3. FDA, USDA & COVID-19

Recorded March 30, 2020

3. FDA, USDA & COVID-19

46 Minute Webinar

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Webinar Notes

Below is a summary and links to the various resources mentioned during the webinar.

USDA and FDA Updates
  • USDA/FSIS and FDA Temporary Labeling Allowances
    • Labeling Flexibilities for products intended for food service but being diverted to retail
      • USDA allowances are for 60 days starting March 23, 2020
      • FDA allowances are in effect for the duration of the public health emergency related to COVID-19 including any renewals
  • General Provisions
    • Exempts USDA and FDA foodservice products switched to retail channels from certain labeling provisions
      • No Claims may be made when claiming nutrition exemptions
      • Labeling must include all other required elements
  • USDA/FSIS Application
    • Foods already manufactured for Hotels, Restaurants or similar Institutions (HRI) can be rechanneled
    • Bulk foods may be distributed to retail and the retailer will repackage into smaller consumer size packages
    • Labeled containers of foods in unlabeled protective coverings may have the separate units labeled at retail
  • FDA Application
    • Restaurants may sell excess of packaged ingredients
    • Foods already manufactured for HRIs can be rechanneled
    • To facilitate distribution of food, continued manufacturing of restaurant foods to be redirected to retailers is acceptable until retail packaging can be developed
  • Other Allowances
    • State government provisions for restaurants to sell excess foods directly to consumers
    • FDA extended their use of enforcement discretion for the nutrition facts and serving size changes through the end of the year
FDA Updates – Food Safety

Access all relevant information through their main site.

Update Your Plans
Download the COVID-19 Site Self-Assessment
  • Review company policies for management of illness in the workforce
  • Refresh all onsite employees on the following policies
  • Assessment of all operational areas for adequate handwash stations, supplies, sanitizer stations
  • Communications for what employees should do if sick
  • Conduct a traffic mapping of employees working inside the plant to identify all contact / touch surfaces

Download Now

Four Key Questions When Increasing Production

During the webinar, Earl Arnold, Manager, Food Defense/FSMA Operations, Quality Assurance, discussed a number of regulatory updates and recommendations to ensure food safety and worker health. One of the practical scenarios he reviewed involved key considerations when increasing production. Specifically, is your facility having longer production runs, but with fewer SKUs? Here are four key questions to ask of your team.

1. What about the ingredients we’re not using?

If you’re increasing production of standard product, but some specialized ingredients won’t be in production for a while and are in storage, they may be susceptible to pests. Per the FDA’s Current GMPs, Sec. 117.80 Processes and controls, section b, 1-4: “Raw materials and other ingredients must be inspected and segregated or otherwise handled as necessary to ascertain that they are clean and suitable for processing into food and must be stored under conditions that will protect against allergen cross-contact and against contamination and minimize deterioration… Raw materials, other ingredients, and rework susceptible to contamination with pests, undesirable microorganisms, or extraneous material must comply with applicable FDA regulations for natural or unavoidable defects if a manufacturer wishes to use the materials in manufacturing food.”

By adding those ingredients to an inspection schedule approximately every four weeks, you will take into account the lifecycle of most insects and limit the potential for an insect infestation in your facility.

2. Do we need changes to our cleaning, sanitation and inspection schedule?

While these activities may each be verified during your normal production schedule, increased production may prompt risks you haven’t considered. You should re-verify your production run to determine if any new risks are present.

Next, discuss your new run schedule with your chemical supplier. They may recommend different products that can assist with these changes and help reduce your risk of cross-contamination or cross-contact issues.

Further, review your cleaning procedures to determine if changes are necessary. This could include additional deep cleaning during shutdowns.

And finally, when you do make changes, train and educate everybody involved to make sure they are aware and understand what changes you’ve made and why. Additional inspections may also be necessary, providing assurance that you’re maintaining the production of safe food.

3. What is the impact of longer runs on traceability?

If production times are increased, more frequent lot changes of staple ingredients may be necessary. Consider reviewing this process and discussing it with employees, reminding them that changes in lots may be more frequent. You should also consider more frequent supervisor checks to ensure that these lot changes are being recorded.

4. Are our preventive maintenance schedules being interrupted?

Review upcoming production runs with your maintenance team. If changes to your schedule are warranted, develop a temporary maintenance schedule and document the need for that change in the schedule.

You will also want to make sure this schedule coincides with your sanitation activities, minimizing downtime.

Questions? Contact Us

As you have questions or need additional insights, please contact us at info@aibinternational.com.

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