One year ago the FDA held an at-capacity public meeting to discuss its latest initiative, the New Era of Smarter Food Safety. At the time, the agency was planning to release the blueprint for the New Era in the spring of 2020. In fact, the FDA was just days away from unveiling it when the COVID-19 pandemic hit in March. The blueprint was put aside and it was all hands on deck, as the agency worked with the food industry to ensure companies continued operating, as they were deemed a part of America’s critical infrastructure. From there, the agency navigated through uncharted waters with the food industry and its stakeholders. It signed an MOU with USDA in an effort to prevent disruptions at FDA-regulated food facilities and address shortages of PPE, disinfection and sanitation supplies. It announced that it would conduct remote inspections and extended the comment period for the Laboratory Accreditation Program Proposed Rule. It released a COVID-19 food safety checklist with OSHA to help guide companies through employee health, social distancing, and the operational issues that have entered into play as a result of the pandemic. Food companies and the supply chain were facing an enormous challenge.
“I always thought we had one of the best food systems in the world… by and large we have an amazing food system,” said Frank Yiannas deputy commissioner for food policy and response during last week’s keynote address at the 2020 Food Safety Consortium Virtual Conference Series. “We just experienced the biggest test on the food system in 100 years. Have we passed the test? I don’t think anyone would say we scored 100%… but by and large we passed the test.” Yiannas added that COVID-19 has exposed some strengths and weaknesses in the food system as well. He also emphasized a point that he has been driving home throughout the pandemic: “The virus that causes COVID-19 is not a virus that is transmitted by food. It is a respiratory virus and generally transmitted in very different ways.”
The FDA released the blueprint for the New Era of Smarter Food Safety, which incorporated some lessons learned from COVID-19, in July. Traceability is a big part of agency’s new era initiative, and the pandemic further put a spotlight on the need for better tracking and tracing in the food industry. And under FSMA, FDA is required to “establish a system that will enhance its ability to track and trace both domestic and imported foods”. In working to meet this requirement, FDA proposed the FSMA rule on food traceability last month.
Yiannas said the proposed rule has the potential to lay the foundation for meaningful harmonization and called aspects of the proposed rule game changing. It establishes two critical components that are the leading edge of food traceability: It defines critical tracking events (i.e., what are the types of events in the food system that required those events to be kept) and key data elements (i.e., the data elements that must be captured at those critical tracking events). “These two things are big ideas for traceability,” said Yiannas. “They will allow us to harmonize how traceability is to be done, allow us to scale and allow for greater interoperability.” The proposed rule also creates a traceability list that identifies foods based on a risk-ranking model for food tracing.
FDA is encouraging comments on the proposed rule and is holding three meetings (November 6, November 18 and December 2) to discuss the proposed traceability rule. “We are going to create the final rule together,” said Yiannas.
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.
With significant clusters of COVID-19 infection among employees—16,000 cases and 86 deaths documented by the CDC through May 2020 — the food processing and distribution industry faces significant challenges in reopening their facilities and ramping up to full capacity. Technology for health and safety access governance and intelligence, along with guidelines from the CDC and OSHA, can help support food companies in the automation of certain compliance activities and a safe return-to-work strategy.
Designated part of the essential critical infrastructure by the federal government at the onset of the pandemic in the spring of 2020, the food supply chain needs active solutions to protect its workforce. But there’s more to this back-to-work transition. Workers need to feel safe and trust that new security, safety and compliance processes have their best interests in mind—transferring to an overall positive experience with their employer.
In the age of contagion, the food industry requires ways to communicate better with the workforce, identify and isolate areas of contagion and also deal with the lingering presence of potential bioterrorism, insider threat and cyber-attack. It’s a multi-faceted and complex workspace we’re reentering, one that takes coordination of technology, people and processes. Without it, food suppliers risk plant shutdowns and loss of business continuity.
Bioterrorism and insider threat remain an active part of the supply chain landscape. In fact, according to a June 2020 Wall Street Journal Pro Research Survey of cybersecurity executives at nearly 400 companies, 67% were concerned about malicious insiders. Remote workers and lax controls have exacerbated the situation and rising threats include malicious employees, accidental negligence, contractor or vendor misuse and account compromise.
The Landscape of Collaboration
The ongoing coordination between human resources (HR) and security is a collaborative effort that bolsters food defense in a COVID-19 world. Fueled by digital transformation, converged physical security and HR management solutions are wound together tightly in a coordinated and analytical approach to keep food industry employees safe and operations running smoothly.
