Tag Archives: employee safety

Jill Henry, Essity
FST Soapbox

The New Hygiene Standard: Building Trust Through Employee Safety

By Jill Henry
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Jill Henry, Essity

The pandemic has heightened the need for a new hygiene standard at food manufacturing sites. On August 19, OSHA and FDA released a health and hygiene checklist for food manufacturers to increase employee safety and help mitigate the spread of COVID-19 at sites. This checklist reinforces the importance of elevating hygiene standards, but it can be difficult to know where to start—especially for food manufacturers aiming to maintain productivity while maximizing hygiene compliance and safety.

For food manufacturers seeking to navigate OSHA and FDA’s new guide, it’s important to remember that no matter the environment, the basics of hygiene remain true. You can kick-start your updated hygiene plan by implementing simple hygiene best practices and establishing comprehensive and clear protocols to achieve compliance on the road ahead. Remember, employee health and productivity begins with a safety-first mindset. Start by establishing a strong foundation with these tips that will help you maintain your food manufacturing site’s hygiene checklist amid COVID-19 and beyond.

Achieve Hand Hygiene Compliance

Hands are the most exposed part of the body to pathogens. Therefore, hand hygiene is considered one of the most important and effective measures to avoid the transmission of harmful pathogens, viruses and diseases. Given this, consistent and proper handwashing is a fundamental aspect of any hygiene plan, especially in food manufacturing sites where employees frequently touch common surfaces (e.g., door handles, technical equipment, etc.) . People often (and unknowingly) touch their eyes, nose and mouth after touching contaminated surfaces, which contributes to potential transmission.

Hand hygiene is proven to be a primary line of defense in stopping the spread of COVID-19 and other pathogens, but only when conducted properly. To maintain hand hygiene compliance, the CDC advises that employees thoroughly wash their hands with soap and water, under warm or cold water for at least 20 seconds, before properly drying their hands with a paper towel. All too often, people forget the importance of hand drying in the handwashing process, but it’s very significant as hand drying can help remove any remaining germs from the skin. In addition, germs can be transferred more easily to and from wet hands, which makes hand drying critical after a thorough handwashing.

Utilize Signage as Visual Cues

While many are familiar with the importance of hand hygiene, it can be difficult to put into practice when employees are busy on the job and forging ahead on production lines. Keep hand hygiene top of mind by utilizing visual cues, such as signage, to remind employees about when, where and how to wash their hands properly. Signage serves as visual reminders to achieve proper hand hygiene compliance and is an important part of establishing a site’s hygiene standard and foundation.

Opt for signage that includes a direct call to action for employees. Using the word “you” can also increase efficacy by calling directly upon the person reading the sign to participate in hand hygiene compliance. Additionally, signage should be updated frequently to keep employees engaged and hand hygiene top of mind. New and fresh reminders on the importance of handwashing will help keep employees attentive, but if you don’t have the time or resources to continually update on-site signage, leverage free tools available online to help you get started.

Establish Surface Cleaning Protocols without Sacrificing Productivity

COVID-19 can spread from surface-to-person contact. This can happen when an employee carrying the virus touches technical equipment on a production line that is not properly wiped down before the next employee’s shift. With this in mind, it’s critical to establish effective surface cleaning protocols that mitigate instances of cross-contamination and don’t create downtime in production or processing.

To create an efficient surface hygiene plan, assess high-touch areas, and develop a list based on where you observe high-touch surfaces to ensure these areas are properly sanitized ahead of shift changes. Provide employees with the surface cleaning checklist that enables them to effectively sanitize surfaces prior to departing their shift. The checklist should include key areas that must be disinfected, as well as tips to properly disinfect surfaces.

When disinfecting surfaces, use an approved disinfectant and a disposable cloth, which ensures the surface is being wiped down with a non-contaminated wiper each time. If using an alcohol-based product, use one with a minimum of 70% alcohol (i.e., Ethanol or Isopropyl alcohol), and always follow the manufacturer’s application guidelines.

Optimize Sanitization Stations and Dispenser Placement
Think strategically and practically about dispenser placement in food manufacturing sites because where sanitizer dispensers are placed makes a difference in whether they are used by employees. Similar to establishing surface cleaning protocols, start by observing where high-traffic areas are on site, and consider critical entry and exit points that would benefit from a dispenser. Dispensers should also be placed in clear view, so they are easily accessible for employees. Consider pairing signage with dispensers as a helpful reminder to utilize these stations and provide instruction on best practices to sanitize effectively.

Optimizing dispenser placement doesn’t stop with implementation. Once dispensers are in place, continue to monitor where dispensers are most frequently used, and assess other areas prime for dispensers. Remember: Employee hygiene and safety is a priority, and optimally placing dispensers and hygiene solutions where they are needed to encourage use is key to creating a safer environment. Place dispensers in areas such as common spaces, near production lines, in locker rooms, and at entrances and exits in order to encourage regular surface cleaning and hand washing. Flexible mounting solutions and portable solutions can facilitate access in harsher environments. The availability of hygiene products encourages their use, so be sure to keep dispensers fully stocked.

