During the COVID-19 pandemic, many restaurants will be severely challenged to continue business. In some cases dramatic steps may need to be considered. At other times a reduction in red tape or a temporary waiver of a rule might be applicable that still accomplishes health and safety goals but has a reduced impact on food businesses. Therefore, please consider the following:
**Consider changing regulations to permit restaurants to use their parking lots for dining space. In other areas, consider converting streets to dining space. Check out an article written on this topic.
- Be as flexible as possible with rules and regulations not directly critical to food safety !!
- Use caution creating temporary regulations specific to one jurisdiction unless they are required by greater risks of illness.
- Waive food safety manager certification expiration and/or alternatively permit technology-based home exams (lock down browsers, video monitoring, etc).
- Consider processes to help restaurants convert to all take-out and delivery
- Provide guidance for safe take-out & delivery
- Monitor delivery services closely. Delivery companies and delivery drivers fall in a gray area of food safety oversight.
- Monitor mail order of TCS food delivery closely. Most shipping companies (USPS, UPS, and Fedex do not monitor temperatures of packages).
- TCS foods must be delivered at ≤ 41F or ≥ 135F
- TCS food shipping/delivery should have temperature verification to ensure safe delivery
- (For cook-at-home meals to go) Consider permitting vacuum packaging of foods provided they are refrigerated ≤ 41F, are clearly marked use or discard within 7 days, and have correct cooking instructions.
- Alternatively apply paragraph 3-502.12 (F) for the 48 hour rule for ROP.
- If vacuum packing is not something that can be permitted, consider providing directions on how an operator can simply use non-reduced oxygen packaging to create cook at home meals (plastic clam shells, plastic wrap, etc. Apply the same criteria (≤ 7 days kept at ≤ 41F with cooking instructions label).
- Consider the regulatory factors involved to convert some or all of a restaurant space into food retail (grocery).
- Consider relaxing plumbing codes to allow for the installation of temporary customer hand sinks (e.g. located at front door). Note that besides hand sanitizer, many portable hands sinks have sold out.
- Remember that cleaning and “sanitizing” for Coronavirus on non-food contact surfaces is disinfection rather than sanitizing. There is a minor difference, but a regulatory one none-the-less. Disinfection of consumer contact surfaces is not covered in the US FDA model food code.
- Consider evaluating consumer contact surfaces and mitigations as part of inspection process (5-10 minutes might have a huge public health impact)
- Provide guidance on disinfection of consumer contact surfaces
- Consider permitting ozone as a device (as a device it is not a registered pesticide product that kills viruses).
- Remember that the Coronavirus as an enveloped virus is should be relatively easy to kill using all acceptable methods of sanitation in the food code. Additionally, regular detergents may also be somewhat lethal as they can disrupt the lipid layers of the enveloped virus. So, both “cleaning” AND “sanitation are helpful.
- Generally sanitizers are meant for 30 s contact times. Encourage contact times as long as possible for greater lethality.
- Most restaurateurs don’t understand all of the regulatory bodies with jurisdiction over them. It will likely help in compliance if mandates are clear and identified to a code (OSHA, Food Code, Health Department emergency notice, State or Governors orders, etc).
- Remember that independent restaurants most likely do not have a food safety professional at their disposal. Consider partnering with Cooperative Extension or a science association (IAFP, AFDO, NEHA, or NACCHO) to provide them with low/no cost assistance.