These departments, once siloed and co-existing without direct interaction, are benefiting from software’s move to the cloud and open operating platforms, which provides increased opportunity for real-time integration of HR, security and facilities technologies. Moving to a converged approach across all departments, including HR, IT/cyber and operational technology (OT)/SCADA—can effectively secure our most critical food production and distribution resources while actively enforcing compliance and company policies, including COVID-19 mandates. In addition, physical security access governance, in a holistic manner, protects food industry workers and processes from compromised identities, systems and insider threats.
HR and physical security now have the ability to share data-insights to prevent, detect and mitigate the spread of contagions. With this convergence, organizations have the information they need to actively defend and protect the workforce, focusing on the human side of security to yield a positive experience.
Enabling a Safe and Healthy Return to Work
This time of unprecedented change has triggered a tectonic shift in the way organizations have been dealing with the health, security and safety of their workforce. Sensing a coming tsunami, HR, corporate real estate and physical security leaders are realizing that they must stop operating in silos and embrace a holistic approach. Enterprise response and recovery plans have become a major catalyst for converged security, as it has proven to be the most effective way to manage workspace access, enforce workforce security, safety and privacy.
Reopening with Technology at Your Back
Physical identity access management (PIAM) software, including visitor identity management (VIM) are convergence platforms that deliver identity and access governance, health and safety intelligence and compliance validation across the enterprise. PIAM provides a safer work environment by managing physical, logical and operational technology access for employees and visitors, actively enforcing company policies, compliance and industry regulations with built-in best practices and regulatory controls. Automated policy-driven background checks yield real-time vetting of visitors, contractors and employees while validating and identifying any policy violations. PIAM and VIM keeps facilities and workers safe, making sure the employees and visitors only have access to the areas, data and assets they need, including vital food processing areas where deliberate sabotage needs to be kept at bay.
While prevention of bioterrorism and insider threat is ongoing at food distribution, production and processing facilities there’s been a notable shift during the pandemic that focuses on the health and safety of workers. Security is no longer simply about keeping the bad guys out; it’s about safety and protecting workers from unsafe behavior.
Workforce health and safety access governance software solutions help organizations open safely in a frictionless, controlled and secure way by automating and enforcing COVID-19 related policies and procedures. Automated batch email/text notifications with self-service links send requests to the remote workforce for self-attestation and self-reporting offsite and enable access by the worker to the facility based on health, travel and other company policies.
Here’s how it works: An employee completes the self-reporting health and travel questionnaire through a mobile app, which triggers automated workflows based on those answers. These health questionnaires collect data and document employee activity during lockdown, including infection, symptoms or exposure. The employee’s self-attestation request comes to the manager for action, and based on answers the worker is considered high risk and per policy their access to the facility is revoked for 14 days while they are in quarantine. A similar self-attestation and workflow then applies to reinstatement for the employee. This reporting and workflow can be configured specifically to the facility. Enterprises can further customize their visitor identity management to provide clear communication of current policies during the outbreak, reinforcing WHO best practices.
Focus on Health and Safety
Health and safety access governance and intelligence provides prescreening support of workforce site entry with automated policy enforcements. Pre-registered and onsite visitors/contractors check-in/check-out with prescreening, watch list and other checks prior to access. In the production or distribution facility, health and safety analytics track confirmed or potentially exposed COVID-19 workers, identify exposed areas for lockdown and/or sanitization, social distancing violation, location heat map and other actionable health & safety analytics.
PIAM also allows you to automate your communications and deliver clear expectations and procedures to your workforce, visitors and contractors pre-visit and onsite—adding to a seamless experience.
Security convergence delivers a comprehensive, holistic solution across the entire food value chain, from sourcing to production to retail distribution. Human resources and physical security have teamed up—yielding real-time data that can prevent, detect and mitigate the spread of contagions. With this convergence comes greater situational awareness that defends and protects the workforce, with a strong focus on safety and building trust between worker and employer.
While foodborne transmission of the novel coronavirus is unlikely , the virus has significantly affected all aspects of food production, food manufacturing, retail sales, and foodservice. The food and agriculture sector has been designated as a “critical infrastructure,” meaning that everyone from farm workers to pest control companies to grocery store employees has been deemed essential during this public health crisis.* As a society, we need the food and agriculture sector to continue to operate during a time when severe illnesses, stay-at-home orders and widespread economic impacts are occurring. Reports of fraudulent COVID-19 test kits and healthcare scams reinforce that “crime tends to survive and prosper in a crisis.” What does all of this mean for food integrity? Let’s look at some of the major effects on food systems and what they can tell us about the risk of food fraud.
Equally concerning are reports of supply disruptions in commodities coming out of major producing regions. Rice exports out of India have been delayed or stopped due to labor shortages and lockdown measures. Vietnam, which had halted rice exports entirely in March, has now agreed to resume exports that are capped at much lower levels than last year. Other countries have enacted similar protectionist measures. One group has predicted possible food riots in countries like India, South Africa and Brazil that may experience major food disruption coupled with high population density and poverty.
