Protections for Our New Normal

With businesses working through COVID-19 reopening, bringing employees back to work, and preparing for a “new normal,” considerations need be made for both the continuation of in-facility employee protections and supply-chain reviews and assessments. I’ve frequently stated that we’re in this for the long-term. Even with states and businesses opening up, I don’t see us returning to the pre-COVID-19 state or entering a post-pandemic era for months, if not years. So, we can expect that employee and supply-chain protections will continue to be part of our new normal.

Many food-production facilities had to source new suppliers when their regular suppliers closed, had shortages due to employee absence, or faced transportation difficulties due to the pandemic — and often those suppliers had to source new suppliers themselves.

To enable manufacturers to continue production, the new suppliers often had to be brought on quickly with little assessment and no possible in-plant inspection. Additionally, with shortages remaining in some segments of the industry, the risk has increased for economically motivated adulteration (EMA) and intentional adulteration (IA) in your supply chain. So, as you prepare for the new normal, we would make two key recommendations:

• Continue to protect your employees.
• Re-assess all suppliers.

EMPLOYEE PROTECTION. Throughout the pandemic, we have recommended the implementation of four COVID-19 preventive controls, and we highly recommend that these be continued for employees, and instituted for visitors who may start coming to your facility, as well as supply drivers:

• Employee Wellness Checks. This includes a temperature check; questions on symptoms; questions on exposure to person with COVID-19, etc. The purpose is to keep anyone who is ill out of the workplace to reduce transmission to others. (See Wellness Screening details at https://www.achesongroup.com/covid-19faqs under Guidance for Employees and Businesses.)
• Social Distancing and Hygiene. Reconfigure your production floor to allow for six-foot distancing and/or barriers between workers, and ensure the distancing is maintained throughout the day (e.g., implement staggered shifts, reduce chairs in breakrooms, etc.). Remind employees about regular handwashing and provide hand sanitizers/stations.
• Enhanced Cleaning and Disinfection. Increase regular food safety cleaning and sanitation; add enhanced disinfection of common areas and frequently touched surfaces throughout the facility. Use EPA SARS-COV-2 listed disinfectants.
• Non-Medical Masks. All employees and visitors should wear masks throughout the day, as COVID-19 can be spread by asymptomatic persons. Mask usage reduces this risk by reducing droplet spread.

SUPPLIER ASSESSMENT. With the challenges faced by food industry businesses in all parts of the world, even those suppliers on whom you’ve relied for decades could have had to make major changes to their production or supply. Because of this, it is critical that you take the time to reassess all your existing suppliers.

For new suppliers acquired during the pandemic, you will need to, first, determine if you will continue to use them. If so, the supply chain management requirements of FSMA will need to be applied to all these suppliers, if you’ve not already done so. Although FDA temporarily suspended the FSMA supplier verification onsite audit requirements, other appropriate supplier verification methods were still required. Any new suppliers not fully verified should be run through your supply-chain program as soon as possible.

You also will want to consider some pandemic-related questions, such as:

• Have your suppliers added new suppliers during the pandemic? If so, did you conduct a risk assessment?
• Did your long-term suppliers have to make any changes to ingredients or production? If so, was a risk assessment conducted?
• Do your suppliers have any refrigerated trucks that were used to store COVID-19 victims? If so, have they been cleaned and disinfected according to FDA Guidance (https://bit.ly/2TaO9S9)?
• What policies do your suppliers have in place to mitigate IA and EMA? (EMA assessment is currently particularly critical in the meat industry where global shortages have led to issues such as EU seizure of mislabeled horsemeat intended for market.)

While we all continue to deal with the impacts of COVID-19, it also is critical that food safety continue to be given priority. Not only is this essential to protect your customers and your brand, but recent cases with Blue Bell and Chipotle have shown that the Department of Justice is alive and well and continuing to hold the industry accountable and prosecute companies — and executives — for food contamination outbreaks.