A well managed food safety system which is specific to the company for which it is developed, is essential for running a compliant food manufacturing facility.

Besides the basics of the legal obligations for a food manufacturer, which is the foundation on which Food Safety Management System (FSMS) is built, other specific requirements for the various FSMS's are successively added to this base. The first being the Pre Requisite Programmes (PRP’s), followed by HACCP and its principles.  Onto this the ISO22000, and then FSSC 22000 requirements are added.  A sturdy food safety system cannot be developed if the underlying foundation is not sound.

Food  safety is an evolving area of expertise.  Standards are updated, legal requirements change and customer's expectations increase which place pressure on current food safety systems, which demand that food producers adapt their Food Safety Systems.

Such is the dynamic nature of any management system.

Allow S.W. Food Consultant to assist with the implementation and support of your Food Safety Mangement System.  


 

COVID-19 in a Food Handling Facility

COVID-19 will most likely affect every organisation at some stage during the next few weeks and months.

Hygiene within the food industry has always been important – a pre-requisite programme without which other food safety systems cannot be implemented.  However, COVID-19 has made everyone more aware of the importance of good hand hygiene and cleanliness.

To prepare for the effect of COVID-19 on food production facilities, the following information has been summarised from a Webinar presented by Food Focus on 24 April 2020.

Policies and Procedures Required

The following topics should be covered in policies and procedures dealing with COVID-19, as applicable to the organisation:

1. Social distancing
2. PPE
3. Temperature checks, monitoring smell and taste as this can be affected,
4. Testing, continuous monitoring of your employees
5. Isolation and contact tracing
6. Cleaning and sanitation
7. Disinfection of common and high traffic areas
8. Business travel
9. Promote work from home for people who are able to
10. Adhering to the policies and procedures set out in your FSMS
11. Monitoring absenteeism
12. Emergency communication channels with employees
13. Daily toolbox talks and communication
14. Infectious disease preparedness and response plan
15. Visitor access

A COVID-19 policy addressing the why, signed by top management, must be developed.

Applicable COVID-19 procedures should be written – what to do at each area and who is responsible. 

Risk Assessment

A risk assessment must be done, not only on the effect on food safety but also the organizational risk.  Where are the risks and what can be done to minimise the risks to employees and the organization.

What do we as a company need to consider and assess:

1. PPE
2. Hand washing facilities and commodities – what if there are no Food Grade sanitiser and cleaning chemicals available
3. Hand hygiene away from the workplace – home hygiene, transportation, sanitation
4. Monitoring
5. Reducing the amount of staff required
6. Footwear – risks associated with footwear
7. Mental health and wellbeing awareness programmes
8. Planned task observations

When conducting the risk analysis: consider the following

1. PPE
   1. Masks
   2. Gloves
   3. Disposal
   4. Laundry
2. Welfare areas
   1. Don’t over crowd
   2. Cross contact risks, e.g. cups
3. Extra sanitation
   1. Cell phones
   2. Keyboards
   3. Railings
   4. Handles
   5. Tools/Utensils
   6. Truck cabs
   7. Other high touch areas (biometric access control, etc)

Where is this risk assessment included in the food safety system?

The risk assessment can be included under employee protection or organisational risk assessment SWOT analysis)

To minimise the risk to the organisation you need to consider the following:

1. Consider working shifts where there is no contact between the shifts – if a staff member tests positive then only a portion of the staff will be isolated.
2. What contingency plans will be made if there are no food grade sanisiters available?
3. Contingency production plans if no staff are available.

The risk to food safety is low, but not negligible, as the coronavirus is a respitory infection and infection is not as a result of ingestion.  The main potential for contamination is through packaging contamination.  If a consumer touches a contaminated package, they may become infected due to the cross contamination.  Worker protection doubles as consumer protection.  Any actions put into place for reducing the risk to staff, will automatically reduce the risk to the consumer.

Plan of Action if a Staff Member Tests Positive

We need to have a documented plan of action in place for when a worker tests positive, or if a service provider is ill with COVID-19.  A contingency plan must be inplace, documented, practiced and communicated.

What must be done if a staff member tests positive?  You may only disclose the person’s name and diagnosis if you have their written permission.   Please ensure confidentially as far as possible when handling the situation.

The following actions must be taken:

1. Isolate/quarantine confirmed empolyee
2. Address and isolate employees working near an infected co-worker for extended periods
3. Clean and disinfect your workplace – remember the workers rest areas (see next section for more details).
4. Notify employees

Cleaning practices and principles

Most cleaning practices are designed and tested for efficacy against bacteria and for the removal of allergens, but viruses are not usually considered.

