Life is full of surprises, but when it comes to food safety, they’re hardly ever pleasant ones. That element of the unknown is partly why the food industry developed the Global Food Safety Initiative (GFSI), which is designed to create universal standards to ensure confidence in the delivery of safe, quality food to consumers worldwide.
And managing those unexpected events — or at least establishing the protocol and systems to proactively minimize and effectively react to them — became the government’s impetus behind the Food Safety Modernization Act (FSMA).
So, after the coronavirus (COVID-19) pandemic struck, how well were these standards designed to ensure food safety in these times? Perhaps one of the best groups to answer this question is the BRCGS, which is used by more than 29,000 suppliers in more than 130 countries, with certifications issued through a global network of accredited organizations.
“Food businesses that are certified to the standard must have a full understanding of the products they manufacture and distribute, and have systems in place to identify and control significant product safety hazards,” said Jessica Burke, senior manager, technical services for BRCGS. “The standard has two key components, senior management commitment and a HACCP-based system, which provides a step-by-step approach to managing food safety risks. With all this in mind, businesses that use the standard are well positioned to identify, assess and act on the new risks associated with COVID-19.”
For Joseph Levitt, the sense of urgency surrounding COVID-19 has reminded him of the post-9/11 period when he was director for the Center for Food Safety and Applied Nutrition in the US Food and Drug Administration (FDA). This time, however, the impact on the food industry is significantly different.
“This one in many ways is worse because it affects personal safety and worker safety,” noted Mr. Levitt, partner with Hogan Lovells, a Washington, DC, firm that serves as legal counsel to SNAC International and other food industry groups. “The one saving grace is it does not present a food safety risk, and we should all be grateful for that.”
Perhaps the biggest hurdle now involves employees who test positive for COVID-19, who Ms. Burke advised to stay home and quarantine themselves according to government guidance.
“The food safety standard requires companies to have procedures in place to ensure that employees, agency staff, contractors and visitors are not a source of transmission of foodborne diseases to products,” Ms. Burke observed. “COVID-19 is not thought to be transmitted through food; however, the principle of medical screening should be extended, and all employees should be assessed for signs of coronavirus infection before starting work, every day. This may include temperature checks or fit-to-work declarations.”
In these situations, Maile Gradison Hermida, also a partner with Hogan Lovells, noted that companies may often find themselves working with suspected — not confirmed — cases of infection from the virus because testing still may not be readily available for all cases. As a result, some jurisdictions may require companies to report both confirmed positives and suspected cases.
She further suggested taking such key steps as informing fellow employees of an ill worker and possible exposure in the workplace. Additionally, companies need to exercise caution concerning the confidentiality of the ill employee. Moreover, businesses should contact and follow local and state guidelines on any quarantine protocols for workers, especially those who had close contact — defined as working within 6 feet — with the ill employee for a prolonged period of time.
“FDA has said very clearly that no recall or market action is necessary,” Ms. Gradison Hermida observed.
That said, Elizabeth Fawell, another partner with the firm, added that any decision to shut down a facility following a COVID-19 positive also requires a case-by-case assessment in conjunction with the local health department.
Since the outbreak, the FDA has suspended routine food safety inspections but is continuing for-cause inspections while providing support and oversight on recalls.
“FDA is only visiting those facilities that are involved in potential food safety issues like customer complaints to FDA that may be the result of unsafe food or in the event facilities initiate a recall,” said Earl Arnold, manager, food defense/FSMA quality assurance, North America, for AIB International.
Two areas of an audit or inspection might be more important than ever; the first of which is sanitation.
“More emphasis may be needed on daily cleaning tasks for areas such as doors, breakrooms and restrooms,” Mr. Arnold said. “Additionally, some facilities may be conducting longer runs with fewer products.”
The second area involves the self-inspection program.
“There should be more focus on reviewing personnel practices like washing hands, monitoring signs of employee illnesses, confirming that equipment cleaning and maintenance is occurring as needed, and other items,” he said.
Likewise, Ms. Burke pointed out that several factors might impact the certification process during this time. Government travel restrictions and company policies may prevent visitors to the site to safeguard employees’ health. Globally, certification bodies are also restricting travel to some regions or countries to protect their auditors.
“As such, we have put procedures in place for existing certificated sites that are unable to receive a physical audit,” she said. “Where a site is operational, but a physical audit may not occur on or before the audit due date, a certificate extension of up to six months may be issued based on the successful completion of a risk assessment.”
Inside the production facility, bakers and snack producers will likely require additional precautions to ensure food and worker safety.
“Some small sites may not need any additional controls,” said Tammy Svoboda, certification manager for AIB International. “Larger sites may have concerns about social distancing requirements to help keep their workers safe.”
Before this health crisis, Mr. Arnold said, the FDA had been focusing most routine inspections on a back-to-basics philosophy including hand washing and employee illness policies that are part of the regulatory GMPs. Additionally, FSMA asks facilities to review food safety and food defense plans when significant changes, such as the current pandemic, occur.
“As this health crisis continues and facilities modify production, hire more temporary personnel and make other changes, each needs to be reviewed to determine if new or temporary controls are needed,” Mr. Arnold said.
Ms. Burke stressed that facilities should have a clear leadership team dedicated to managing COVID-19 processes.
“Given the speed at which circumstances are changing, the team should meet regularly to review and update the COVID-19 processes as required,” she advised. “The team should be considering government advice, staff sickness and customer requirements.”
She recommended increased emphasis on critical control points (CCPs). Backup employees should be trained to manage these CCPs in case of absenteeism, and best practices should be highlighted for new employees. If bakeries employ high levels of temporary staff due to higher absenteeism, they should review their food defense plans with an emphasis on managing any increased vulnerability.
Moreover, bakeries and snack makers should identify emergency supplier and raw material approval procedures if they’re unable to obtain ingredients from their regular suppliers and then find different ways of approving raw materials suppliers when audits can’t be undertaken. Along with additional testing and inspection, Ms. Burke said, any changes should be communicated to brand owners and approved before use, where required.
From a sanitation perspective, keep an eye on pest control and establish reporting procedures to minimize any infestation or seasonal factors. Additionally, Ms. Burke urged food producers to focus on preventative maintenance programs since outside maintenance companies may not have access to the site. And remember to proactively identify equipment that may be at risk of failure and pose a potential contamination threat.
To protect employees, facilities should have a clear policy for accepting general visitors and sub-contractors including service engineers, contract cleaners and vehicle drivers. Make sure they’re aware of the plant’s rules for managing COVID-19 and ensure they are not exhibiting the symptoms of the virus. In addition, visitors should be provided with any protective clothing required for access to the site.
“The site should also ensure that its operations are managed to reduce the risk to employees from cross-contact,” Ms. Burke said.
This article is an excerpt from the May 2020 issue of Baking & Snack. To read the entire feature on certifications, click here.