By Conn Maciel Carey’s COVID-19 Task Force
On August 19, 2020, the Food and Drug Administration (FDA) and the Occupational Safety and Health Administration (OSHA) released a detailed checklist for human and animal food manufacturers to consider when continuing, resuming or reevaluating operations due to the COVID-19 pandemic.
The stated purpose of the new guidance document is “for FDA-regulated human and animal food operations to use when assessing operations during the COVID-19 pandemic, especially when re-starting operations after a shut down or when reassessing operations because of changes due to the COVID-19 public health emergency caused by the virus SARS-CoV.”
The checklist is intended to guide employers who grow, harvest, pack, manufacture, process or hold human and animal food regulated by FDA, and covers nearly every (if not every) topic related to COVID-19 including:
- Employee health screenings;
- Operation configuration for social distancing;
- Recommended engineering controls (e.g., physical barriers and adequate ventilation);
- Communication and training;
- Coordination with public health officials;
- Exposure scenarios and return-to-work criteria;
- Hand hygiene and respiratory etiquette;
- Flexible sick leave policies;
- Cleaning/disinfecting; and
- PPE and face coverings.
The checklist also includes some more topics somewhat unique to the food industry, such as:
- Shared/communal housing;
- Recommendations for critical infrastructure workers;
- Social distancing configurations for harvesting and along production lines; and
- Process Safety Management considerations for facilities with ammonia refrigeration systems that may have been shut down.