COVID-19 and your FSMS

Welcome to Food Bites, your weekly food safety fix!

We are having so much fun pulling this Blog together just for you, we cannot understand why we didn’t start ages ago.

Last week we promised to share some insights about COVID-19 and how you can use your food safety management system (FSMS) as a crises management tool.  It’s no secret that the current pandemic is wreaking havoc in food factories across the globe.  There are also so many ripple effects and although we are not the experts in terms of telling you how to deal with a positive COVID-19 test result on-site, we do know food safety management systems and how you can use the various elements of your FSMS to deal with problems.

By design, your FSMS is there to help you and it should certainly not become an extra burden while you are trying to deal with the pandemic.  On the contrary, your FSMS has some handy tools designed for this specific purpose:

1. Dealing with non-conformity through a corrective actions system is a fundamental requirement of any FSMS. Use your current system to raise non-conformances or concessions where you have deviated from any of your procedures:

• • If you are unable to execute your environmental monitoring or final product testing plan due to constraints on external or internal laboratory resources, record the deviation as a concession so that you can demonstrate that you were aware of the deviation and keep track of what still needs to be done.
  • Executing your internal audit schedule may be a challenge and you can use the same process as above to record and track any deviations from your programme.
  • Some sites have opted to disable their biometric systems to prevent unnecessary cross-contact of personnel. Using your non-conformance system to document this deviation will go a long way in demonstrating that you were aware of the implications and that you were of a “sound mind” when this decision was made.

2. Effective communication is so important in times like this when particularly important decisions need to be made. Keeping track of all the discussions and decisions could be a nightmare but using your existing internal communication infrastructure such as food safety team meetings, shift hand-overs and production meetings provide the perfect forum to discuss and track progress on certain actions.  No need to schedule MORE meetings!

3. The concept of risk is not strange to us – we are risk-assessing food safety hazards, security threats, vulnerabilities, organizational risks and many, many more. Use this aspect of your FSMS to risk assess decisions which are made that may impact the safety of the product or the integrity of your FSMS.  A perfect example is the deviation from your internal audit programme which I have already mentioned in the first section.  If you plan on deviating from the programme, you need to demonstrate that the decision to make these changes is based on risk.  In some cases, you may even find that certain aspects of your FSMS may need to be audited more often instead of less often.  Considering that you may have stricter cleaning regimes or additional personal hygiene requirements at this stage, more frequent GMP inspections may be necessary to verify that these new rules are adhered to.  In fact, if I could give you any advice, I would say; “when in doubt, risk assess.”

No doubt, how you handle the crisis situation will form an integral part of your next audit and it may become impossible for you to remember why certain decisions were made or why a specific course of action was chosen.  Recording your decisions and actions by using the existing structure within your FSMS will help you demonstrate that the situation was handled appropriately and will help you generate the evidence you may need during your next audit.

Next week’s “food bites” will look at food safety culture and why it is so important.

Take care, stay safe and don’t let your food bite!