Covid-19 Risk Assessment in Food Manufacturing environments (part 2)

Undertaking a Covid-19 Risk Assessment

The welcome news that food businesses are slowly returning to normal also creates a dilemma for business owners and managers. Many have been hit with difficult financial situations and now must balance business as normal with increased safety procedures designed to protect staff and customers.

Following on from, Covid-19 Risk Assessment in Food Manufacturing environments (part 1): Working Safely during Covid-19 outbreak, this article briefly discusses some of the added risks posed by Coronavirus within food manufacturing environments.

Manufacturers should already be familiar with undertaking and implementing risk assessments as part of standard operations. The threat of covid has introduced a number of new risks and hazards that need to be considered, but the 5 point risk assessment plan (as detailed in the Safer Food Group’s Level 2 Health and Safety course) is an effective tool to use in the face of this new challenge.

An employer is legally responsible to protect their employees from harm at work https://www.hse.gov.uk/simple-health-safety/risk/index.htm – failure to do so can lead to prosecution, considerable fines and even prison sentences. A risk assessment should be carried out by a competent person who has adequate experience and oversight but involving workers in the process is a very good idea as this can often highlight hazards and risks unforeseen by managers or business owners. A very comprehensive example of a covid-19 risk assessment within a food business has been compiled by Food Standards Scotland , and examples of standard risk assessments for factories and food production are available via the HSE.

  • Identify the hazards

Hazards are processes, environments or physical objects that may cause harm. In normal circumstances, you would have identified hazards by considering:  

  • Working processes and practices
  • Plant and equipment
  • Chemical and substances
  • Working environment

In the current climate, you will need to consider a new hazard – the transmission of a highly contagious virus that has the potential to cause serious harm to a large percentage of your workforce if left unchecked. This could be within your business premises, or outside of your premises if you despatch goods or send people to work outside of your premises.

Write this down – either in additional to your normal workplace risk assessment, or as a specific document that addresses Covid-19 as an individual risk. If you would like to use our Risk Assessment template, click here.

  • Assess the risk

How likely is the hazard to occur, and how much harm could it cause?

Unfortunately, in this case, the hazard could cause very significant harm. In business terms, you could experience a depletion in your workforce meaning you cannot continue day to day business, or you could transmit the virus to your customer, damaging your reputation. In personal terms, anyone who contracts the virus may be at risk of a considerable period of sickness, long term health effects or even death.

Think about the ways the virus can enter and be transmitted around your business. The current strain of Coronavirus has been shown to be particularly resistant and robust, surviving both in the air and on surfaces for considerable lengths of time. This is one of the reasons it has become such a dangerous disease.

Consider any person or object coming into your premises as a potential carrier of the disease, and think about their journeys as they move around your premises. At what stages in these journeys do people come into contact with other people or objects? Do workers share equipment, touch the same surfaces, work within a small area?

In your risk assessment, write down all the instances in which a person touches a surface or object that might have been touched by someone else – whether handling stock, ingredients or finished goods, sharing equipment or working in a shared workspace. Consider all of the times within a working day they be in close proximity to another person – don’t forget to think about break times, and periods before work when staff may gather to get changed or access leisure areas, rest areas and lockers.

As part of your assessment, you will need to understand if some people are at greater risk than others, either because of the job that they do, or because of their personal characteristics. Current guidance suggests that no specific groups of the population are unaffected by coronavirus, and as such you must consider all members of staff at risk. However, it is sensible to consider extra measures for those specifically identified as vulnerable, such as those with underlying health conditions, older people and pregnant women.

Add this information to your risk assessment document, so you remember to look at each group individually.

