When the food industry developed the Global Food Safety Initiative (GFSI), it was designed to provide a benchmark for standards to ensure confidence in the delivery of safe, quality food to consumers worldwide.
So after the coronavirus (COVID-19) pandemic struck, how well designed were these standards to ensure food safety in these times?
That’s what Baking & Snack asked Jessica Burke, senior manager, technical services for BRCGS, which is used by more than 29,000 suppliers in more than 130 countries, with certifications issued through a global network of accredited organizations.
It’s not a simple answer, of course. But overall, it’s a good thing that the industry has these standards and systems in place.
Baking & Snack: How can BRCGS certification standards ensure food safety during the current COVID-19 environment?
Jessica Burke: Our global standard for food safety has been developed to specify the food safety, quality, and operational criteria required to be in place within a food manufacturing organization to fulfill obligations about legal compliance and protection of the consumer. Food businesses that are certified to the standard must have a full understanding of the products it produces, manufactures and distributes, and have systems in place to identify and control significant product safety hazards.
The standard has two key components, senior management commitment and a HACCP-based system, which provides a step-by-step approach to managing food safety risks. With all this in mind, businesses that are used to the standard are well positioned to identify, assess and act on the new risks associated with COVID-19.
What extra precautions need to be layered onto a BRCGS-certified operation to ensure food and worker safety?
It is increasingly important that sites have a clear leadership team dedicated to managing COVID-19 processes. Given the speed at which circumstances are changing, the team should meet regularly to review and update the COVID-19 processes as required. The team should be considering government advice, staff sickness and customer requirements.
There should be increased emphasis on critical control points (CCPs). For example, back-up employees should be identified and trained to manage CCPs in case of any absenteeism. There should also be clear identification of CCPs within the processing environment for the benefit of new employees.
Emergency supplier and raw material approval procedures are crucial during this time as sites may not be able to obtain ingredients from their regular suppliers. Sites may need to look at different ways of approving raw materials suppliers where audits can’t be undertaken. They’ll also need to consider requirements for approving the raw materials themselves, which may include additional testing and inspection.
In addition, it’s important that there is good communication between the site and their customers; any changes to raw material or suppliers should be conveyed to brand owners and approved before use, where required.
Since sites may be employing high levels of temporary staff due to higher absenteeism, food defense plans should be reviewed with particular emphasis on managing any increased vulnerability.
How should production facilities handle maintenance, sanitation and similar programs?
Maintenance service providers may not be able to access the site; therefore, plans should be reviewed to set minimum maintenance levels acceptable to run the plant without unacceptable increased risk of breakdown. Items which are of known risk of failure and consequent contamination risk should be identified and regularly inspected where planned maintenance programs have been reduced. Where specialist engineering contractors are used these shall be closely controlled and managed in accordance with the sites’ COVID-19 visitor policies.
Similarly, visits from pest control technicians may be reduced. Any changes to access for pest controllers for routine visits should be based on pest risk and consider the sites’ pest management history, products handled and inherent risk of pest infestation and seasonal factors. If pest controller activity is reduced as a safeguarding measure, additional in-house surveillance and pest reporting procedures should be introduced to compensate.
Cleaning priorities should be reviewed to include the identification of hard surfaces with the potential for transfer of coronavirus, for example, door handles and utensils. Sites may also need to increase environmental monitoring and line changeover/startup inspections to manage the output of changed cleaning processes.
Obviously, employee protection is essential during this time. To manage this, sites should have a clear policy for acceptance of visitors to the site, including general visitors and subcontractor, including pest control, service engineers, contract cleaners and vehicle drivers.
Where visitors are allowed on site, procedures should be in place to make them aware of the site rules for the management of COVID-19 and ensure they are not exhibiting the symptoms of COVID-19 and do not present a COVID-19 risk to staff before acceptance on site. In addition, they should be provided with any protective clothing required for access to the site.
The site should also ensure that the operations of the site are managed to reduce the risk to employees from cross contact. This may include things like transport to the site where company contracted vehicles are used. It also involves management of communal areas, including changing areas and restrooms as well as shift start and changeovers. Other key factors include working arrangements within production, packing and storage areas, employee movement within production areas, and the use of screens to separate workers on lines where social distancing cannot be achieved.
Where risk assessment has identified the need for the use of personal protective equipment to reduce the risk of spread of coronavirus, this shall be provided for all employees and where permitted visitors.
Lastly, the site should have procedures in place to ensure employees are assessed for signs of coronavirus infection before starting work, which could include temperature checks and fit-to-work declarations.
If an employee tests positive for COVID-19, what practices should they have in place and what extra precautions should they take?
Any employee that tests positive for COVID-19 should stay home and quarantine themselves according to government guidance. The food safety standard requires companies to have procedures in place to ensure that employees, agency staff, contractors or visitors are not a source of transmission of foodborne diseases to products.
COVID-19 is not thought to be transmitted through food; however, the principle of medical screening should be extended, and all employees should be assessed for signs of coronavirus infection before starting work, every day. This may include temperature checks or fit-to-work declarations.
How is certification or recertification being conducted now during the COVID-19 environment?
There are a lot of factors at play when it comes to certification during this time. Government travel restrictions have an impact on audit arrangements and sites will have company policies to prevent visitors to the site to safeguard the health of employees. Certification bodies are also restricting auditor travel to particular countries or regions to safeguard the health of their auditors. As such, we have put procedures in place for existing certificated sites who are unable to receive a physical audit.
Where a site is operational, but a physical audit may not occur on or before the audit due date and will result in existing certificates expiring, a certificate extension of up to six months validity may be issued based on the successful completion of a risk assessment by the certification body confirming it is appropriate to continue certification.
Through discussions with the site, the certification body will gather information related to the history of third-party certification, the history and maturity of the BRCGS system, whether there is any other management system or certification in place, absence of critical situations throughout the organization's certification history with respect to the BRCGS standard and pending compliance activities or legal proceedings.
Additionally, it will gather information on product recalls since the last BRCGS audit, whether the site is functioning normally, whether significant changes have been made at the site since the last BRCGS audit, whether the site is operating to the scope of certification, any changes to processes or services outsourced following the COVID-19 emergency, and the appropriateness of the sites emergency response plan to COVID-19.
The aim of the discussion is to assess the site actions in response to COVID-19 and ensure that the site has developed its procedures such that it can continue its operations to supply safe products.
Special attention will be paid to the implementation of sites emergency response plan to COVID-19, internal audits, any significant changes to the operation of the site in response to COVID-19, recent customer complaint levels and any product recalls since the last BRCGS audit, including root cause and corrective actions put in place as a consequence.