Covid considerations for HACCP
My seniors have suggested we do so, though personally I'm sceptical of the relevance or need to amend the HACCP given the nature of HACCP itself and what we know about the risk of Covid to food safety. I imagine any argument would involve an indirect i.e. distancing/loss of sales = less staff = potential impact on training/monitoring.
Before I meet and discuss with the directors I'm interested to hear if anyone here has amended their HACCP and if so on what basis?
Haven't specifically added to HACCP, but did minute it as a point of discussion at a recent senior management review - we have a standard section for any scientific developments of relevance, so provided an ideal opportunity to discuss and confirm that this wasn't a direct consideration for food safety. Hopefully anyone reviewing your system will fully understand that it isn't a food safety risk in the normal sense, but having some opportunity to have recorded that it's been considered might not be a terrible idea. I wouldn't go to too much trouble to do this though ;)
We didn't change our HACCP but we did go over our GMPs and SOPs. I have a separate folder for the COVID-19 related SOPs and GMPs.
Based on the advice of our consultants (yes, even consultants have consultants) in science, medical field, crisis management, etc. we have advised our clients to not do anything specific to CV. However we are in discussions on bringing out the best and the worst this exercise brought forth for each company and that will be used for future planning and the immediate need of our clients to overcome what could be a big near term issue with employees of their companies that put CV related protocols into place.
I haven't changed anything with regard to FSMS, GMP, etc. It's more about health & safety as it's been mentioned by some advisories (e.g. MOL, Health Canada) that covid's not transmittable through the food products.
Not HACCP plans but some PRPs including personnel health, GMP requirements have been reviewed. Also risk assessment was carried out for use of PPEs (facemask/ clothmask disposable/ reusable) in the facility If this is not in your program yet. Also reviewed the food fraud vulnerability assessments for RM's that are from highly affected countries which might have an effect on the supply chain (thereby maybe increasing likelihood of food fraud in the future).
Not HACCP plans but some PRPs including personnel health, GMP requirements have been reviewed. Also risk assessment was carried out for use of PPEs (facemask/ clothmask disposable/ reusable) in the facility If this is not in your program yet. Also reviewed the food fraud vulnerability assessments for RM's that are from highly affected countries which might have an effect on the supply chain (thereby maybe increasing likelihood of food fraud in the future).
I speculate that the terminology PRP was in fact invented as a part of the HACCP "System". Unlike GMP. :smile:
The food fraud musing seems not impossible but a bit of a (RA) stretch.
Bit OT
Theoretically it should be the Employee's responsibility to inform Supervisor if they have (or presumably think they may have) Covid-19. ?
I daresay in some facilities H&S is included in the QA/Production job description ? eg -
Updated Crisis Management plan to include pandemics and their supply chain disruptions. I mentioned the wearing of masks, just saying they are not a risk to food safety. You also have to be careful with things like production managers increasing sanitation, some employees here just started spraying without really thinking. Also any sneeze shields etc that have been put in place have been added to a cleaning schedule etc. Also have to be careful if you are forced to shutdown and sanitize, some of these cleaning companies are not used to the strictness of manufacturing facilities, they usually clean pizza joints etc. Also my go-to ready to use sanitizing spray was not on List-N, so we had to add our new bleach dilution to approved chemicals etc.
Hopefully the rest of the HACCP team will agree!