  • Control the risk

Consider all of your examples in your risk assessment one by one. For each of them, you should aim to ELIMINATE the risk whenever possible – examples would be to:

  •        Monitor staff infection levels. Ensure that you have a clear reporting method for any staff that report covid symptoms, and that staff and managers are aware that any suspected cases must remain away from work premises as per government guidelines.
  • Introduce a clear social distancing policy, that details how people should behave at all times whilst on your premises.
  •        Eliminate shared equipment: create individual named kit for every worker, and specify how this kit is kept apart from others’.
  •        Introduce clear zoning, so that each worker has their own obvious workspace. Enforce this with bold wall and floor signage and visual cues such as colour coding
  •        Close areas of congregation – this may mean that staff are not able to use on site facilities such as canteens if you are not able to provide adequate space for social distancing.
  •        Outsourcing elements of production if you cannot safely undertake them in house.
  •        Quarantine non perishable items that come into your business for a 72 hour period. For perishable items, you could create a suitably temperature controlled quarantine area as long as you are able to operate within use by dates

If you are unable to ELIMINATE any of your identified risks, you must take adequate steps to MINIMISE them. This might include:

  •        Regular cleaning schedules for plant and equipment that has to be shared by workers, ensuring surfaces are sanitised between each use.
  •        Provision of shields between workspaces if individuals are not able to keep at least 2m apart
  •        Provision of appropriate PPE if workers are likely to come into close contact with one another.
  •        Staggered breaks and work schedules to minimise the number of staff on premises at any point in time.

Handwashing remains one of the single most effective ways of reducing infection levels, so on top of any measures identified above, you must ensure staff have regular assess to clean, hot water and soap and are encouraged to use it on entering the premises and before and after touching surfaces and objects, on top of the normal levels of handwashing required to maintain good hand hygiene.

  • Record your findings and implement them

Add the control measures to your risk assessment document and put everything in place to allow these control measures to take place.

A vital part of this step is COMMUNICATION. In order for your control measures to be effective, everyone must understand their role in the process and carry it out. The best approach to communication is to start with a face to face discussion, that allows workers to ask questions, and gain a good understanding of your new control measures. Follow this up by a simple written document that allows them to remind themselves of the process, and use simple, bold signage within the workplace to remind them of the most important details.

During the communication stage, do not be afraid of feedback given by staff – listen to what they have to say. Their understanding of some work processes may be greater than yours, or they may have more effective ideas of how to deal with the risk. It may be useful to revisit your plans in light of staff feedback – working in a collaborative way that recognises the contribution of others is more likely to result in an effective plan that the whole team can adhere to.

  • Review your assessment and update if necessary

In light of the rapidly changing situation with Covid-19, you will need to monitor and review your measures on a regular basis to ensure their effectiveness. Some measures, such as staff absence levels should be monitored on a daily basis, in order to identify and deal with any unusual rises as quickly as possible.

Observe your control measures in action. Do they eliminate or minimise risk in the way that you intended? Do they introduce other, unconsidered risks (for instance – does increased handwashing create congregation points at sinks?)?

Keep lines of communication with staff open, seek and listen to their feedback and be prepared to adjust control measures if they are not effective. Whilst this is a period of adjustment and is unsettling for everyone, demonstrating that staff welfare is of genuine concern is very likely to have a positive long term effect within your workforce, as well as protecting your future business.

Important Links

Guidance for food businesses on coronavirus (COVID-19)

Reopening and adapting your food business during COVID-19

https://www.gov.uk/guidance/working-safely-during-coronavirus-covid-19/factories-plants-and-warehouses

https://www.hse.gov.uk/coronavirus/working-safely/index.htm

https://www.foodstandards.gov.scot/downloads/COVID-19_-_Risk_Assessment_Tool_for_Re-starting_Food_Business_Operations_During_COVID-19.pdf

https://www.hse.gov.uk/risk/casestudies/pdf/foodprep.pdf

https://www.hse.gov.uk/risk/casestudies/pdf/factory.pdf

I want to start food deliveries – do I need a license, or special car insurance?

To deliver prepared food / meals to customers, you need to be registered as a food business, via your local authority. If you run an existing food business and want to start delivering food orders, you need to consider any new or different risks posed by this change. You will need to work through your Food Safety Management System* to make sure any food you sell in this way remains safe to eat.

Planning rules were relaxed on 17 March 2020 to allow pubs and restaurants to operate for 12 months as hot food and drinks takeaways during the coronavirus outbreak. However, businesses that do this must tell their local authority when the new use begins and ends.