Promote Awareness among Employees and Instill Confidence

It’s more important than ever to build employee trust and confidence. As the saying goes, knowledge is power. Communicate frequently with employees and distribute guidelines around COVID-19 so that they understand the measures being introduced and how you will continually monitor your environment. Consider implementing COVID-19-specific training and education sessions that empower employees to ask questions about hygiene and safety measures on site, and provide essential instruction on COVID-19 and what to do if a case is confirmed among employees. These sessions can also be used to provide further education and emphasis on how individuals can maintain hygiene compliance for the greater good of the manufacturing site and their colleagues.

In the current environment, it’s clear that food manufacturers must secure a new hygiene standard to maintain employee health and safety and continue to deliver essential products. But with ongoing shifts, changes and uncertainty, it can be challenging to juggle operations and hygiene compliance—while instilling trust and confidence among employees. Whether a site is continuing, resuming or re-evaluating operations amid the current pandemic, it is critical to maintain a strong foundation for hygiene, so that employees are safe and essential production moves ahead.

Checklist

2020 FSC Episode 3 Wrap: Does Your Company Have a COVID Czar?

By Maria Fontanazza
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Checklist

Navigating the murky waters that COVID-19 presents has been no easy task for food companies. Being part of America’s critical infrastructure has meant that adapting to the pandemic has been unavoidable, and the industry has directly taken on the challenges to ensure the nation has a reliable food supply. But what about the frontline workers, their safety and how this ties into operational continuity as a whole? During last week’s episode of the 2020 Food Safety Consortium Virtual Conference Series, an expert panel discussed the practices that food companies have put in place during the pandemic and offered advice on managing the entire scope of COVID-19 challenges including screening employees and preventing infection transmission, safeguarding workers and the facility, administrative and engineering controls, education and training, and risk management.

“No doubt that it is a concert of controls and interventions that have allowed our industry to effectively combat this over the past several months,” said Sanjay Gummalla, senior vice president of scientific affairs at the American Frozen Foods Institute. “By and large, the industry has taken charge of this situation in a way that could not have been predicted.” Gummalla was joined by Trish Wester, founder of the Association for Food Safety Auditing Professionals and Melanie Neumann, executive vice president and general counsel for Matrix Sciences International.

First up, the COVID Czar—what is it and does your company have one? According to Neumann, this is a designated person, located both within a production facility as well as at the corporate location, who manages the bulk of the requirements and precautions that companies should be undertaking to address the pandemic. “We’re not trained in people safety—we’re trained in food safety,” said Neumann. “And it’s a lot to ask, especially on top of having to manage food safety.”

Some of the takeaways during the discussion include:

  • Administrative controls that must be managed: Appropriate cleaning, disinfection and sanitation; PPE; employee hygiene; shift management; and surveillance mechanisms
  • PPE: “It’s really clear now that face masks and coverings are critical in managing source control—it prevents the spread and protects other employees,” said Gummalla. “All employees wearing masks present the highest level of protection.” When the attendees were polled about whether face coverings are mandatory where they work, 91% answered ‘yes’.
  • Engineering controls within facility: Physical distancing measures such as plexiglass barriers, six-foot distance markings, traffic movement, limited employees, and hand sanitizer stations. “Engineering controls in a facility involve isolation from the virus,” said Gummalla. “In this case, controlling [and] reducing the exposure to the virus without relying on specific worker behavior. This is where facilities have implemented a great amount of thoughtful intervention, probably at a high capital cost as well.” Companies should also consider airflow management, which can involving bringing in an outside professional with expertise in negative and positive air pressure, advised Wester.
  • Verification activities and enterprise risk management: Neumann emphasized the importance of documentation as well as advising companies to apply a maturity model (similar to a food safety culture maturity model) to a COVID control program. The goal is to ensure that employees are following certain behaviors when no one is watching. “We want to be able to go from ‘told’ to ‘habit’,” she said.
  • Education and training: Using posters, infographics, brochures and videos, all of which are multilingual, to help emphasize that responsibility lies with every employee. “It is important to recognize the transmission is predominately is person to person,” said Gummalla. Do you have a daily huddle? Neumann suggests having a regular dialogue with employees about COVID.
  • The future, 2021 and beyond: Does your company have a contingency, preparedness or recovery plan? “The next six months are going to be critical; in many parts of the world, the worse is not over yet,” said Gummalla. “There will be a lot more innovation in our industry, and communication will be at the heart of all of this.”

Get access to the presentations and points discussed during this exclusive session by registering for the 2020 Food Safety Consortium Conference Virtual Series. Attendees will have also access to upcoming sessions as well as the recordings of all sessions.

Pratik Soni, Omnichain
Retail Food Safety Forum

Top Three Visibility Challenges in Today’s Food Supply Chain

By Pratik Soni
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Pratik Soni, Omnichain

To say that COVID-19 has been disruptive would be putting it mildly. The pandemic’s sudden and seismic impact has brought major upheaval across industries—the food industry and its supply chain included.

There was the initial panic buying that drove upticks in consumer demand for which few manufacturers and grocers were prepared, resulting in widespread product shortages. With restaurants closed, distributors and suppliers were left with considerable excess inventory—most of which ended up as waste and losses. Inside production sites and plants, many had to try and maintain their output with a reduced workforce, even as demand continued to climb. Meanwhile, some plants unfortunately have had to shut down operations on account of employees testing positive for COVID-19.

