Who would have even thought to put the topic of a pandemic in your business continuity plan? I know, I sure never thought of it, even as a senior auditor. I think that most of us are familiar with the typical subjects of tornados, floods, power outages and disgruntled employees, to name a few. We now need to focus on adding a pandemic to the to-do list of your plan, as this global issue has become a reality since early 2020.
It is quite likely that your plant has been affected by COVID-19 in some way, therefore your site has put into place actions to mitigate the risks posed by the pandemic. What may not be likely, is that any of these actions have been documented. I have currently seen plants evolve actions based on the severity of the pandemic in their locations. Travel restrictions, reduced work force, changing employee personal protective equipment, additional employee monitoring, and remote work environments are some of the examples directly affecting sites that I have witnessed during the first half of this year. As plants learn and experience more issues, they tend to adapt to how they are mitigating the risks in their facilities.
Capturing what actions went smoothly and what has gone astray will aid in strengthening your business continuity plan. Pandemics as well as other extraordinary events are handled by a multi-step approach that needs organization and good communication. That is why it is imperative to build and document actions, then verify how those steps are to be used. Involving key personnel–not just the quality manager–at the site is a best practice in getting a full grasp on what needs to happen during an emergency. In several instances, I have witnessed that key personnel are not informed about where a site’s business continuity plan is located; or the plan was updated right before an audit and after goes back on the shelf for the next 12 months, collecting dust. Employees should be trained on the contents of the plan, their responsibilities (if they are part of the business continuity team), current contacts, updates, and ways to initiate proper channels, if or when a time comes to do so. Hopefully, it never does, but it sure does not hurt to be prepared.
The business continuity plan is not a “one-size-fits-all” approach for plants. An important consideration, when defining what actions to take, if your area has been plagued by a pandemic includes determining what risks are brought by employees, visitors (i.e., contractors), location, and type of product being produced. Plant A making a high-risk open product may implement additional hand washing and sanitation, whereas Plant B making a low-risk closed product may implement additional health screening (i.e., temperature checks) for employees. You should ensure that it makes sense, and it is beneficial for your site and your interested parties, such as customers, consumers and stakeholders.
Your business continuity plan should be built to be a great resource to you in the time of need. And in return, you will have to put some elbow grease into shaping the document in a way that fits the ever-changing food environment. Keeping your plant current will assist your business to quickly respond to a negative event. In consequence, not having a plan that works for your site, or any at all, could lead to closed doors.
If your food processing facility needs an expansion or update, construction can be a disruptive event. Throughout the process, a variety of food safety hazards can be present, potentially putting your products at risk. While the contractors you work with are skilled at their trade, protecting your brand is ultimately your responsibility.
Extra precautions are needed to minimize the food safety risks during construction, but by developing a thorough plan and following it diligently, you can keep your products, facility and employees safe.
Preparation: The Important First Steps for Safety
Having an established environmental plan before construction starts will make the construction process go smoothly and help maintain safety. If the plan your staff is following needs changes or improvements, make updates in advance of construction and be sure that your staff is up to speed before the project begins.
First, remove any equipment that can be moved from the construction zone and cover all electrical panels, open conduit and electrical outlets to minimize areas that might harbor dust or bacteria during construction.
Next, taking steps to separate the construction and production areas is crucial. Installing heavy gauge plastic sheeting or even temporary walls to isolate the construction area will help prevent cross-contamination. Any doors or wall openings on the temporary barriers should be sealed on both sides, and the gaps between the base of the barriers and the floor should be adequately sealed to keep the surrounding production areas safe. Do whatever is necessary to minimize organisms from traveling by air outside of the construction zone.
The HVAC and air handling system in the construction area should also be evaluated for cross-contamination potential. Be sure to close off or divert the airflow to prevent air movement from the construction zone to any production areas. In addition, make sure the system will be able to accommodate additional areas or space after construction is complete and make any upgrades if necessary. Thoroughly clean the HVAC system and filters before the construction process starts.
Similarly, evaluate any drains that are present in the construction zone for cross-contamination potential and take precautions to keep pathogens from passing from the construction area to the food production areas.