The Association of British insurers have confirmed that if you are using your personal vehicle to deliver groceries or other essential goods to people, as long as you are not including a delivery charge, you do not need to update your insurance cover.  If you are charging for deliveries, you should contact your insurance provider/ broker to check if they can extend your vehicle insurance to cover home delivery.

*Your Food Safety Management System, sometimes referred to as HACCP, is the system you create that considers the safety risk of every element of your food operation and puts measures in place to eliminate or minimise those risks. See TSFG’s Level 2 HACCP course for more details.

Can I train while on furlough?

We know how frustrating it can be. For some staff, the first weeks on the Job Retention Scheme felt like a welcomed break from busy lives. But now you’re keen to get back to work and thinking of ways to ease you back into your job. Renewing your food hygiene certificate, or even increasing your skills and knowledge with a Level 3 award feels like a great way of making the most of your time and showing your employer how much you’ve missed them!

But are you allowed to undertake a training course if you are furloughed? And is your employer allowed to ask you to train during your time away from the office? In most cases – YES! Your employer can ask you to undertake training related to your work, as long as you are not making money for your employer or providing services to your employer.  If your employer has asked you to train then you must be paid at least the National Minimum Wage / National Living Wage (or the equivalent apprentice wage) during the training, even if this is more than your 80% subsidised rate of pay during furlough. 

Of course, you are allowed to take courses that you choose and pay for yourself during this time – at The Safer Food Group, we have found a lot of our learners have chosen to take our Nutrition course during time off. There have been some great deals available for training courses during the pandemic, and it’s a good time to concentrate on learning that new skill or hobby that you’ve just never found time to do. BUT – do be cautious of signing up to courses that advertise themselves as free. Choose reputable suppliers, such as FutureLearn and OpenLearn, who are very clear about their genuinely free courses. Many others come with small print that reveal you become liable for fees after 4 weeks, or require you to pay back the cost of the course if you do not complete it. If in doubt, don’t be afraid to ask for clarification of terms and conditions in writing before you sign up.

What is Legionnaires Disease? Do I need to worry about it before I lockdown and when I reopen?

Legionnaires Disease is caused by Legionella bacteria, which live and breed in temperate, standing water and are then transmitted through airborne particles. Any premises that has been closed down for two or more weeks may have unintentionally been breeding this potentially fatal disease. Water systems, condensers, coolers, A/C units and tanks which have reached temperatures of 20-45 degrees C, may now harbour the bacteria – and no-one wants to face a new biological enemy in the wake of a global pandemic!

Ideally, water systems will have been flushed out, chemically treated and properly closed down before lockdown, but many businesses will not have considered this risk before they locked their doors. If that includes your business – you are not alone. The HSE has issued guidance about what to do in this situation. Follow their guidance and risk assessment here . And if necessary, call on the services of a local expert to ensure your water system is risk free before you open up to staff or customers.

7-point plan for dealing with the threat of Coronavirus in a catering premises

The key to defeating the threat of all pathogenic viruses is to break the chain of contamination. And this strategy applies as much to tackling Coronavirus in small catering premises as it does to governments dealing with the threat globally.

Guidance

Clearly Coronavirus represents a real, and in all likelihood, a sustained threat. It’s quickly become the biggest topic of conversation online, in the media, and in the park (standing a safe distance apart), resulting in huge amounts of information circulating. It hopefully goes without saying that the vast majority of this is inaccurate and misleading speculation and opinion. Rather than following the opinions of certain presidents or other uninformed reality stars, we recommend you prioritise advice from the following sources, and in the order its listed:

  1. Follow the guidance of the UK Government (Gov.uk or equivalent region)
  2. Follow the advice of your Local Authority Environmental Health team (EHO)
  3. Follow the advice of The Foods Standards Agency (food.gov.uk)
  4. Follow the advice of your professional body or trade association (for example NDNA)

Physical measures

The catering industry has for a long time used physical barriers, for example, plexiglass screens, to reduce contamination and protect food. Every food premises now needs to consider their increased use in applying social distancing between individual customers, between individual Food Handlers, and between the two. PPE including masks and visors are all generally recommended subject to a risk and needs assessment. It’s important that all catering premises that involve attendance by the public implement appropriate efforts to promote and support social distancing, including posters, limiting the numbers inside premises, floor marking, stewarding (staff allocated to control at busy times), and consider leaving doors open to help circulate air and minimise contact points. Can customers be served outside or via delivery to prevent the need to enter the premises at all?

