Highlights

  • Creating Hygienic Culture

  • ABCs of PPE

  • Employee Monitoring

  • Cleaning & Sanitizing

While many economic areas have come to a halt, the food industry remains resilient in its efforts to feed the public.  But remaining in business has meant a heightened dedication to employee safety, bringing unique challenges to an already difficult job.

The U.S. Department of Homeland Security (DHS) has designated farmers, food manufacturers, storage and distribution, foodservice take-out, and retailers as “Essential Critical Infrastructure” during the COVID-19 pandemic.  These industries have the immense responsibility of delivering a safe and adequate supply of food to the nation, while keeping the health and well-being of their employees a top priority.  As a result, food industry operators must adopt supplemental activities beyond standard food safety practices in an efficient and timely manner.

Hygienic Culture Basics

It is good practice for manufacturers to create a hygiene culture similar to food safety culture where the primary objective is to use preventive measures to reduce the spread of contaminants.  Many practices that will help minimize spread of COVID-19 should already be in place, such as covering mouths and noses when coughing or sneezing, directing coughs and sneezes away from food, proper handwashing, and asking ill or symptomatic employees to remain home.  

These measures should be expanded upon by adding employee training on COVID-19 symptoms, as well as implementing six feet distancing on lines and elsewhere in the facility.  Additionally, adding extra cleaning of high traffic areas and staggering shifts and break times to support social distancing should be considered.  More frequent changing of garments such as smocks and aprons can be effective as well.  Any additional measures should be documented in writing so they can be easily referenced.

The Whats and Hows of PPE

The CDC recently revised its position on mask-wearing, stating that “CDC recommends wearing cloth face coverings in public settings where other social distancing measures are difficult to maintain (e.g., grocery stores and pharmacies), especially in areas of significant community-based transmission.”

First, it is recommended that employers review OSHA’s requirements for using masks as there are important employer compliance considerations to understand.  Key points include the fact that employers must determine that the masks themselves do not pose a hazard to workers, and that employers must provide information found in Appendix D to 1910.134 of OSHA’s Respiratory Protection Standard to workers on a one-time basis.  This appendix provides important information the employee needs to know about wearing dust masks.

Second, it is important to understand the difference between surgical masks and N95 respirators, and evaluate implications of their use given current supply constraints and CDC’s guidance that these types of masks be limited to health care workers and COVID-19 patients.

Beyond masks, cGMPs include wearing beard nets, but these vary in design and effectiveness in limiting spread of aerosols containing COVID-19.  Some are porous while others are more solid like cloth, and others are designed to cover the mouth as well. However, it is important to note these solutions are not designed to offer the same protection as face masks.  Manufacturing sites also may use disposable gloves or reusable gloves. Disposable gloves are preferred and should be used in place of reusable gloves. Where this is not possible, reusable gloves should be washed between uses with an adequate detergent concentration and water temperature.

Employee Monitoring 

The guidance document put forth by the US Equal Employment Opportunity Commission has been updated to address COVID-19.  Some highlights of the update include:

  • The ability for the employer to send home an employee with COVID-19 symptoms
  • The ability for the employer to ask employees if they are experiencing symptoms if they maintain confidentiality
  • The ability to measure employees body temperature confidentially with a calibrated infrared thermometer or by infrared camera

Additionally, an ADA-covered employer may require employees who have been away from the workplace during a pandemic to provide a doctor’s note certifying fitness to return to work.  Given doctors and other health care providers may be too busy to provide such documentation in person, other approaches may be appropriate, such as telemedicine or reliance on local clinics to provide a form, a stamp, or an e-mail to certify that an individual does not have the pandemic virus.  Modified guidelines aside, it remains important for employers to continue adherence to ADA in regard to responsibilities to individuals with disabilities.

Cleaning & Sanitizing

In reviewing cleaning programs, it is important to review current studies on persistence of coronavirus.  One study on persistence or survival of coronavirus is a summary of all coronaviruses and not specific for SARS-CoV-2 (the virus that causes COVID-19).  This study indicated that survival ranged from hours to 9 days depending on the surface type.  The second study is SARS-CoV-2 specific and reports that viable virus could be detected in aerosols up to 3 hours post aerosolization, (sneeze, cough, etc.) and up to 4 hours on copper, up to 24 hours on cardboard and up to 2-3 days on plastic and stainless steel.  This data can be used to help determine sanitation frequencies while following EPA guidelines for sanitizer use.  Beyond EPA guidelines, WHO has recommended the following:

  • 70% ethyl alcohol to disinfect small areas between uses, such as reusable dedicated equipment
  • Sodium hypochlorite at 0.5% (equivalent to 5000 ppm) for disinfecting surfaces

Note that this level of chlorine is not generally approved for food contact surfaces, so if used on these surfaces, it would need to be rinsed with potable water or an approved strength sanitizer before food production could commence.  The more concentrated solution could also be used without a rinse for things like high traffic door handles and other non-food contact areas.  Adding more frequent cleaning in high traffic areas or during certain higher risk situations, such as an employee’s work area who has been sent home ill and/or is confirmed to test positive.  Dry facilities should continue to remain dry to prevent bacterial growth.

Note that existing USDA restrictions on sanitizers used for certified organic operations are still in effect, but the following are currently allowed:

  • Chlorine materials (effective on coronaviruses at >1000 ppm)
  • Hydrogen peroxide
  • Ozone
  • Peracetic acid/peroxyacetic acid
  • Phosphoric acid
  • Potassium hydroxide
  • Sodium hydroxide (effective at normal soap/detergent concentration and contact time)

Building On A Solid Foundation

While we’re all attempting to manage the rapid pace at which the COVID-19 pandemic is evolving, it’s important to remember that existing best practices and processes in food manufacturing form a strong base in fighting harmful microorganisms, viruses included.  From there, applying guidance from leading organizations such as FDA, CDC, OSHA and WHO, while focusing on measures that are most efficient to implement and protect the largest number of employees, is the best approach to managing this crisis.

Mérieux NutriSciences is prepared to assist food manufacturers with developing business continuity plans, developing & testing crisis management plans, routine testing, regulatory support, and more.  We provide online training which may be useful during the travel bans.  We can create and conduct customized training webinars specific to businesses.  All of our routine labs are open as critical infrastructure to support the food industry, and we have courier pick up services available in many locations.

 

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