COVID-19 Food & Beverage Regulatory Updates - September 2020

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Foley & Lardner LLPThe U.S. Food and Drug Administration (FDA) has continued to publish food safety updates relating to the coronavirus (COVID-19) pandemic throughout the pandemic.  Foley’s Food and Beverage team have continued to monitor and review such guidance.  Most recently, in mid-August 2020, FDA in consultation with  the Occupational Safety and Health Administration (OSHA) released the “Employee Health and Food Safety Checklist for Human and Animal Food Operations During the COVID-19 Pandemic.” This checklist is meant to be a quick reference guide to help food manufacturers comply with the various guidance released by the FDA, OSHA, and Centers for Disease Control (CDC) during the COVID-19 pandemic. The checklist is broken down into two distinct parts.

Employee Health, Screening, and Operation Configuration

The first section focuses on employee health, screening and operation configuration for social distancing to prevent or minimize the spread of COVID-19. The checklist provides a variety of questions employers should consider when assessing operations and includes general safety measures, along with additional considerations for facilities, all personnel, and persons who are symptomatic or develop symptoms at work. Additionally, the checklist provides direction for employee exposure investigation and training and various work environment configurations to maintain social distancing.

Revisiting Existing Food Safety Requirements

The second section highlights food safety requirements that can help the food industry evaluate the potential impact of COVID-19 related operational changes on food safety practices, including closures, changes in staff, or supply chain modifications with new suppliers or ingredients. This section recommends reviewing the food manufacturer’s Food Safety or HACCP Plan to ensure that any variation in processes accounts for either a reasonable potential for a new hazard or increases the risk in a previously identified hazard. This re-assessment should include:

  • Ensuring that personnel are qualified to perform their assigned duties.
  • Considering whether a new supplier or a new ingredient warrants process changes to receiving procedures, formulation, allergens, labeling, or supplier controls.
  • Confirming that Current Good Manufacturing Practices are still being met.

The FDA notes that this checklist is not an exhaustive list of all measures that facilities may take to protect employee health and food safety during the COVID-19 pandemic, and that not all items on the checklist are relevant to all food manufacturers. Therefore, in addition to this checklist and other federal guidance, facilities should continue to communicate with and listen to guidance from their state and local governments. 

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The evolving federal, state and local policies in this area are continuously evolving as the pandemic moves across the country.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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