In the time since the outbreak, the food supply chain has stabilized to an extent. Store shelves are continuously being replenished with products. Restaurants have started reopening with new health and safety measures. Yet even as the industry takes gradual steps toward recovery, the underlying problem that led to the magnitude of COVID-19’s impact persists: Lack of visibility. There was lack of visibility into supply and demand and what was happening upstream and downstream across the supply chain, which prevented timely, proactive action to optimize operations in face of disruption.

Looking ahead, participants across the food supply chain will need enhanced end-to-end visibility so that they can work together to get ahead of the curve. As part of gaining this visibility, they will need the transparent exchange of information and cohesive collaboration to adapt especially as the food industry continues to see shifts in consumer behavior and the marketplace in the wake of COVID-19—particularly in the following three key areas.

Food Distribution

While food producers have been working tirelessly to keep grocery store shelves and restaurant kitchens well stocked, there continues to be fluctuating availability on certain products, such as eggs, dairy, poultry and meat. This has led distributors and suppliers to increase their prices when selling these goods to stores and restaurants, who have had to then pass the additional costs on to consumers through their own price increases and surcharges, respectively. One report from CoBank, a cooperative bank part of the Farm Credit System, notes there could be as much as a 20% increase in the price of pork and beef this year due to supply issues.1 Many grocers have also implemented purchase limitations on consumers to combat shortages.

These downstream implications stem largely to uncertainty in the supply chain, with stores and restaurants unsure about available supply upstream and when they can expect to receive shipments. But if there was clearer visibility and transparency between production, distribution, transportation, food service and retail, then all parties could better anticipate and plan for supply shortages or delays. For instance, if a meat processing plant has to temporarily close due to cases of COVID-19, they can immediately communicate to the rest of the supply chain so that parties downstream can readily find alternative sources and minimize any necessary price inflations or other implications to consumers.

Consumer Demand

Even with the reopening of restaurants, people will likely choose to cook more of their meals at home. It was a trend that began with restaurant closures and will continue for the foreseeable future as consumers remain cautious of dining out. While this may bring tough times ahead for the food service industry, the grocery sector is seeing a huge lift in business. Research from restaurant management platform Crunchtime shows that, towards the end of June, restaurants were only seeing 64.5% of their pre-COVID-19 sales levels.2 At the same time, a study by Brick Meets Click and Mercatus reveals U.S. online grocery sales reached a record $7.2 billion in June, up nearly 10% over May.3

For food companies and brands, growth in the grocery sector has presented a challenge in the way of demand planning and forecasting. I’ve personally spoken with several company executives who have seen significant upticks in orders from their grocery channel partners—an increase for which they didn’t forecast—and are now struggling to adjust production levels accordingly to avoid the risk of excess production that would lead to unnecessary costs, wastes and losses. In such instances, real-time visibility into transactional activity and stock levels at the retail level would help production planners improve the accuracy of their forecasts and enable them to think steps ahead before orders come in and thereby optimally balance supply with demand. Stores would remain well stocked and the supply chain could flow in a more efficient and profitable way for all participants.

Food Handling

Without question, public health is the number one priority right now. Participants at each point in the food supply chain today need to communicate with each other, as well as to consumers, that they’re following best practices for social distancing, disinfecting and other precautions. It’s not to prevent the possible transfer of the virus via actual products, as the FDA notes there is currently no evidence of transmission through food or packaging. But rather, it’s to build greater confidence in the food supply chain—that everyone is doing their part to support individual and collective health and safety, which in turn prevents possible facility closures or other case-related bottlenecks that would inhibit consistent supply to the market.

There also has to be confidence that, amid these countermeasures for COVID-19, companies are still upholding their commitments to food safety, integrity and proper handling. What can support that confidence is data—shared data from every point in a product’s journey from source to shelf. The data should be transparent and available to all supply chain participants as well as immutable so that it is tamperproof and fully traceable should there be any problem, such as mislabeling or a foodborne illness. The data ultimately holds everyone accountable for their role in ensuring a safe food supply chain.

To achieve the level of visibility outlined above, the food industry will have to break away from legacy processes involving the siloed management of operational systems and databases. Instead, the disruption seen during COVID-19 and ongoing shifts in the marketplace should encourage companies to consider digital transformation and technologies that can enable a more cohesive and nimble food supply chain. These are technologies like blockchain, which provides a decentralized, distributed ledger to publish and share data in real time. Moreover, artificial intelligence that can leverage incoming real-time data to guide next-best actions, even when the unexpected occurs. Personally, I always return to the notion that the supply chain is a team sport. You need visibility to know what each team member is doing on the field and how to align everyone on a gameplay. The digital solutions available today offer that visibility and insight, as well as the agility to pivot as needed to obstacles along the journey from source to shelf.

References

  1. Taylor, K. (May 6, 2020). “The American meat shortage is pushing prices to unprecedented heights — here’s how it could affect your grocery bill.” Business Insider.
  2. Maze, J. (July 7, 2020). “As the coronavirus resurges, restaurant sales start slowing again.” Restaurant Business.
  3. Perez, S. (July 6, 2020). “US online grocery sales hit record $7.2 billion in June.” TechCrunch.
Melanie Neumann, Neumann Risk Services
FST Soapbox

The COVID-19 Record Retention Conundrum

By Melanie J. Neumann
2 Comments
Melanie Neumann, Neumann Risk Services

During this global pandemic, the U.S. Equal Employment Opportunity Commission (EEOC) green-lighted employers to take temperatures checks of employees and to administer COVID-19 testing for workers prior to returning to work without running afoul of the Americans with Disabilities Act (ADA). This appears straight-forward upon first reading, however, several practical uncertainties about implementation, including confidentiality, discrimination, and how long to retain records remain.

