Procedure-Scope
This hazards and controls guide can assist a food facility in mitigating the effects of a pandemic infectious disease such as COVID-19 (SARS, MERS, or influenzas). The scope of this document is any food facility across the food chain.
Introduction
COVID 19 Coronaviruses are NOT believed to be transmitted via food.
However, it is possible respiratory droplets containing virus lands on food or food contact surfaces. Instead, we are looking at transmission via staff, customers, and visitors (human-to-human).
Understand the differences between viruses and bacteria.
Viruses require a host to reproduce. For COVID-19 that host is humans. Transmission of the virus is generally via human respiratory droplets (e.g. coughs and sneezes). Respiratory droplets can remain in the air for short periods of time and eventually fall and land on surfaces. Uninfected people come in contact with the virus and transmission occurs.
Which regulators or government entities may be involved?
Manufactured foods, except meats and poultry, are generally made under the regulation of the US FDA. Meats and poultry are regulated by the USDA FSIS. Retail level food businesses are likely regulated by state or local health departments or departments of agriculture. Staff concerns may be regulated by OSHA (Occupational Safety and Health Administration). Pandemic events are coordinated nationally by the US CDC and locally by individual health departments. State governments may also issue mandates.
Respiratory Virus Hazards?
- Respiratory viruses on food or food contact surfaces
- Employees are ill with a respiratory virus
- Customers, consumers, or visitors are ill with a respiratory virus
- Respiratory droplets of infected persons can transmit the virus to others.
- Respiratory droplets can remain in aerosols for short periods of time (0-3 hrs).
- Respiratory droplets can remain active on surfaces for days (0-4 days – in a few circumstances longer).
- Customers and consumers avoid food businesses due to fears of respiratory viruses.
Possible Mitigations
| Hazard: Respiratory viruses on food or food contact surfaces |
| Mitigation(s): As mentioned above, COVID 19 Corona viruses are NOT believed to be transmitted via food. Therefore, following the normal procedures in the US FDA model food code should suffice to maintain good hygiene. Special purchasing or supplier controls are not needed. It is possible that respiratory droplets from ill staff members containing virus lands on food or food contact surfaces. Therefore, a preventive measure here is to exclude ill workers from the food production facility. |
| Hazard: Respiratory viruses on food or food contact surfaces coming from ill workers. |
| Mitigation(s): Screen staff daily for symptoms of the illness. Verbal or written screening for symptoms of COVID-19 and contact with COVID-19 cases should include the following questions (reference: US CDC): q1. Today or in the past 24 hours, have you had any of the following symptoms? Fever, felt feverish, chills, cough, or difficulty breathing? q2. In the past 14 days, have you had contact with a person known to be infected with the novel coronavirus (COVID-19)? If a temperature check is to be made, use a non-contact thermometer. If questions 1 or 2 are answered yes, or if a measured temperature indicates a fever temperature range, then exclude that person from the facility. Continue to monitor excluded staff members to ascertain progression of symptoms and COVID-19 testing status. |
| Hazard: An employee is confirmed to have COVID-19 |
| Mitigation(s): The FDA has stated that if an employee is confirmed to have COVID-19, employers should inform fellow employees of their possible exposure to COVID-19 in the workplace, but maintain confidentiality. Employers should consult with the local health department for additional guidance. In some cases, local health departments are calling for 14-day isolation of people exposed to a known positive illness. Additionally, some health departments require tracking exposure of others to a known ill person. Those exposed would also be subject to the 14-day isolation. |
| Hazard: An employee is confirmed to have COVID-19, must all other staff who were in contact with them isolate for 14 days? |
| Mitigation(s): Some health departments require tracking exposure of others to a known ill person. Those exposed would also be subject to the 14-day isolation. To minimize the impact of this scenario, consider the following: 1. Limit access to different processing areas to only those workers who are necessary 2. Reconsider communal access to areas such as break, rest and locker rooms. 3. Reconsider in-facility travel of supervisors and certain positions that normally work in all areas. 4. Separate staff by shifts or work days. 5. Cross train others to fill in for vital tasks. |