Make Contractors Part of Your Plan
While contractors might have years of experience in their trade, they don’t know your food safety plan. Schedule a formal food safety training session with the contractor and all members of the construction staff. Don’t allow anyone to work in the facility before completing the training. Determine which protective clothing contractors and their team will need, such as frocks, boot covers or hairnets, and provide a separate bag or place to store them during the construction process.
Designating a single entrance for contractors and construction staff will minimize confusion and avoid mistaken entries into prohibited areas. Educate them on the appropriate traffic flow as they arrive, enter the facility, and conduct their work. Their entrance should be separate from those used by office and food production employees. Have quat or alcohol hand and tool sanitizers stationed at the designated contractor entrance, and require them to sanitize any tools, materials or equipment before entering the facility. Emphasize that no mud or other debris should be tracked into the facility. Provide the necessary guidance and monitor the entrance area to prevent that from happening.
Construction staff and in-house food production staff should be separated at all times. To prevent cross-contamination, there shouldn’t be any direct paths from the construction area to the production area. No material from the construction area should ever be brought into the food production area. Contractors and construction staff should also be prohibited from using the break rooms or restrooms that are used by the facility employees. Because they won’t have access to other areas, temporary hand wash sinks may be needed for construction employees to follow frequent hand washing and sanitizing procedures.
Best Practices for Sanitation During Construction
Before demolishing and removing any walls during the construction process, apply a foam disinfectant at 800–1000 ppm without rinsing. If any equipment needs to be moved, or if there will be new equipment brought into the area, clean and disinfect it with quat at 800–1000 ppm without rinsing.
Quat should also be applied heavily on the floors around the designated construction team entrances. Foam or spray contractors’ walkways and the construction area floor every four hours at 800–1000 ppm. Allow contractors, forklifts, dollies or other wheeled carts to regularly travel through the disinfectant to keep their feet and wheels sanitized as they move throughout the construction area.
If your construction project involves new equipment installation, discuss the sanitation requirements and restrictions with a sanitation chemical provider before purchasing this equipment to ensure you have the right chemistry on hand. Any new equipment should be cleaned and sanitized, as well as the area where it will be installed, before bringing the equipment into the area. Make sure all the surfaces of the new equipment are compatible with your current cleaning chemistry and that the installation follows proper food safety guidelines. If necessary, upgrade your food safety process to accommodate the new equipment.
Transitioning from Construction to Safe Food Production
Once the construction project is complete, remove all construction materials, tools, debris, plastic sheeting and temporary walls. Seal any holes that might have occurred in the floors, walls and ceilings where equipment was moved, and repair or replace epoxy or other floor coverings. Inspect any forklifts or man lifts used during the construction, and clean and sanitize them.
Clean the HVAC and air handling system and return it to either its pre-construction settings or an updated configuration based on what the new area requires.
Continue cleaning everything in the construction area, from ceiling to floor, including lights, walls, drains, refrigeration units and all equipment following SSOPs. Note that different cleaning products containing solvents may be needed for the initial cleaning to remove cutting oil, welding flux residues, greases, and other elements from the construction process. Be sure to have those cleaning products on hand before you get to this step to avoid delays of a thorough sanitation process. Where necessary, passivate any stainless steel equipment.
Finally, test the environment. Collect a special set of swabs and monitor the results. Apply post-rinse sanitizer and then begin food production. Implement an enhanced environmental monitoring program in all areas disrupted by the construction until the data shows a return to the baseline levels. Revise your facility SSOPs in light of any changes based on the new construction.
Achieving Seamless Productivity
Expansion can mean new capabilities for your business, but lax food safety processes during construction can jeopardize the new opportunities your expansion brings. By having a strong plan in place, following it diligently, educating contractors on your plan, monitoring activity, and using effective sanitizing chemistry, you will be able to expand while protecting your brand and avoiding food safety issues.
Grocery stores have become some of the most important retail establishments over the past few months. They’ve kept people fed and provided access to essential supplies such as toilet paper, cleaning agents and over-the-counter medications. Grocery retailers have taken extraordinary steps to help protect the health and safety of their workers and customers during the worldwide pandemic, understanding that viruses can spread quickly with high customer traffic.