As such, deciding whether to take temperatures and/or require COVID- 19 testing as a return to work strategy is more complicated than it may seem.

Temperature Screening & Testing Considerations

Temperature screening and COVID-19 mandatory testing are both permitted medical examinations during this pandemic but are otherwise prohibited during non-pandemic times. Before adopting, employers should understand the requirements impacting the records these tests generate, including the need to protect confidentiality and to retain records for longer than one may expect.

Temperature Screens
Under normal circumstances, temperature checks are considered a prohibited medical examination under the ADA. During a pandemic, however, the Equal Employment Opportunity Commission (“EEOC”) makes an exception, allowing employers to take temperatures/use temperature checks and exclude employees from the workplace should temperatures exceed public health recommendations. If employers keep records of temperatures, they must retain these records per applicable regulations. This is important because an “employee medical record” would likely result if employers take employees’ temperatures or collect temperature related records. As we will see below, there are regulatory requirements that require how we conduct these screens, and where and for how long we must retain them.

COVID-19 Testing

COVID-19 testing also constitutes a permissible medical exam under ADA during this pandemic, per the EEOC-issued guidance regarding mandatory employee testing.

For medical examinations to be allowed under the ADA, the test must be “job related and consistent with business necessity,” and employers must treat information as a confidential medical exam.

The initial guidance acknowledged that the spread of COVID-19 is a “direct threat,” hence meeting the requirement that a medical exam be “job related and consistent with business necessity” and that temperature screenings were therefore appropriate. For the same reasons, in updated guidance released at the end of April 2020, the EEOC expanded that guidance to clarify that employers may choose to administer COVID-19 testing to employees before they enter the workplace to determine if they have the virus for the same reasons.

When reading the EEOC’s language closely, the permission granted by EEOC appears to be for diagnostic tests, as the guidance states testing is to determine if employees have the virus before allowing employees to return to work. It is unclear whether antibody testing is included in the above analysis because antibody tests do not determine if someone is currently infected.

In addition, there are other considerations employers should assess before adopting a testing protocol. EEOC reminds employers that they must review the accuracy and efficacy of the selected test per FDA and CDC recommendations. Moreover, pragmatic considerations, such as how to maintain social distancing and employee privacy, determining who will perform the testing and at what the frequency, not to mention evaluating whether there is enough test capacity to perform employee-wide testing at a meaningful cadence should be evaluated.

Records Management & Retention

There is another often over-looked question: What do employers do with documented test records? This question applies whether the employer conducts the test, requires tests from employee’s healthcare providers to be off work to self-isolate, or as a return to work requirement.

It was clearly outlined above that temperature records and COVID-19 test records constitute employee medical records. Why is this important? Because there are specific requirements relating to employee medical records, including what appears to be a surprisingly long retention requirement.

Where to retain: An employer should store all medical information related to COVID-19 in existing medical files, separate from the employee’s personnel file, per the ADA, limiting access to this employee confidential information. This includes an employee’s statement that he has COVID-19 or suspects he/she has the disease, or the employer’s notes or other documentation from questioning an employee about symptoms.

How long to retain: That is the 30-year question. The Department of Labor’s Occupational Safety and Health Agency (OSHA) provides retention requirements for employee medical records in certain situations for a period of an employee’s employment plus 30 years.

While COVID-19 test results and temperature screening documentation are deemed medical examinations under the applicable regulations, are the documented results deemed medical records? We turn to applicable EEOC OSHA regulations in section 1910.1020 for answers.

OSHA Requirements

The OSHA general duty clause, section 5(a)(1) requires employers to furnish to each of its employees a workplace free from recognized hazards that are causing or likely to cause death or serious physical harm. COVID-19 appears to rise to this threat level. But is that fact alone dispositive to falling under the applicable OSHA retention requirements?

OSHA regulation section 1910.1020 requires employers to retain employee exposure or employee medical records relating to employee exposure to certain hazards. This section applies to each general industry, maritime and construction employer who makes, maintains, contracts for, or has access to employee exposure or medical records, or analyses thereof, pertaining to employees exposed to toxic substances or harmful physical agents (Emphasis added).

Is SARS-CoV-2, the virus that causes COVID-19, considered a “toxic substance or harmful physical agent?”

Most would quickly assume the answer is ‘yes’. But it may not be as clear as the black and white letter of the law would hope. Let’s review some key definitions in the applicable regulation to help shed more light on this question.

What are Toxic Substances or Harmful Physical Agents?

The record retention requirement pivots on the last phrase of 1910.1020, that is “…pertaining to employees exposed to toxic substances or harmful physical agents.”

