COVID-19 and HACCP: What Food and Beverage Companies Should Know

9/21/20
Grainger Editorial Staff

The COVID-19 pandemic has created new challenges for many manufacturing companies. In short order, managers have had to reconfigure production lines, develop screening programs and take many other steps to help keep employees healthy and workplaces safe.

In the food and beverage industry, managers face an additional challenge—determining the impact that COVID-19 may have on food safety or HACCP plans.

The hazard analysis and critical control point (HACCP) management system is a tool that many companies in the food and beverage industry use to help maintain the safety of their products. All U.S. food manufacturers regulated by the U.S. Department of Agriculture (USDA) and the Food and Drug Administration (FDA) are required to have proactive rather than reactive food safety plans in place.

When companies with food safety or HACCP plans change the way they operate—as many companies have had to do in response to the COVID-19 pandemic—FDA regulations require that they take stock of how these changes may affect their plans. For example:

Whenever a significant change in a company's operations creates a reasonable potential for a new hazard or significantly increases a previously identified hazard, the company must reanalyze its food safety plan, according to 21 CFR §117.170(b)(1) and 507.50(b)(1).
Whenever there's a change that could affect a company's hazard analysis or change its HACCP plan, the company must reassess the adequacy of its plan, according to 21 CFR §123.8(a)(1).
Whenever there's a process change that could affect the company's hazard analysis or alter its HACCP plan in any way, the company must validate that its HACCP plan is adequate to control food hazards that are reasonably likely to occur, according to 21 CFR §120.11(b).

So how might this look in practice?

Here are some examples of operational changes that could require companies to reevaluate their HACCP and food safety plans:

Changes to ingredient suppliers or ingredients
Changes to the products a company makes
Changes to operations that have an impact on procedures (for example, a change in the number of personnel working at the facility could have an impact on control measures, monitoring or verification procedures)

These examples are drawn from a checklist put together by the FDA and OSHA in August 2020. This checklist offers more guidance on how COVID-19 may affect HACCP and food safety plans in areas including:

Appropriately trained and qualified personnel
Suppliers and incoming ingredients
Current good manufacturing practice (CGMP) requirements, which are the basic sanitation and food safety protections that help ensure food is not contaminated or adulterated

While the FDA/OSHA checklist provides guidance on how to evaluate the effect of COVID-19 on food safety and HACCP plans, it also offers important resources to help companies in the food and beverage industry address one of the critical changes facing all companies today: maintaining employee health and safety. Topics covered include workspace configuration for social distancing, HVAC considerations, face coverings, disinfecting after COVID-19 exposure, employee testing and more.

Download the full FDA/OSHA checklist here: Employee Health and Food Safety Checklist for Human and Animal Food Operations During the COVID-19 Pandemic.

Frequently Asked Questions

Q: Does COVID-19 create food safety challenges for manufacturers and processors in the food and beverage industry?

A: Food products and food packaging are believed to pose a very low risk of COVID-19 transmission, according to the CDC. Coronaviruses such as SARS-CoV-2, the virus that causes COVID-19, spread mainly through the respiratory tract, unlike viruses that cause foodborne illnesses, which spread mainly through the digestive tract. And according to the CDC, there's no evidence that COVID-19 has spread from people working in food production facilities to people handling or consuming their products. However, as manufacturers and suppliers change their operations to help maintain the health of their employees and the safety of their workplaces in response to COVID-19, these changes may introduce new food safety hazards, requiring companies to re-evaluate and possible redesign their food safety and HACCP plans.

Q: What steps can consumers take when handling groceries and packaged food to help prevent the spread of COVID-19?

A: The CDC recommends that people take everyday actions to help prevent the spread of COVID-19, even though the risk of contracting the illness by eating or handling food or food packaging is believed to be low. Most importantly, people should wash their hands for at least 20 seconds with soap and water after shopping or handling food packages—and before preparing or eating food. The CDC recommends that consumers do NOT use bleach, ammonia or other hard-surface disinfectants on food packaged in plastic wrap or cardboard.

The information contained in this article is intended for general information purposes only and is based on information available as of the initial date of publication. No representation is made that the information or references are complete or remain current. This article is not a substitute for review of current applicable government regulations, industry standards, or other standards specific to your business and/or activities and should not be construed as legal advice or opinion. Readers with specific questions should refer to the applicable standards or consult with an attorney.