Coronavirus: How can food businesses safely reopen during and post pandemic?

15th May 2020

Following the Government’s announcement on Sunday 10 May 2020 highlighting the change in strategy from ‘Stay at home’ to ‘Stay alert’, most Food Business Operators (“FBOs”) will be looking to consider how and in what way they can reopen for business.

Coronavirus has placed an enormous strain on the food and hospitality sector and whilst businesses will understandably wish to reopen as soon as possible, the health, safety and welfare of employees and the public should always remain a priority. 

We have prepared a non-exhaustive list of considerations for food businesses assessing their reopening process. In addition, we have set out some more specific considerations which are particularly relevant to certain types of business. Please note, these considerations should be read together with current UK guidance, accessible here.

General considerations

Risk assessments – A comprehensive risk assessment should be undertaken to evaluate all risks posed by reopening. The risk assessment should detail whether it is possible to manage those risks and if so, the steps that will be taken. 

Review of Food Safety Management System – In particular, FBOs should keep under review and update as required, their Food Safety Management System. It is highly likely that as part of this process your staff will require additional training, particularly if you are asking them to undertake new tasks.

Cleaning - Prior to reopening, FBOs should conduct a thorough deep clean. This should include all areas used by staff, for example, canteens and locker rooms. Once reopened, regular cleaning should remain a priority, with a particular focus on high-touch surfaces. Cleaning should be in accordance with food hygiene practice and the environmental controls set out in the business’ Food Safety Management System.

Fire safety - Fire safety issues should be considered and risk assessments should be updated accordingly. Considerations may include: changes in staff numbers, testing of fire equipment and managing evacuation routes in accordance with social distancing guidelines.

Equipment and maintenance checks – Prior to turning on machinery, it is imperative that businesses conduct all necessary checks. Ensure that all statutory testing has been conducted in accordance with relevant legislation and updated government / HSE guidance.

Legionella – To avoid the risk of contracting legionnaires’ disease, ensure that all taps are run prior to use in accordance with relevant guidance. See, for example, guidance from the European Society for Clinical Microbiology and Infectious Disease. For further information on this topic, please see this article prepared by our colleague, Sarah Valentine.

Employees – Contact staff prior to their return to establish whether they, or anyone in their household, has tested positive for coronavirus or experienced symptoms. Ensure self-isolation guidelines are followed in this respect. Establish an action plan if a staff member becomes ill at work and ensure that staff training and briefings are provided regularly. 

Canteen areas – Ensure canteens are regularly cleaned and limit the number of individuals congregating at break times, for example, by removing chairs, staggering lunch breaks and offering other large areas for staff to spread out.

Smoking areas – If possible, extend the smoking area and introduce additional signage / floor markings to encourage social distancing.

Food packaging – Government guidance states that food packaging is not known to present specific risks, but efforts should be made to clean and handle packaging in line with usual food safety practices.

Cleanliness – Ensure that staff regularly and thoroughly wash their hands and if possible, install non-touch hand sanitiser dispensers. Decrease high-touch areas, for example, by leaving doors open (except fire doors).

Pest control – Conduct thorough checks in accordance with pest control procedures prior to reopening, to ensure that there are no infestations.

PPE – The two key messages from the government guidelines is frequent handwashing and social distancing. Whilst facemasks might make employees feel more secure they should only be a complimentary measure and should not be used instead of the other two. Where facemasks are to be provided, please ensure your employees have been appropriately trained on how to don and doff correctly and that they understand hygiene requirements during its use i.e. not to adjust the facemask or touch their face whilst wearing.

In an open letter from the HSE dated 21 April, food businesses have been urged to only provide face masks to those workers who need it due to the current lack of availability. The letter recognises that because of a shortage in the current crisis, some workers may have to use less effective equipment than normal.  This includes masks used to protect against the inhalation of flour dust, where workers usually have to use masks with a so called “assigned protection factor” (APF) of at least 20. The letter states that employers should, in such cases, look to use masks with an APF of 10, where usual masks are not available, which could be made safe enough to use alongside the implementation of other measures.  Whilst this letter is specific to the risks associated with flour inhalation, the principles can be equally applied to all food operations.

More specific considerations

Takeaways

A number of restaurants have begun to operate a takeaway function following the relaxation of rules in March 2020. Whilst this is a lifeline for many businesses, it poses a number of food safety challenges. When considering whether to offer a takeaway option the following issues should be considered:

1.    Allergen management

Given the likelihood of staff redeployment, ensure that all staff are aware and have been trained in allergen / cross-contamination processes.

