COVID-19 and my HACCP Plan!

One question we have been getting asked a lot lately, is do I need to amend my HACCP Plan in the light of COVID-19? This post might help.

Who is responsible for COVID-19 control in my workplace?

Actually, since COVID-19 is an infectious agent that can cause harm to the workforce and visitors, it really sort of falls under COSHH, under biological agents (see here the HSE guidance on COSHH https://www.hse.gov.uk/coshh/basics/substance.htm). So in reality the Health & Safety team in your workplace is responsible for risk assessment and the implementation of controls to mitigate risk of harbourage and cross infection from COVID-19. And there’s lot’s of guidance available from the gov.uk website on COVID workplace controls (https://www.gov.uk/guidance/working-safely-during-coronavirus-covid-19). If there is a microbiologist in the HACCP team then certainly the H&S team should seek help from them!

So what has the HACCP team to do as a result of the COVID-19 crisis?

The important thing for the HACCP team is to have called an extraordinary HACCP review including as many members of the HACCP team as follows. If they have all been furloughed, but your food operation is still running, then beware! You are in breach of the food hygiene regulations as your “food safety executive” is not acting to protect food safety on site! Assuming that is not the case (hopefully!), then the extraordinary meeting should be used as the forum to discuss any potential food safety issues and what controls you will put in place as a result.

Consider these potential food safety issues arising from COVID

• You are working with less staff – does this impact food safety? For instance, are CCP, OPRP or control points not being monitored or managed as they normally would be?
• You may have extra stock of raw materials as a result of production delay. This may also have been exacerbated by Brexit “stocking up”! Does this mean that storage is overcrowded? That cleaning, inspection and pest management activities are at risk?
• You may actually have ramped up production! We have seen this for both food companies manufacturing for the increased demand in supermarkets and also from packaging companies who normally produce food and consumer goods packaging, but have “re-tooled” for PPE production. What is the impact of this? Have important monitoring and food safety management tasks been overlooked as increased production takes up resources? Have the HACCP prerequisites of waste management, housekeeping or even supplier approval suffered? Is there contamination risk to food and consumer goods packaging from the PPE packaging process?
• You may be turning on production equipment that has sat idle for a while. Does this increase risk of contamination from equipment that may not have been dismantled sufficiently, and sanitised to remove old build up. Think of pipes, pumps and seals that have sat around for a while and weren’t perfectly clean when switched off!
• You may be operating in a facility that has not been managed, cleaned and inspected as it normally would. Have you furloughed cleaning and facility management staff? If so, who is deputising for them to keep the site standards, workflow and layout in a satisfactory state?
• You may have had, or still have an essential visitor only policy. Or no external visitor policy. What is the impact? Have pest control inspections been missed? Has equipment servicing suffered?
• Have audits, internal auditing and GMP audits been lacking – remember this is where you pick up potential risk and manage it!

The list could go on of course. The key thing is recognising these potential shortfalls and doing your best to address them. Then your organisation won’t end up being one of the Infectious Intestinal Disease statistics, or potentially engaging in product withdrawal, or seeing a mass rise in complaints, or answering to the Food Standards Agency or local authority in the case of an investigation.

Don’t forget also, that released very shortly initially on Google Play, will be PandemicCheck – an essential app to audit and manage your workplace COVID and pandemic controls! https://mqmconsulting.co.uk/pandemiccheck/