While many grocery stores made operational changes to stay open during this time, more adjustments are needed to help stem future infections. Guest occupancy limits, face-covering recommendations and single-directional aisles are here to stay, at least for the near term. Customers are likely to continue online shopping, which has its own set of challenges for food and delivery safety. It will be critical for retailers to obtain reliable information, specific to the store’s location and to follow local, state and federal mitigation guidelines. Trusted sources of such information include the National Institutes of Health (NIH), the CDC and the World Health Organization (WHO), plus state and local health departments.
Grocery retailers should also consider how and when employees interact with customers. Acrylic barriers at checkout lines are one method of physical control. Providing personal protective equipment and appropriate training on its use is another good method for maintaining infection control. As regulations relax, retailers need to evaluate what, if any, other changes should occur to keep safety at the forefront.
There are many other common sense practices retailers can adopt to help minimize the spread of any virus. Viral illnesses spread primarily between individuals, so the most important act of prevention is to keep employees healthy and safe. Hand washing is one of the most important steps we can take to help prevent the spread of illnesses. Most states require grocery stores to post restroom signs mandating that employees wash their hands, but these signs typically lack specific instructions. The CDC recommends cleaning hands in a specific way to avoid getting sick and spreading germs to others. The steps are the following:
Dispense a paper towel, so it is ready before wetting hands
Wet hands with warm (100°F/38°C) water
Apply an appropriate amount of soap
Rub hands vigorously together for 20 seconds
Clean between the fingers, the backs of the hands and the fingertips
Rinse hands under warm water to remove soap
Dry hands with the paper towel
Turn off faucet with a paper towel
Use the paper towel to contact door surfaces to exit
Throw away paper towel in a trash receptacle
Because grocery store workers touch food, increasing their handwashing frequency can help prevent the transmission of other types of illnesses beyond respiratory viruses. Employees should take care to wash their hands before donning gloves for any food preparation, after touching exposed skin, after handling soiled utensils and after engaging in any other activities that could soil hands.
Facility sanitization is another essential aspect in preventing the spread of illnesses. Grocery stores already have rigorous cleaning protocols that explain how to mix and use chemicals correctly. Additional instruction on how to apply cleaning agents to surface areas as well as visual reminders reminding workers how long a cleaning solution needs to remain before wiping with a cloth. To prevent the spread of infection, many stores have added more frequent cleaning for high-touch surfaces like door handles, touch screens and carts.
When approved sanitizers run low, however, some people turn to chlorine sanitizing agents like unscented bleach. Bleach can be a highly effective sanitizer, but it can also be potentially hazardous when misused. Specifically, when mixed with other cleaning products that contain ammonia, it creates a highly toxic chlorine gas. The cleaning staff needs proper training on how to mix and use cleaning solutions, use the appropriate personal protective equipment (PPE), such as wearing gloves or a protective outer garment, and to provide appropriate ventilation in rooms where sanitizers are mixed and stored.
Grocery stores have been at the forefront of the pandemic response for some time and they will be the first to adopt “new normal” procedures. Specific guidelines around health and safety evolve, but the fundamentals of health and safety stay the same. Stores that strive to maintain high standards around cleanliness and sanitation are likely to be better positioned for the inevitable next time.
–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.”
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.”
“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.
Hand hygiene is a crucial aspect of food production and processing. How can food companies reduce the risks associated with human error in hand hygiene?
Ensuring that employees maintain a proactive and responsible attitude to hand cleanliness is worth a great deal to companies in food processing and production. This can be in regards to financial aspects- a contamination of food materials could cripple a company financially, as well as the damage to reputation that may result from poor cleanliness. In addition poor hand hygiene is a significant factor in individual illness; with employee illness hampering productivity. The costs associated with employee illness and the absences associated with such are also surprisingly high. While the vast majority of food production companies have in place a proactive approach to hand hygiene, ensuring employees themselves actually abide by hand hygiene practices can be more difficult.
You’d be forgiven for thinking that workers handling food would be proactive in terms of ensuring hand hygiene, deeming hand washing initiatives and education campaigns unnecessary. Yet research from the Environmental Health Specialists Network (ESH-Net), the collaborative forum of environmental health specialists associated with the Centers for Disease Control and Prevention (CDC), questions whether sufficient hand hygiene compliance is as widespread as one may have thought. ESH-Net found in one study that 12 percent of food workers had been into work despite suffering from a sickness bug and/or diarrhea1. Illnesses such as these can spread through a working environment very quickly and one sick employee can spiral into many more ill workers in a short period of time.
