issue? Do I need to make changes to my food safety practices?

There is no evidence that COVID-19 is transmissible by food, so food safety practices are not an issue. That being said, just because the virus is a food safety risk yet, there are several food safety programs that you may want to review and update based on this new emerging information. Perhaps not your hazard analysis in your HACCP or Food Safety Plan, rather your GMPs and Prerequisite programs like the employee health and hygiene program, crisis management program, sanitation programs, and training programs just to name a few.