Supply chain complexity, transparency and strong and established supplier relationships are key aspects to consider as part of a food fraud prevention program. Safety or authenticity problems in one ingredient shipment can have a huge effect on the market if they are not identified before products get to retail (see Figure 1). Widespread supply chain disruptions, and the inevitable supplier adjustments that will need to be made by producers, increase the overall risk of fraud.
Regulatory oversight and audit programs have been modified. The combination of the public health risk that COVID-19 presents with the fact that food and agriculture system workers have been deemed “critical” has led to adjustments on the part of government and regulatory agencies (and private food safety programs) with respect to inspections, labeling requirements, audits, and other routine activities. The FDA has taken measures including providing flexibility in labeling for certain menus and food products, temporarily conducting remote inspections of food importers, and generally limiting domestic inspections to those that are most critical. USDA FSIS has also indicated they are “exercising enforcement discretion” to provide labeling flexibilities. The Canadian Food Inspection Agency (CFIA) announced they are prioritizing certain regulatory activities and temporarily suspending those activities determined to be “low risk.” GFSI has also taken measures to allow Certification Program Owners to provide certificate extensions due to the inability to conduct in-person audits.
While these organizations have assured stakeholders and the public that food safety is of primary importance, the level of direct regulatory and auditing oversight has been reduced to reduce the risk of virus transmission during in-person activities. Strong auditing programs with an anti-fraud component are an important aspect of food fraud prevention. Adjustments to regulatory and auditing oversight, as necessary as they may be, increase the risk of fraud in the food system.
There is a focus on safety and sustainability of foods. The food industry and regulatory agencies are understandably focused on basic food safety and food sustainability and less focused on non-critical issues such as quality and labeling. However, there is a general sense among some in industry that the risk of food fraud is heightened right now. Many of the effects on the industry due to COVID-19 are factors that are known to increase fraud risk: Supply chain disruptions, changes in commodity prices, supplier relationships (which may need to be changed in response to shortages), and a lack of strong auditing and oversight. However, as of yet, we have not seen a sharp increase in public reports of food fraud.
This may be due to the fact that we are still in the relatively early stages of the supply chain disruptions. India reported recently that the Food Safety Department of Kerala seized thousands of kilograms of “stale” and “toxic” fish and shrimp illegally brought in to replace supply shortages resulting from the halt in fishing that occurred due to lockdown measures.
High-value products may be particularly at risk. Certain high-value products, such as botanical ingredients used in foods and dietary supplements, may be especially at risk due to supply chain disruptions. Historical data indicate that high-value products such as extra virgin olive oil, honey, spices, and liquors, are perpetual targets for fraudulent activity. Turmeric, which we have discussed previously, was particularly cited as being at high risk for fraud due to “‘exploding’ demand ‘amidst supply chain disruptions.’”
How can we ensure food sufficiency, safety, and integrity?FAO has recommended that food banks be mobilized, the health of workers in the food and agriculture sector be prioritized, that governments support small food producers, and that trade and tax policies keep global food trade open. They go on to say, “by keeping the gears of the supply chains moving and actively seeking international cooperation to keep trade open, countries can prevent food shortages and protect the most vulnerable populations.” FAO and WHO also published interim guidance for national food safety control systems, which noted the increased risk of food fraud. They stated “during this pandemic, competent authorities should investigate reported incidences involving food fraud and work closely with food businesses to assess the vulnerability of supply chains…”.
From a food industry perspective, some important considerations include whether businesses have multiple approved suppliers for essential ingredients and the availability of commodities that may affect your upstream suppliers. The Acheson Group recommends increasing supply chain surveillance during this time. The Food Chemicals Codex group recommends testing early and testing often and maintaining clear and accurate communication along the supply chain.1 The nonprofit American Botanical Council, in a memo from its Botanical Adulterants Prevention Program, stated “responsible buyers, even those with relatively robust quality control programs, may need to double- or even triple-down on QC measures that deal with ingredient identity and authenticity.”
Measures to ensure the sufficiency, sustainability, safety and integrity of foods are more closely linked than ever before. In this time when sufficiency is critical, it is important to avoid preventable food recalls due to authenticity concerns. We also need to stay alert for situations where illegal and possibly hazardous food products enter the market due to shortages created by secondary effects of the virus. The best practices industry uses to reduce the risk of food fraud are now important for also ensuring the sufficiency, sustainability and safety of the global food supply.
*Foodborne transmission is, according to the Food Standards Agency in the U.K., “unlikely” and, according to the U.S. FDA, “currently there is no evidence of food or food packaging being associated with transmission of COVID-19.”
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