Other studies focusing on the economic cost of workplace absence due to sickness in the United Kingdom demonstrate the financial issues associated with avoidable illnesses. A report carried out by the Chartered Institute of Personnel and Development in conjunction with Simplyhealth found that the average cost of employee absence is £673 per employee, per year, with two-thirds of cases involving short-term (fewer than 7 day) absences2. The British Health and Safety Executive (HSE) put the annual cost of employee illness at more than £12billion3.
The potential for the spread of infection from an ill employee coming into work is high. It is also exacerbated by the fact that a large minority of workers do not practice adequate hand hygiene. The ESH-Net found that the average worker in facilities where food is handled will carry out an activity which would require hand washing before and after nine times an hour. The same ESH-Net report discovered that only 27 percent of workers fulfilled their hand hygiene obligations in carrying out these activities. It is also true that in many cases the quality of hand washing is insufficient and not enough to properly kill germs4. The guidelines for proper hand washing recommend the use of hot water and soap and for the whole process to take at least 20 to 25 seconds. One recommendation is that a sufficient hand washing session should take the same amount of time as singing the Happy Birthday song twice. Despite this it is clear that many people do not wash their hands for anywhere near as long as these guidelines. A report from Michigan State University found the average time spent washing hands was barely 6 seconds5.
Another piece of research suggested that 95 percent of people do not wash their hands to an adequate standard6. In addition to insufficient time spent washing hands, the efficacy of hand washing techniques employed by many people can be questionable. The Michigan State University report detailed how more than a third of people did not use soap when washing their hands, with 1 in 10 not washing their hands at all.
Although these data outline public hand hygiene practices, not specifically the practices of food workers, the findings still paint a worrying picture of ignorance of the dangers of the spread of germs or a lack of concern afforded to hand hygiene. This is especially clear when we consider how data indicating that in the food industry 89 percent of instances where workers were the source of food contamination, such contamination originated from the spread of germs directly from the hands of workers to the food itself.7
Many food facilities do attempt to tackle the issue of hand hygiene amongst its workforce, with measures including hand washing ‘stations’ situated before entrances to production areas. Other measures include minimising direct hand contact with raw food by using utensils and wearing disposable gloves. However the latter measure, disposable gloves, can cause more problems than it solves with people forgetting that some germs can be spread on the gloves just the same as on bare hands. The frequency to which hands should be cleaned, and the number of different situations that warrant hand washing can also be underestimated. Workers should clean their hands whenever it is required, not merely at regular intervals.
The installation of full-compliance, non-optional hand hygiene measures has been a success for many food companies. The most significant benefit of products which provide this service is clear- they cannot be missed or bypassed, therefore helping to ensure far greater levels of hand hygiene.
Some criticize hand sanitizers, arguing that it discourages thorough hand washing. It may be argued that points such as these misunderstand the role hand sanitizers play in hand hygiene. A proactive and effective approach to hand hygiene should combine comprehensive hand washing with sanitizing. This is why hand sanitizing products in places such as corridors can be useful as they act as a clean barrier in places where hand washing is not feasible. Hand sanitizers are most effective as an addition to hand washing, and should never be regarded as a stand-alone alternative. Using sanitizers alone is insufficient but in conjunction with thorough hand washing, it makes for is an effective hand hygiene regimen. Full-compliance products are already available. Their specific function varies from specialist hygienic door handles which dispense gel upon grip, to badges and other technology that reminds workers to wash their hands and notes when they do not, as well as simple products such as specialist self-cleaning sticker material.
Any company that includes aspects of work where food is handled face a difficult task in ensuring proper hand hygiene. Human error on the part of the worker, such as forgetting to wash hands before entering sensitive areas, or failing to wash hands to an adequate standard can result in serious consequences. This is why full-compliance products are becoming far more popular. To continue to make progress in fighting contamination in the food industry there must be a culture change amongst hygiene managers in addition to food workers as a whole towards ensuring, rather than merely encouraging hand hygiene. When hand hygiene is made compulsory the risks of human error become far less significant.