| Hazard: An employee is caring for a member of their household confirmed to have COVID-19. |
| Mitigation(s): Most health departments require those exposed to known COVID-19 positive persons be subject to the 14-day isolation. To minimize the impact of this scenario on your staff, consider the following: 1. Review employee leave policies 2. Consider using temporary workers. 3. Cross train others to fill in for vital tasks. |
| Hazard: Customers may have COVID-19 (symptomatic or asymptomatic). |
| Mitigation(s): Invasive prevention (questions or temperature checks) are not likely in a consumer environment. The next best method is notification and requests that ill persons not enter the facility. Since asymptomatic consumers likely do not know they have the virus, it is best to assume the virus is entering the facility and use some of the mitigations listed below. |
| Hazard: Customers may have COVID-19 (symptomatic or asymptomatic) and contaminate consumer areas with aerosols. |
| Mitigation(s): Post signage requesting customers follow good respiratory virus hygiene including covering their nose and mouth when they cough or sneeze with a tissue or parts of the clothes (shirt, sleeve, etc). Businesses should make tissues readily available and provide a trash bin to discard tissues. |
| Hazard: Customers may have code V or D resulting in the need for clean up. Note: COVID-19 may be like other Corona viruses and be shed in infected persons feces. |
| Mitigation(s): Consider using a Norovirus Kit and following all instructions for using the PPE (Personal Protective Equipment) included. |
| Hazard: Aerosols containing virus particles may be present. |
| Mitigation(s): Consider using the highest rated HVAC filters and change them often. If possible, verify with the filter manufacturer, that the filter will trap aerosols. Consider leaving fans off to limit spread of aerosols. CDC doesn’t address aerosols for air handling in retail environments (fans and HVAC). An OSHA document does make the filter recommendation (link). |
| Hazard: N95 masks have limited availability for use in staff PPE for food facilities. |
| Mitigation(s): Limit the use of N95 face masks to those needs absolutely necessary (consult OSHA standards). Consider following the guidance of CDC on reuse of N95 face masks and disinfection recommendations. (See below). |
| Hazard: Virus particles may be present on consumer contact surfaces. |
| What exactly is a consumer contact surface? Basically this is an area or location that a consumer can touch or come into contact with. Areas of walls and ceilings that are out of a consumers reach would not be included. The consumer themselves are considered a consumer contact surface, especially their hands. Anything a consumer can touch is included, e.g. credit card machines, pens for signatures, self service items (think plastic wares or napkins), rest rooms, and front-of-house areas (booths, chairs, etc). Mitigation(s): 1. Clean and sanitize consumer contact surfaces with a high frequency (as often as feasible). Increase the frequency based on the risks or virus transmission in the area. Use normal detergents and sanitizers. They are effective in killing the virus. 2. Remove non-essential consumer contact surfaces. 3. Remove non-cleanable consumer contact surfaces or place them in areas that cannot be reached. Examples are paper or cardboard signs or menus. 4. Place pens for signing credit card receipts upside down in sanitizer between uses or find touch-less alternatives. |
| Hazard: Virus particles may be present on consumer hands. |
| Mitigation(s): 1. Provide hand antiseptic or antiseptic wipes. 2. If these are unavailable, consider placing a mobile hand sink at the facility entrance. 3. Or, make your own hand sanitizer. The FDA is permitting hand sanitizer formulation during the COVID-19 pandemic. Follow the guidance from FDA (here). |
| Hazard: Customers and consumers avoid food businesses due to fears of respiratory viruses. |
| Mitigation(s): 1. Post notices of the efforts you are doing to protect their health. 2. Remind customers that food is NOT a method of virus transmission. 3. Remind customers that retail food must be handled under the US FDA model food code that includes cleaning and sanitation procedures that occur multiple times daily. 4. Notify customers of the enhanced cleaning and sanitation of consumer contact surfaces. 5. Always provide consumers with a link to the USU CDC website so that they can access the latest evidence based information. At the same time watch for misinformation directed at the food industry. |
FAQs from the FDA (March 2020)
