Although FDA food facilities inspections are still largely suspended due to the COVID-19 pandemic, FDA has notified states that they can begin to conduct Produce Safety Rule (PSR) inspections on farms, following their state’s, and any federal, safety and reopening guidelines.
As discussed in an IEG Policy article, the inspections will be phased in to begin to enable inspections while still paying attention to the pandemic. Although FDA had not yet publicized the change, the article says the agency had notified the states and cites an FDA spokesperson as stating “if a State develops their own state-specific criteria for conducting inspections of crops that may have limited growing seasons and addresses or considers any CDC or OSHA guidance for those activities, then the FDA has no objections.”
The change is likely also linked to a late May request from the Association of Food and Drug Officials (AFDO) to FDA to allow the resumption of inspections where states had reopened, particularly because of the limited growing season of some produce.
In addition to following general guidelines, the inspections will need to include a focus on social distancing and personal protective equipment (PPE) requirements, so states would have to have PPE for their inspectors as well. So, while states could resume inspections immediately, it is likely that most are still working to develop their plans and for at least the early inspections, farms will be notified so the state can gather information ahead of time, such as ensuring the farm does not have ill employees.
From an FDA perspective, we have heard that they are also in the process of resuming routine inspections based on the level of “phased opening” in different locations. So, based on this it will not be long before FDA is back in food facilities to check up on food safety programs.
What this means to you. For farms, it means that you need to ensure you know what your state is requiring, and you are following all its guidance. You will have notice of an inspection but ensuring you’re on par with COVID-19 requirements as well as food safety requirements is critical to the well-being of your employees – and your business.
For other food establishments, it is a bit of a wake-up call that inspections are restarting in some segments of the food industry, which likely means that FDA is beginning to consider its own reopening and/or at least setting plans in place for when it can. Additionally, the fact that the farm inspections are to include emphasis on COVID-19 employee protections means that FDA food facility Preventive Controls (PC) inspections also could include such a review of these precautions. For at least the near future, you also are likely to be notified in advance, if only to allow FDA to ensure the safety of its inspectors by asking about worker illness, and to ensure it is prepared to follow your visitor requirements.
We’ve long said that business, and life in general, will be different in the “new normal” brought on by the pandemic. The phased-in approach and planning being conducted for the resumption of PSR inspections verifies that projection and gives a look at what we can likely expect as recover continues and life resumes.
Please keep in mind that TAG is available 24/7 if you have food safety concerns and while travel is still a challenge, we have a solid program of virtual technology to undertake remote assessments. Please call us for more details.
In follow up to the TAG Insights article on GFSI COVID-19 Policy and Certification Extensions (May 28), GFSI has announced that it will be presenting solutions for on-site auditing in the coming week. As discussed with the standard owners, for food operators who have proven safety records and have sought and secured extensions, GFSI advocates the use of a food safety risk assessment for sites unable to coordinate an on-site audit and renew their current certification before its expiration date. For sites facing challenges relating to seasonality or continued restrictions, it recommends proactively discussing this situation with key customers and identifying alternative information to provide to demonstrate conformity.
The organization stated that its Board has “discussed these issues at length, and we believe that by proactively engaging with those sites dealing with lapsed certificates through risk assessments, buying companies can maintain supply and maintain responsible relationships with supply partners.”
Additionally, it stated that it “is gearing up for a new world of auditing and introducing the use of ICT (Information and Communications Technologies) to food safety audits,” so has accelerated discussions on the potential to replace some aspects of physical audits with the use and support of ICT in the longer term.
TAG will continue to track GFSI announcements and provide information in this newsletter.