Norovirus is the number one cause of foodborne disease outbreaks worldwide. It makes people sick causing nausea, stomach cramping, vomiting and diarrhea or “stomach flu” and leads to a lot of discomfort and even death, especially in vulnerable populations like children and the elderly. Elevated risk of infection is associated with certain foods that are served raw, like fruits and vegetables, contaminated ready-to-eat (RTE) foods, or improperly cooked Oysters from contaminated waters. According to the CDC, Norovirus is the leading cause of illness and outbreaks from contaminated foods in the United States, especially in retail foodservice settings like restaurants.
Some of the potential sources of Norovirus outbreaks in retail foodservice are as follows:
Infected food handlers
Infected non-food workers and guests
Bare hands contact with RTE foods
Contamination of food deliveries at source
Improper cleaning and disposal of body fluids
Training gap on sanitizer and disinfectant use
Aerosolized vomitus around food and people
Contaminated food contact and non-food contact surfaces
Improper hand washing by food handlers
Cross contamination from restrooms
Cross contamination from high touch points in the back of the house
It is apparent from the statistics that Norovirus constitutes a major hazard to the retail foodservice industry. The good news, however, is that there are a lot of cost-effective strategies that can be implemented in a proactive manner to reduce its spread and impact on businesses, protect customers and the bottom line. Some of these preventive measures will be discussed here and in next week’s blog post.
Proper Hand Washing by Foodservice Workers
Proper hand washing is the most cost-effective method for preventing cross-contaminations including Norovirus in a retail foodservice environment. Hand wash sinks should be appropriately located to encourage compliance by both foodservice workers and guests. For example; the food code requires handling dry clean dishes with clean hands during the dish washing process. Thus, it makes a lot sense to install a hand wash sink in close proximity to an automated dishwasher. This will enhance hand washing compliance by Team Members before handling and stacking dry clean dishes. Adequate soap and hand sanitizers should be provided at all hand washing stations including restrooms. Whereas the use of hand sanitizers is not a replacement for proper hand washing with soap, there is evidence that hand sanitizers are effective against Norovirus. Proper hand washing remains the preferred option however, since the use of soap can indeed get rid of other cross contaminating organic matter and dirt. Incentive programs may be used to encourage frequent and proper hand washing by foodservice workers. More resources may be found at handwashingforlife.com to help foodservice establishments update their hand washing culture.
While enforcing proper hand washing among foodservice employees is desirable, it is also advisable to encourage hand washing among guests. Norovirus can be transmitted by infected guests to the foodservice establishment especially in buffet style restaurants where guests come in very close proximity with RTE foods. Facility design that encourages hand washing by guests was elegantly captured by the Florida based PDQ restaurant chain that installed a hand wash sink in their main dining room with a strong brand statement that “quality and clean go hand in hand”. The strategic location of a hand wash sink encourages hand washing by guests, especially among children in the full view of their parents, and with less cross contaminating contact surfaces as found in the restrooms.
Restroom Cleaning and Sanitation
Color coded cleaning and sanitizing tools are recommended for restrooms to prevent cross contamination. Tools will be dedicated for use in restrooms only and stored in a dedicated storage or closet to avoid accidental use in other areas of the foodservice establishment. The restroom can be the most important part of the restaurant with opportunities to prevent infections. Guests may also use the cleanliness of the restroom as a measure of food safety commitment by the retail food establishment (see my previous blog on “Clean Matters”). Thus, extra efforts are required to maintain and keep restrooms in a clean and sanitary condition all the time. Use of disinfectant grade chemicals for disinfecting restrooms, body fluids clean-up and high touch point areas is recommended. The alternative of preparing high concentration sanitizers is laborious and prone to mistakes by foodservice workers. In addition, such high concentrated sanitizers like 1000 – 5000 ppm chlorine-based sanitizer can be a safety concern to employees when used without PPEs. Frequent cleaning, disinfecting and replenishing of hand soap and sanitizers in the restroom are effective measures against restroom infections and cross contaminations including Norovirus.
Stay tuned for more preventative measures to be discussed in next week’s blog post…
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