Supply chain disruption may have resulted in the substitution of goods. FBOs should review all substituted goods and ensure that staff members are informed of these changes and that all information provided to the consumer is correct and up-to-date. FBOs should also be aware that due to PPE shortages, hypoallergenic gloves may have been substituted with latex gloves, which pose a risk for some consumers. 

FBOs should ensure that there is an effective process in place which allows members of staff to obtain and communicate allergen information from / to the consumer. Any information received from the customer should also be relayed to kitchen staff.  

Social distancing reduces effective allergen dialogue, which is imperative for allergen management. Consider how best to reduce the risks posed by this, for example, through utilising the comment section on online ordering platforms.

Please note you must provide allergen information:

before the purchase of the food is completed. This can be in writing on a website or menu, or orally by phone.

when the food is delivered. This can be in writing (allergen stickers on food or an enclosed hard copy of a menu) or orally (by the delivery driver).

1.    Social distancing

Serve a limited menu to help small kitchen teams maintain social distancing.

Look at employee rotas – can you consider asking employees to work back to back to reduce the risk of transmission?

Can you use see through barriers to protect staff on tills and only accept contactless payment or try to ensure that all payments are taken over the phone.

Assign staff to the same shift patterns and avoid swapping team members.

At the point of ordering a takeaway, you should put in place a process to establish whether the customer is self-isolating or ill. Communicate this to delivery drivers so a safe method of delivery can be undertaken.

Consideration should be given to whether food can be left on the customers doorstep and how you will notify customers that food has been delivered to ensure that it is received.

Kitchen staff should not come into contact with any delivery staff and there should be a designated “safe zone” for food to be collected from / away the main preparation areas.

Stagger collection times to discourage crowding outside premises

2.    Hygiene

Drivers should wash their hands on arrival for pick-ups and when returning after deliveries.

Consideration as to whether drivers can be given hand sanitiser to keep in their car to ensure they can sanitise their hands immediately prior to and after a delivery.

Consideration should be given to how food can be protected from contamination – vehicles and bags used to store and transport food will need to be regularly cleaned and disinfected.

Correct food temperatures will also need to be observed when food is being transported. Hot food needs to be kept hot by using insulated bags or boxes and refrigerated food must be kept cool with the use of cool bags or coolant gels.

Food manufacturers / factories

Many of the issues discussed above are also applicable within a factory environment. However, there are some unique considerations which must also be taken into account:

 Maintenance checks – Maintenance checks will be particularly important in the factory environment. Before production commences ensure that all maintenance checks are carried out in line with the manufacturer’s recommendations.

Equipment – Ensure that all pieces of equipment have been calibrated and are running accordingly such as: fridges; freezers; temperature probes and scales.

Social distancing – Use floor marking to manage social distancing. If possible, make corridors a one-way system. If possible, create a one way system around the factory floor and ask members of staff to stand 2m apart on the food production line and in logistics. Where employees have to work face to face, try to ensure that they work side by side rather than face to face if possible. Finally, members of staff should follow the social distancing guidelines even when entering and leaving the work premises, this includes in the car park.

Visitors – Reduce the number of visitors entering sites. If this is not possible, restrict the areas they can visit.

Deliveries – Take reasonable steps to safeguard delivery drivers, in accordance with social distancing and updated health, safety and welfare rules.

Allergen free site – If you are no longer providing a canteen arrangement for employee breaks then please provide fridges and inform staff that they must bring in their own food. However, ensure that if you are an allergen free site that all employees are reminded of this and asked not to bring certain allergens on site.

Audits – note that there may be a delay in the current auditing regime. Certification bodies will also be following government guidance and not travelling to sites. Ensure you speak with your auditor as soon as possible to understand the options available to you i.e. you may be able to agree an extension with the certification body for any certificates about to expire, you may be able to agree an extension to the usual audit regime or the audit may be able to take place remotely via video link.

Whilst it is important that changes are made to manage the risks posed by coronavirus, it is equally important that these changes are monitored to ensure business-wide compliance and effectiveness.

The above is a brief guide on some of the issues FBOs may be facing when looking to reopen. If you require further detail on the guidance detailed above or any advice regarding your reopening process, please contact our food safety lawyers, Laura Shirley, Natascha Gaut and Prem Thakor

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