Toxic substances or harmful physical agents are defined as follows;

  • 1910.1020(c)(13) “Toxic substance or harmful physical agent” means any chemical substance, biological agent (bacteria, virus, fungus, etc.), or physical stress (noise, heat, cold, vibration, repetitive motion, ionizing and non-ionizing radiation, hypo – or hyperbaric pressure, etc.) which:
    • 1910.1020(c)(13)(i) is listed in the latest printed edition of the National Institute for Occupational Safety and Health (NIOSH) Registry of Toxic Effects of Chemical Substances (RTECS) which is incorporated by reference as specified in Sec. 1910.6; or
    • 1910.1020(c)(13)(ii) has yielded positive evidence of an acute or chronic health hazard in testing conducted by, or known to, the employer; or
    • 1910.1020(c)(13)(iii) is the subject of a material safety data sheet kept by or known to the employer indicating that the material may pose a hazard to human health. (Emphasis added by author).

The use of “or” clarifies that only one of the criteria need to be met. Based on the above, while subsections (c)(13)(i) and (c)(13)(iii) do not appear relevant, subsection (c)(13)(ii) appears to apply as SARS-CoV-2 has shown to result in acute health hazard, resulting in the disease COVID-19. Whether there is a chronic health impact remains to be seen given the novelty of this virus. That said, acute health impact appears sufficient to determine SARS-CoV-2 as a “toxic substance or harmful physical agent” for purposes of this analysis.

This alone doesn’t automatically place an employer in a 30-plus year requirement to retain employee medical records. What constitutes an “employee medical record” and “employee exposure record” for purposes of this regulation must be further understood before determining appropriate retention.

What are Employee Medical Records and Employee Exposure Records?

“Employee medical records” are defined in section 1910.1020(c)(6), and means a record concerning the health status of an employee that is made or maintained by a physician, nurse or other healthcare personnel, or technician, including: Medical and employment questionnaires or histories, the results of medical exams, lab test results, medical opinions/doctor’s recommendations, first aid records, employee medical complaints, and descriptions of treatment or prescriptions.

Section 1910.1020(d)(1)(i) goes on to specifically prescribes a minimum of a 30-plus year retention period as follows: “The medical record for each employee shall be preserved and maintained for at least the duration of employment plus thirty (30) years.”

“Employee exposure records,” are defined in subsection 1910.1020(d)(1)(ii), as: “Each employee exposure record shall be preserved and maintained for at least thirty (30) years,…”. Some exceptions are listed in this subsection for records relating to health insurance claims, first aid records and records relating to employees working less than one year.

What Constitutes Employee Exposure?

One must also look at what “employee exposure” means in light of this regulatory requirement to determine applicability of the 30-plus year retention.

1910.1020(c)(8) defines “exposure” or “exposed” to mean that an employee is subjected to a toxic substance or harmful physical agent in the course of employment through any route of entry (inhalation, ingestion, skin contact or absorption, etc.), and includes past exposure and potential (e.g., accidental or possible) exposure, but does not include situations where the employer can demonstrate that the toxic substance or harmful physical agent is not used, handled, stored, generated, or present in the workplace in any manner different from typical non-occupational situations.

More Questions than Answers

This analysis may leave more questions than answers, as several questions remain after looking closely at the regulatory requirements. For example:

  • How can an employee prove that exposure to SARS-CoV-2 occurred in the course of employment?
  • Does the employee even have to? The regulation clearly states that it is the employer’s burden, in that the “employer demonstrate that a toxic substance or harmful physical agent was not present in the workplace in any manner different from typical, non-occupational situations”.
  • How can an “employer demonstrate” that the harmful physical agent was not present? In other words, how can employers demonstrate that its employees are at any greater exposure by coming to work than they are in their every day lives, like going to the grocery store?
  • How do employers prove absence? Is it even possible given several people are asymptomatic?
  • Does this analysis differ by food industry sectors? What about meat and poultry processors with known high rates of infection in their workplace? Would the analysis differ?

Conclusion

Short of additional guidance issued by Department of Labor’s OSHA, ultimately this will likely be decided by the courts when the first lawsuit on this topic arises, known as decision via case law. What do employers do in the interim while these shades of gray are not yet adjudicated? It is recommended to err on the side of caution. Find ways to adjust your company’s record retention procedures and systems to be able to accurately retain these records for the duration of your employee’s employment plus 30 years.

Resources

  1. OSHA Laws & Regulations. OSH Act of 1970. SEC 5. Duties. Retrieved from https://www.osha.gov/laws-regs/oshact/section5-duties
  2. OSHA Standards. Part 1910, Standard 1910.1020. Retrieved from https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1020
  3. OSHA. Access to Medical and Exposure Records. (2001). U.S. Department of Labor, OSHA. Retrieved from https://www.osha.gov/Publications/pub3110text.html
  4.  U.S. Equal Employment Opportunity Commission. “What You Should Know About COVID-19 and the ADA, the Rehabilitation Act, and Other EEO Laws”. (Updated May 7, 2020). Retrieved from https://www.eeoc.gov/wysk/what-you-should-know-about-covid-19-and-ada-rehabilitation-act-and-other-eeo-laws. See A. 6 and B.1.
Food Safety Tech

Upcoming Webinar: Is Your Plant COVID-19 Safe?

Food Safety Tech

The COVID-19 pandemic has caused significant disruption to the food industry, especially in meat and poultry processing facilities. On Wednesday, May 27, Food Safety Tech is hosting a complimentary webinar, “Is Your Plant COVID-19 Safe?”, to provide realistic advice and tips on how to mitigate workplace exposure risks related to COVID-19. Our subject matter expert speaker, Trish Wester, founder of The Association for Food Safety Auditing Professionals, will also insights into updated cleaning and sanitation practices, and how companies can make sure that their facilities are more prepared for the entire period of the pandemic. The event is sponsored by Sterilex.