Hand hygiene

Washing your hands regularly using the approved hand-hygiene technique explained in TSFG’s food hygiene courses is crucial to prevent the spread of pathogenic viruses. Wash your hands immediately on arrival at work, between changing food handling tasks, and after breaks, touching deliveries, cleaning, and coughing or sneezing into them. Coronavirus is destroyed by detergents, in other words ordinary soap, which breaks down the protein shell of the virus destroying it in the process. Hand-sanitisers that contain +70% alcohol content have also proved effective against Coronavirus in tests.

 What works: Detergent (soap) and hot water, hand sanitiser +70% alcohol.

 Not effective: Antibacterial wipes, antiseptic wipes, disinfectants.

Cleaning

Following your approved premises cleaning schedule has a vital role in breaking the chain of contamination. Pay particular attention to cleaning and sanitising door and cupboard handles and push plates. Detergent (physical effort and hot water) remains one of the only effective approved chemicals for a food premises. (Household bleach and surgical spirit have also proven effective in destroying Coronavirus, however neither are currently approved for general sanitising use in UK catering premises).

What works: Detergent (soap) and hot water.

 Not effective: Disinfectant, antibacterial wipes, antiseptic wipes.

Illness reporting

Food handlers have always had a professional and legal responsibility to report illness to their supervisor before attending work. In general food safety terms this included any food poisoning like symptoms and a list of communicable diseases. Coronavirus has increased these measures dramatically, so make sure you also follow the latest government (gov.uk published) advice on COVID-19 symptoms and isolation in addition to your previous illness reporting obligations.

Zoning & workflow

Social distancing at work is likely to require some rethinking of how you produce and serve or distribute food. Zoning and Workflow are food industry terms that refer to the logical planning and sequencing of food production tasks, and allocating dedicated work spaces for certain tasks. The idea is to minimise cross-contamination and time the food spends in the Danger Zone. Given that the rules around social distancing are likely to be in place for some time, it’s important that your layout and plan are reassessed to ensure they are still fit-for-purpose. 

Training & teamwork

Behind every successful food business and every unblemished food safety record is a team effort. Make sure you’ve received up to date training and you’re doing the basics such as coughing or sneezing into the elbow (aka the Dracula), as well as any changes to your role and how it must now be performed during the threat of this pandemic. It’s important that the food industry thinks creatively to find practical solutions to the challenge of Coronavirus, and every Food Handler can and must play their part by working by participating in training, contributing ideas, raising concerns, and working together.

Important Links

Guidance for food businesses on coronavirus (COVID-19)

Reopening and adapting your food business during COVID-19

Is Coronavirus (COVID-19) linked to food?

COVID-19 is NOT generally associated with food, nor does it produce food poisoning like symptoms. We have however included it in our online food safety courses for two important reasons. Firstly, most practical measures used to destroy existing food poisoning viruses on surfaces can also be applied to tackling COVID-19. And secondly, Coronavirus will have a lasting effect on how we all work, socialise and consume food, so it’s important as an industry that we understand the threat and adapt the way we work to reduce the threats to ourselves, our customers, and the future of the sector.

Government & FSA guidance is currently the best way forward for you to understand how this new virus and your business can operate safely together.


Guidance for food businesses on coronavirus (COVID-19)

Reopening and adapting your food business during COVID-19

How does coronavirus (COVID-19) spread?

Like many pathogenic viruses, Coronavirus spreads person-to-person through airborne particles produced when an infected person coughs or sneezes, and when contaminated hands touch and thus contaminate other objects. Research suggests that Coronavirus can survive for up to several days on some of the most common materials and surfaces used in food premises:

  • Coronavirus can survive airborne for up to a few hours
  • Coronavirus can survive on cardboard packaging for around 24 hours
  • Coronavirus can survive on plastic packaging for up to 3 days
  • Coronavirus can survive on stainless steel for up to 7 days

Do I need a food hygiene certificate?

