Do we still need to carry out a Crisis Management Exercise even though we have one for Covid-19?
Hi everyone!
I just have a quick question re: the crisis management exercise. Since we've already deployed our crisis management plan during the pandemic, do we still need to meet to conduct a mock exercise? Or can we skip the mock exercise meeting and just provide the auditor with documented evidence of our plan in action over the last few months?
Thanks!
You need to do a mock exercise.
You do a mock exercise when you haven't had a real incident. It is meant to test your system to see if it will still function properly.
I don't see why doing real crisis management due to CoVid-19 is not a sufficient test of your system, as long as you do some sort of review to evaluate if your response was adequate or anything needs to be changed or improved.
Probably going to come down to the auditor. The system requires a "test" so certainly an actual event counts as a test of the sytem IF you followed up and analyzed where you can improve the system based on the results of the test.
I've foregon mock traces/recalls in years where the company had an actual withdrawal event. The key to a successful audit is to show that you used the event to test and improve your system, not just use it.
I believe the test must include evaluation of product. The COVID-19 doesn't affect product that we know of so there is nothing to evaluate at this time.
If Covid-19 affected the ability to continue to manufacture a a safe product due to limited staff, or re imagining a way to manufacture a safe product within the confines of employee safe distancing and reduced staff numbers wouldn't this be something that could be "tested"?
The issue of whether Covid-19 can/cannot be interpretable in respect to a Crisis Management (Mock or not) Exercise has been debated at some length already, eg -
https://www.ifsqn.co...omes-to-covid-1
https://www.ifsqn.co...20/#entry159672
https://www.ifsqn.co...on/#entry159896
The conclusion appeared to be - No Consensus. Just like this thread.
I had an audit a few months ago, I tried to play the Covid-19 card and he asked me one key question: "When you have a crisis to manage you contact SQF and your certifying body. Have you done that?" The answer is no, and he explained to me that it didn't count.
The above response is correct. Covid-19 does not affect product safety and is, therefore, not considered part of crisis management.
I wouldn't overlook the value of performing a reassessment of your Pandemic plan given what you have experienced. Not all pandemics will be the same and you could have one that affects food. They most certainly affect labor which heavily impact your business. Using what has worked and what didn't to better your plan is critical.
We treated the initial Covid-19 event as a crisis. Crisis Management Team met documented the situation (including riots/civil unrest/ site security, resources and transportation) and proceeded from there, with regular updates for the first few weeks. Once we got things stabilized in the covid restricted environment, we established rules, modified operating procedures, and documented everything.Our auditor liked what what we did and said it met the requirements for testing the system.
You do a mock exercise when you haven't had a real incident. It is meant to test your system to see if it will still function properly.
I don't see why doing real crisis management due to CoVid-19 is not a sufficient test of your system, as long as you do some sort of review to evaluate if your response was adequate or anything needs to be changed or improved.
how do you run a mock exercise for something that was never isolated?