Register now!

Alert

Meat Shortage Threat, Facility Employees Can Still Work After Potential COVID-19 Exposure

By Maria Fontanazza
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Alert

–UPDATE April 29, 2020— Yesterday President Trump signed an executive order to keep meat and poultry processing facilities operational during the coronavirus national emergency. U.S. Secretary of Agriculture Sonny Perdue said the following in a USDA statement, “Maintaining the health and safety of these heroic employees in order to ensure that these critical facilities can continue operating is paramount. I also want to thank the companies who are doing their best to keep their workforce safe as well as keeping our food supply sustained. USDA will continue to work with its partners across the federal government to ensure employee safety to maintain this essential industry.”

–END UPDATE–

As critical infrastructure workers, employees at meat and poultry processing facilities have stayed on the job during the coronavirus crisis. Hundreds have fallen ill and many have died as a result; at least 100 USDA inspectors have tested positive for COVID-19 and at least one inspector has died, according to reports. Production facilities across the country have shut down over the past month, and the threat of a meat shortage is very close to becoming a reality, warns Tyson Foods Chairman John Tyson. “In small communities around the country where we employ over 100,000 hard-working men and women, we’re being forced to shutter our doors. This means one thing—the food supply chain is vulnerable. As pork, beef and chicken plants are being forced to close, even for short periods of time, millions of pounds of meat will disappear from the supply chain,” Tyson stated in a company blog. “As a result, there will be limited supply of our products available in grocery stores until we are able to reopen our facilities that are currently closed.”

Hog and cattle producers are altering rations to slow the growth of livestock. In Iowa, the National Guard was activated to conduct testing and contact tracing of plant workers from Tyson Foods and National Beef Packing Company.

Meat production is on a 25% decline and by the end of this week, America could be entering a meat shortage, according to Dennis Smith, an Archer Financial Services commodity broker and livestock analyst.

Access the COVID-19 Resource CenterProtecting Essential Employees

“To ensure continuity of operations of essential functions, CDC advises that critical infrastructure workers may be permitted to continue work following potential exposure to COVID-19, provided they remain asymptomatic and additional precautions are implemented to protect them and the community,” the CDC’s Critical Infrastructure Guidance states. The agency also notes that screening workers for COVID-19 symptoms is “an optional strategy”.

Meat processing workers are not exposed to COVID-19 through product handling; they can be exposed via close contact with other employees in a facility. The CDC and OSHA have released interim guidance for meat and poultry processing workers and employers that details how communal work environments should be laid out and how employers should be promoting social distancing. Engineering controls include the following:

  • Reconfiguration of workstations to allow employees to be six feet apart, if possible
  • Establishing physical barriers (i.e., plexiglass or strip curtains) to separate workers
  • Working with an HVAC engineer to establish proper ventilation that limits potential exposure to coronavirus; removal of any pedestal or personal fans
  • Setting up handwashing stations or hand sanitizer (60% alcohol) stations
  • Reconfiguring break rooms and other communal areas to promote social distancing

The CDC also recommends that workers wear cloth face coverings that fit over the mouth and nose.

For workers who have experienced COVID-19 symptoms and have self-isolated at home, the CDC advises they do not return to work until they meet specific criteria.

Read the CDC and OSHA interim guidance.

Megan Nichols
FST Soapbox

How to Prevent Foodborne Pathogens in Your Production Plant

By Megan Ray Nichols
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Megan Nichols

Foodborne pathogens, such as bacteria and parasites in consumable goods, can result in illnesses and deaths, wreaking havoc on residents of states and countries. The companies at fault often face severe damage to their reputation as people fear that continuing to do business with a brand is not safe. Moreover, if the affected enterprises do not take decisive steps to prevent the problem from happening again, they may receive substantial fines or closure orders.

Statistics from the U.S. federal government indicate that there are approximately 48 million cases of foodborne illnesses in the American food supply each year. Fortunately, there are proven steps that production plant managers can take to minimize the risk of foodborne pathogens. Being familiar with the preventative measures, and taking steps to implement them prevents catastrophes.

Engage with Suppliers about Their Efforts to Kill or Reduce Foodborne Pathogens

Foodborne pathogens can enter a production plant on items like fresh produce received from farm suppliers. Agricultural professionals commonly use chlorine to decontaminate goods before shipping them. However, researchers used a chlorine solution on spinach leaves to assess its effectiveness in killing common types of bacteria. The team discovered that, even after chlorine exposure, some bacteria remained viable but undetectable by industrial methods.

Foodborne pathogens can originate at farms for other reasons, too. Failing to take the proper precautions during animal slaughter can introduce contaminants into meats that end up in food production facilities. Water impurities can also pose dangers.

All production plants should regularly communicate with suppliers about the actions they take against foodborne pathogens. Food safety is a collective effort. Practicing it means following all current guidance, plus updating methods if new research justifies doing so. If suppliers resist doing what’s in their power to stop foodborne pathogens, they must realize they’re at risk for severing profitable relationships with production plants that need raw goods.

Consider Using Sensors to Maintain Safe Conditions

The Internet of Things (IoT) encompasses a massive assortment of connected products that benefit industries and consumers alike. One practical solution to enhance food safety in a production plant involves installing smart sensors that detect characteristics that humans may miss.