There is no one simple answer to the question, ‘Do I need a Food Hygiene Certificate’ – but we can certainly help find the right answer for you.

If you are responsible for managing food safety in a business – for example, a supervisor, manager or business owner – you must be suitably trained to ensure you can put correct procedures in place and see they are carried out. You must also ensure that your team is appropriately trained in food hygiene and safety, including allergens.

If you are someone who works with food, you must be trained to a suitable level for your role, in food hygiene and safety, including allergens.

But – what is suitable or appropriate training?

The Food Standards Agency define training as:

  • training while working
  • self-study
  • relevant previous experience

So, technically, neither a supervisor nor their team requires a food hygiene certificate to operate safely and satisfactorily. However, it is worth bearing in mind that training is a key area that your EHO will look into, and it is very likely that any inspection will include a number of questions both to management and team members to satisfy the inspector that good food safety is understood and carried out. For that reason, it is good practice for all food handlers and managers to regularly undertake regulated food hygiene training and to renew on a regular basis.

For supervisors, managers, and anyone else who oversees activities and staff and is responsible for introducing and maintaining procedures and processes, it is important that training includes management level skills, for example creating and using a Food Safety Management system. In general in the UK these would be Level 3 courses – although it is always important to check the syllabus of any course you undertake, to ensure you cover all the important elements.

For food handlers – including chef, cooks, anyone in food prep and front of house staff – a Level 2 Food Hygiene certificate should cover day to day needs – although again, we would always recommend checking the syllabus of any course before you sign up. A Level 3 Certificate would be a good way to increase skills and knowledge and demonstrate readiness to take the next step into management

For anyone who doesn’t directly handle food, but an understanding of food safety is important, a Level 1 Food Hygiene Certificate can provide the basic level of training required. This training might be useful for someone making food deliveries, or a kitchen porter.

For all regulated food training, we would recommend retaking the course every 3 years. As well as refreshing knowledge, this gives the learner insight into any new practice or legislation influencing food hygiene practice introduced since their previous training.

Do volunteers need food safety training?

According to the Food Standards Agency advice on providing food at charity or community events, this depends on whether you provide food on an occasional and small scale basis – in which case you do not qualify as a food business – or on a regular and organised basis – in which case, you may need to register as a food business. In any case, food supplied at any event MUST comply with food law and be safe to eat.

If you are unsure which category you fall into, seek advice from your EHO (contactable via your local council). Don’t be afraid that this will lead to extra red tape – your EHO is there to help and advise you, and responsible planning at the outset may prevent a far more tricky situation if your food sales lead you into legal problems along the line. To give you examples – a scout group selling tea and premade cake at an annual jumble sale is not likely to qualify as a food business, but a rugby club selling cooked bacon rolls and pies every Sunday morning probably will. The scout group should still make sure that their food and drink is fresh and kept safely, and that they have a list of allergens in their cakes – but they won’t need regular checks from an EHO.

All food businesses need to comply with all EU food hygiene law, including those related to food hygiene training and allergen awareness. This means that the person in charge of the event or the catering set up must ensure that anyone preparing or handling food receives ‘the appropriate supervision and training in food hygiene and food allergens, which is in-line with the area they work in and will enable them to handle food in the safest way’ (The Food Standards Agency). This can be ensured by taking accredited training – online courses are often the most cost and time effective route for volunteers, and reputable providers can advise on the correct level of training. It could also be achieved by on-the-job training and supervision by a suitable person on site. Or the volunteer themselves may already have sufficient skills and experience to allow them to undertake the role safely – the person in charge must be able to demonstrate that the skills of each volunteer have been considered and are appropriate for their role.

At the Safer Food Group, we support a number of youth organisations, sports clubs and charities with their food hygiene and allergen training requirements. Our flexible, value for money courses allow organisations to purchase courses on behalf of their volunteers, taking advantage of our bulk purchase prices and allowing learners to undertake the training at a time that fits with their busy schedules.