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Shawna Wagner, DNV GL
FST Soapbox

Pandemics and Your Business Continuity Plan

By Shawna Wagner
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Shawna Wagner, DNV GL

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.

FDA

COVID-19 Leads FDA to Extend VQIP Application Period to July 31

By Food Safety Tech Staff
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FDA

Last week FDA announced the extension of the application period for importers that want to participate in the Voluntary Qualified Importer Program for FY 2021. The COVID-19 pandemic has resulted in travel restrictions and advisories that have hampered efforts by accredited Certification Bodies (CBs) to both conduct the onsite regulatory audits and issue certifications to foreign entities, which are required by the VQIP application.

The application portal will stay open until July 31.

VQIP is a voluntary fee-based program that was established under FSMA. Approved applicants are granted an expedited review and import of human and animal foods into the United States if they prove they are achieving and maintaining a high level of control over their supply chains from a safety and security standpoint. Eligibility criteria includes ensuring facilities of foreign suppliers are certified by a CB that has been accredited via FDA’s Accredited Third-Party Certification Program.