Navigating Employee Health and Food Safety for Human and Animal Food Operations: Key Considerations from OSHA and FDA

This checklist is just one resource industry can leverage to determine whether operations align with existing regulatory requirements and guidance out of the FDA, OSHA, and CDC.

In the U.S. Food and Drug Administration’s (FDA) March 18 briefing for stakeholders on COVID-19, Frank Yiannas, deputy commissioner of the Office of Food Policy and Response, assured listeners that the FDA is “committed to ensuring the safety of the food supply and that the food supply chain from farm to table is not disrupted.” In the same vein, Yiannas noted the importance of “protect[ing] the health and well-being of employees in the food industry responsible for bringing food from farm to table.” As the COVID-19 pandemic has since evolved, the FDA and OSHA jointly issued an Employee Health and Food Safety Checklist, covering considerations related to employee health and food safety for the food industry.

Applicability

The checklist is intended to be used by FDA-regulated human and animal food operations during the COVID-19 pandemic, including entities that are growing, harvesting, packing, manufacturing, processing, or holding human and animal food regulated by the FDA. The agencies indicate that the checklist may be useful “especially when re-starting operations after a shut down [sic] or when reassessing operations because of changes due to the COVID-19 public health emergency.” The items included in the checklist are not meant to cover every food operation. For example, while the checklist items that pertain to food safety may be useful for foreign firms that manufacture, process, pack, or hold food subject to FDA oversight, the OSHA-related safety items would not apply to those entities. Also, as indicated in the checklist, there is existing guidance applicable to specific sectors that should also be referenced, such as the Meat and Poultry Processors guidance from the Centers for Disease Control and Prevention (CDC) and OSHA or the Seafood Processing Workers guidance from the CDC, OSHA, and FDA.

Intended to Serve as a Resource, Not a New Regulatory Tool

In an interagency webinar on September 1, 2020, “COVID-19 Update for Food Operations Stakeholders Webinar,” officials from the FDA and OSHA emphasized that the checklist is only intended to serve as a resource, not a new guidance document or regulation that binds regulated entities. Michael Rogers, assistant commissioner for Human and Animal Food Operations in the FDA’s Office of Regulatory Affairs, noted that the checklist will not be used to document deviations during food inspections. Specifically, according to Rogers, “this is simply an educational tool, and not a regulatory requirement.”

Key Components

In an attempt to consolidate relevant already-existing guidance and applicable regulatory requirements, the checklist raises issues of both employee health and food safety for food operators to consider. Some of the questions directly address regulatory requirements (e.g., reassessment of the adequacy of a hazard analysis and critical control point (HACCP) plan whenever any changes occur that could affect the hazard analysis or alter the HACCP plan) while some are intended to address recommendations from the agencies (e.g., using CDC videos on COVID-19 to provide prevention information to workers). Highlighted below are a few of the key questions raised by the checklist that food facility operations should be asking when reassessing operations:

Employee Health

Employee health

  • Are practices implemented to minimize the spread of COVID-19 in accordance with recommendations from the CDC, FDA, and OSHA?
  • Does your operation have a COVID-19 assessment and control plan, as recommended by the CDC and OSHA?
  • Have you provided employees with a point of contact to report symptoms and illness and a procedure to consult with employees who have been sick with COVID-19 symptoms?

Facilities:

  • When restarting, have you ensured the environment is free from safety and health hazards, as described by OSHA?

All personnel

Persons who are symptomatic or develop symptoms at work?

  • Are procedures in place for requiring symptomatic workers to stay home or go home if they develop symptoms during the workday?
  • Are cleaning protocols in place to clean and disinfect surfaces in all areas used by a sick person, as recommended by the CDC?

Employee exposure and testing:

Work environment configuration:

  • Has the operation accounted for social distancing where feasible?
  • Has the operation consulted with engineers to ensure adequate ventilation?

Food Safety

Food safety or HACCP plan:

  • Have there been any changes to your ingredient suppliers or food products that require you to reconsider the evaluation of your hazards under your food safety or HACCP plan?
  • Should you consider a change to your procedures due to changed operations or processes?

Personnel:

  • Have there been any changes to personnel or operating procedures that would require training in food safety?
  • Is there a plan in place for how to operate with a reduced workforce if employees are sick?

Suppliers and Incoming Ingredients:

  • Do new supplier verification controls need to be implemented to address changes to your suppliers or incoming ingredients?
  • Do you need to reconsider your receiving procedures after changing suppliers or ingredients?

CGMP:

  • Are you continuing to follow current good manufacturing practices (CGMPs) to provide basic sanitation and food safety protections, including, among other things: modification to employee handwashing and sanitizing instructions; determining whether changes need to be made to cleaning, sanitizing, and disinfecting procedures; ensuring equipment is operating properly upon reopening; and determining whether current procedures address potential delays in shipments or products that could impact the safety of food?

Conclusion

Maintaining both employee health and food safety are paramount to the food industry’s ability to ensure that a safe food supply is not disrupted during the COVID-19 pandemic—and beyond. This checklist is just one resource industry can leverage to determine whether operations align with existing regulatory requirements and guidance out of the FDA, OSHA, and CDC. Industry should continue to monitor agency guidance related to employee health and food safety and be prepared for continued modifications as the COVID-19 pandemic evolves.

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