For example, the USDA published a temperature safety chart that explains what to do with food after a power outage. Most items that people typically keep in refrigerators become dangerous to eat if kept above 40o F for more than two hours.

Food production plants typically have resources like backup power to assist if outages occur. But, imagine a cooler that appears to work as expected but has an internal malfunction that keeps the contents at incorrect temperatures. IoT sensors can help production plant staff members become immediately aware of such issues. Without that kind of information, they risk sending spoiled food into the marketplace and getting people sick.

Researchers also developed a sensor-equipped device that detects the effectiveness of hand washing efforts. In a pilot program involving 20 locations, contamination rates decreased by 60% over a month. Most restrooms at food preparation facilities remind people to wash their hands before returning to work. What if a person takes that action, but not thoroughly enough? Specialty sensors could reduce that chance.

Install Germicidal Ultraviolet Lights

With much of the world on lockdown due to the COVID-19 pandemic, many people want to know if germicidal ultraviolet lights could kill the novel coronavirus. Researchers lack enough information to answer that question definitively. They do know, however, that germicidal ultraviolet lights kill up to 99.99% of bacteria and pathogens.

Plus, these lights are particularly useful in food production because they get the job done without harsh chemicals that could make products unsafe. Ultraviolet lights can damage the skin and eyes, so you must only run them when there are no humans in the room. However, it’s immediately safe to enter the environment after switching the lights off.

These specialized light sources do not eliminate the need for other food safety measures. Think about implementing them as another safeguard against adverse consequences.

Teach Workers about Safe Practices

Food contamination risks exist at numerous points along the supply chain. Mishandling is a major culprit that could make several parties partially responsible for a foodborne pathogen problem. For example, if a person does not wear the proper gear when handling food or stores items intended for raw consumption in places where meat juices touch them, either of those things and many others could cause issues with foodborne pathogens.

As you inform employees about which procedures to take to manage the risks, emphasize that everyone has an essential role to play in keeping products free from contaminants. If workers make ready-to-eat foods, such as packaged sandwiches, ensure they understand how to avoid the cross-contamination that happens when reusing cutting boards or utensils without washing them first.

The FDA requires domestic and foreign food facilities to analyze and mitigate risks. Employee training is not the sole aspect of staying in compliance, but it’s a major component. If a person makes a mistake due to improper or nonexistent training, that blunder could have significant financial ramifications for a food production facility.

Widely cited statistics indicate that food recall costs average more than $10 million, which is a staggering figure in itself. It doesn’t include litigation costs incurred when affected individuals and their loved ones sue companies, or the expenses associated with efforts to rejuvenate a brand and restore consumer confidence after people decide to take their business elsewhere.

Ensuring that workers receive the necessary training may be especially tricky if a human resources professional hires a large batch of temporary employees to assist with rising seasonal demands. If a higher-up tells them that time is of the essence and the new workers must be ready to assume their roles on the factory floor as soon as possible, training may get overlooked. When that happens, the outcomes could be devastating. Efficiency should never get prioritized over safety.

Stay Abreast of Emerging Risks

Besides doing your part to curb well-known threats that could introduce foodborne pathogens, spend time learning about new problems that you may not have dealt with before.

For example, scientists have not confirmed the origin of COVID-19. However, since early evidence suggested live animal sales and consumption may have played key roles, Chinese officials cracked down on the wildlife trade and imposed new restrictions on what was largely an unregulated sector cloaked in secrecy.

Much remains unknown about COVID-19, and it’s but one virus for food producers to stay aware of and track as developments occur. The ongoing pandemic is a sobering reminder not to blame specific groups or ethnicities, and to avoid jumping to hasty conclusions. It’s good practice to dedicate yourself to learning about any production risks that could introduce foodborne pathogens. Read reputable sources, and don’t make unfounded assumptions.

A Collective and Constant Effort

There is no single way to combat all sources of foodborne pathogens. Instead, anyone involved in food production or supply must work diligently together and know that their obligation to prevent issues never ceases.

Coronavirus, COVID-19

Worker Safety a Concern as COVID-19 Affects U.S. Meat Plants, Supply Chain Uncertain

By Maria Fontanazza
1 Comment
Coronavirus, COVID-19

Employees at meat processing plants across the nation aren’t reporting to work as they fear for their health during the coronavirus pandemic. Hundreds of workers have become infected with COVID-19, and several deaths have been reported. There is no official count on the infection rate or how many employees have succumbed to the novel coronavirus, but the information released thus far is alarming. Demands for more protective equipment, along with hazard pay, may not be enough to keep workers safe; concerns over a meat shortage loom.

Tyson Foods

On March 31, Tyson Foods posted on “The Feed Blog” (the company’s blog) that it would be taking additional measures to protect and reward its frontline workers and truckers during the COVID-19 crisis: Protection in the form of “protective facial coverings for production workers who request them” and a reward in the form of a “one-time $500 bonus” to be paid the first week in July “based on their work attendance in accordance with our relaxed COVID-19 attendance policy during the months of April, May and June”.

Last week Tyson Foods issued a news release about the steps it is taking to further handle the COVID-19 problem at U.S. plants: At all facilities, workers are having their temperatures taken (temporal thermometers or infrared temperature scanners, depending on the location) prior to entering the plants; the company has increased deep cleaning and sanitizing, some of which will require the shutdown of at least one day of production. The release also states that Tyson Foods is implementing more social distancing measures, which includes putting up dividers between workstations and increasing space between workers on the plant floor.