The WHO suggest the use of disinfectants active against enveloped viruses such as the novel Corona virus responsible for COVID-19.  These are known to be:

• 70% ethyl alcohol (disinfecting small areas and equipment, e.g. thermometers)
• Sodium Hypocholorite 0.5 % (5 000 ppm) for disinfecting surfaces.

Currently virucidial efficacy testing is not available in South Africa, and sample approval at overseas laboratories takes approximately 8 weeks.  The best advise is to use chemicals which have been tested against similar viruses and to follow the WHO guidelines.

Cleaning after a COVID-19 diagnosis will be initiated after approval from the Department of Health or NICD.  A plan or protocol must be available for staff to follow.  This protocol must be available for the cleaning staff to follow.  Appropriate records must also be kept.

The protocol must include the following:

1. List of staff names involved with cleaning – for tracing purposes.
2. Chemical matrix
3. Cleaning and disinfecting process – wet clean or fogging
4. Areas to be cleaned

Records must be kept and have space for the cleaning and sanitation staff to sign as acknowledgement that cleaning was completed.  This is important should there be any queries relating to the protocols which were followed.

The most appropriate type of cleaning is dependent on the industry and what can be applied in the various areas.

Wet cleaning:

As with any cleaning programme it is specific to the industry.  Chemicals for cleaning and sanitation can be:

• Chlorinated caustic detergent/heavy duty alkaline detergent
• 1% Sodium hypochlorite (for high touch points)
• Peracetic acid (with >0.5% Hydrogen peroxide)
• QAC – broad based spectrum sanitiser following chlorine application

Fogging

Fogging follows dry and wet cleaning and sanitation protocols.  There are 2 types of fogging:

1. ULF / Cold fogging – using alcohol sanitiser (office facilities).  This has a 1 hour settling time
2. Fogging using QAC or Peracetic Acid sanitiser.  This has an 8 hour settling time.

As with fogging for insect control, safety of staff is important.  The correct respirator and other safety equipment must be followed, and signage during fogging and settling period must be visible.

Before any fogging is done sensitive equipment must be sanitised and covered.

Please also remember the staff facilities when arranging appropriate cleaning.

Advantages and Disadvantages of COVID-19

COVID-19 has taken up a large amount of resources and time to ensure the safety of staff and visitors to the premises.  Ensuring that we maintain the FSMS through this time of crisis is of continued importance.  There are some advantages for the food industry.  These include:

• More cleaning
• Better PPE
• Improved Security

But there are also disadvantages which can impact food safety:

• Less staff – but workload remains the same or is increased
• Focus is away from foreign materials, pests, maintenance, etc
• Raw material supply can be affected which may increase risks such as food fraud

References
There are a number of resources available for more information relating to COVID-19.  These are some useful links:

ENTECOM:  http://www.entecom.co.za/blog-articles/janice-giddy/1/covid-19-support-pack/134

FOOD FOCUS: http://foodfocus.co.za

GOVERNMENT WEBSITE: http://sacoronavirus.co.za

For a PDF version of this document please click here Covid_19_in_a_food_facility.pdf


Compulsory Specification for Processed Meat

The National Regulator for Compulsory Specifications (NRCS) has published regulations relating to the specifications for ready-to-eat and heat processed meat products. These standards refer to SANS 885 and, with a few exceptions, transform this voluntary standard into a compulsory standard.
 

Regulation 4 specifically refers to the SANS 885 standard, with regards to :

a) The structure of the factory/processing facility and of equipment;

b) The handling, preparing, processing, producing, packaging, marking, labelling and storage of the product;

c) The product ingredients and composition related to safety of the product e.g. food additives, contaminants;

d) The test methods specified;

e) The hygiene requirements for the factory/processing facility, equipment and for employees; and

f) Microbiological requirements for the product

 

R1058 requires that every factory or processing facility which manufactures ready-to-eat meat products be registered to ensure compliance to this standard.  Thus every shop or butchery which produces their own processed cooked or partially cooked meat products for sale, must be registered with the NRCS.

To download a copy of the regulation click on the link below.
R1058_NRCS_Compulsory_specification_for_processed_meat.pdf
 

To obtain a copy of SANS 885, go to the SABS standards store.
http://store.sabs.co.za

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