The company’s measures come among serious concerns about the presence of outbreaks at various facilities. The New York Times reported about the deaths of three workers at a Tyson poultry plant in Camilla, Georgia, one of whom was allegedly told to return to work even after feeling symptoms of COVID-19. In Columbus Junction, Iowa, a Tyson pork plant closed after more than 24 employees tested positive for COVID-19. And according to the Benton-Franklin (Washington state) health district COVID-19 Case Count page, 30 people linked to the Tyson Fresh Meats plant have been diagnosed with the coronavirus as of April 13.

Cargill, Inc.

Last week Cargill closed a meat production facility in Hazleton, PA due to the high concentration of COVID-19 cases in the area. The facility has 900 employees, and it has been reported that some workers were staying home as a result of testing positive for coronavirus or out of concerns for their own safety.

JBS

JBS shut down its plant in Pennsylvania for two weeks; it shuttered its beef plant in Greeley, Colorado after at least 36 employees tested positive for the virus, and at least one death was reported. One representative for union workers stated 50 employees have tested positive and an additional worker has died. JBS issued a statement on Friday that it is offering free COVID-19 tests to all workers at the Greeley beef plant. The company also lists its policy on prioritizing team member health and safety on its website.

Smithfield Foods, Inc.

Smithfield Foods is the world’s largest pork processing company, employing 40,000 people in the United States. The company shut down its plant in Sioux Falls, SD indefinitely after more than 80 workers tested positive for COVID-19 (this particular accounts for 4–5% of pork production domestically and employs an estimated 3700 workers). “The closure of this facility, combined with a growing list of other protein plants that have shuttered across our industry, is pushing our country perilously close to the edge in terms of our meat supply,” said Kenneth M. Sullivan, president and CEO of Smithfield Foods in a news release. “It is impossible to keep our grocery stores stocked if our plants are not running. These facility closures will also have severe, perhaps disastrous, repercussions for many in the supply chain, first and foremost our nation’s livestock farmers.”

Several Smithfield Food workers in poultry plants across Alabama, Georgia and Tennessee have also tested positive for the virus.

“We have a stark choice as a nation: we are either going to produce food or not, even in the face of COVID-19,” said Sullivan.

Maria Fontanazza, Food Safety Tech
From the Editor’s Desk

COVID-19 in the Food Industry: So Many Questions

By Maria Fontanazza
1 Comment
Maria Fontanazza, Food Safety Tech

Industries across the global are reeling from the COVID-19 crisis. Although we are clearly not in a state of “business as usual”, the food industry is essential. And as this entire industry must continue to move forward in its duty to provide safe, quality food products, so many questions remain. These questions include: Should I test my employees for fever before allowing them into the manufacturing facility? What do we do if an employee tests positive for COVID-19? How can the company continue safe production? Should we sanitize between shifts on the production line? Should employees on the production floor wear face masks and shields? At what temperature can the virus be killed? The list truly goes on. We saw it ourselves during the first Food Safety Tech webinar last week, “COVID-19 in the Food Industry: Protecting Your Employees and Consumers” (you can register and listen to the recording here). Amidst their incredibly busy schedules, we were lucky to be graced with the presence and expertise of Shawn Stevens (food safety lawyer, Food Industry Counsel, LLC), April Bishop (senior director of food safety, TreeHouse Foods, Inc. and Jennifer McEntire, Ph.D. (vice president of food safety, United Fresh Produce Association) for this virtual event.

From a manufacturing point of view, we learned about the important ways companies can protect their employees—via thorough cleaning of high-touch areas, vigilance with CDC-recommended sanitizers, conducting risk assessments related to social distancing and employees in the production environment—along with the “what if’s” related to employees who test positive for COVID-19. Although FDA has made it clear that there is currently no indication of human transmission of the SARS-CoV-2 virus through food or food packaging, some folks are concerned about this issue as well.

“The U.S. food supply remains safe for both people and animals. There is no evidence of human or animal food or food packaging being associated with transmission of the coronavirus that causes COVID-19,” said Frank Yiannas, FDA deputy commissioner for food policy and response in the agency’s blog last week. “Unlike foodborne gastrointestinal viruses like norovirus and hepatitis A that make people ill through contaminated food, SARS-CoV-2, which causes COVID-19, is a virus that causes respiratory illness. This virus is thought to spread mainly from person to person. Foodborne exposure to this virus is not known to be a route of transmission.”

As the industry continues to adjust to this new and uncertain environment, we at Food Safety Tech are working to keep you in touch with experts who can share best practices and answer your questions. I encourage you to join us on Thursday, April 2 for our second webinar in this series that I referenced earlier, COVID-19 in the Food Industry: Enterprise Risk Management and the Supply Chain. We will be joined by Melanie Neumann, executive vice president & general counsel for Matrix Sciences International, Inc. and Martin Wiedmann, Ph.D., Gellert Family Professor in Food Safety at Cornell University, and the event promises to reveal more important information about how we can work through this crisis together.

We hear it often in our industry: “Food safety is not a competitive advantage.” This phrase has never been more true.

Stay safe, stay well, and thank you for all that you do.