Pew - A Guide for Conducting a Food Safety Root Cause Analysis

Pew Charitable Trusts published a guide to conduct a root cause analysis.  This type of analysis would be used by a food operation to solve issues that lead to a recall or even a deviation from a CCP/preventive control parameter.  "The guide describes practices for effective RCA that, if used routinely, would help identify lessons learned from food safety failures and ultimately prevent foodborne illnesses. The guide provides approaches and rationales for how stakeholders can prepare for and conduct an RCA, report findings and conclusions, and apply lessons learned to prevent recurrence."

So it is a good reference source for corrective action procedures.

Pew Trusts
https://www.pewtrusts.org/en/research-and-analysis/reports/2020/03/a-guide-for-conducting-a-food-safety-root-cause-analysis
A Guide for Conducting a Food Safety Root Cause Analysis
Approaches for investigating contamination incidents and preventing recurrence
REPORT
March 24, 2020
Topics: Food & Drug Safety & U.S. Policy Projects: Safe Food Read time: 53 min

PA Woman Arrested After Coughing on Grocery Food, Store Disposes of Food

In what has become a national story coming from northeastern PA, a woman was arrested after coughing on exposed food in a grocery store and claiming to be sick with COVID-19.  In response, the store ended up disposing of $35,000 worth of groceries.  She was charged with two felony counts of terroristic threats using a biological agent as well counts of criminal mischief, disorderly conduct, and attempted retail theft.

The Hill
https://thehill.com/homenews/news/489981-woman-accused-of-coughing-on-stores-food-jailed-charged-with-terrorist-threats
Woman accused of coughing on store's food jailed, charged with terroristic threats
BY KAELAN DEESE - 03/28/20 11:30 AM EDT

FDA Warning Letter - HACCP Issues for NY Seafood Processor

FDA issued a Warning Letter to a NY seafood processor for issues associated with HACCP compliance for their operation.   The company had four common issues noted.

1) Temperature monitoring of a cooling step did not take worse-case scenario for product characteristics as well as did not have an adequate frequency.

"FDA recommends when selecting samples to consider the variables that affect the rate of cooling and represent “worst case” conditions. This can include overlapped or closely placed units, the position of the units in the tray and on the (b)(4) where heat may be retained (e.g., the units in the center of the trays in the middle of the (b)(4)), and the distribution of cold air in the cooling room. In addition, your listed frequency, “at least every (b)(4),” is inadequate to show that your critical limit of “…no more than (b)(4) of those (b)(4) is above (b)(4)” is not exceeded."

2) The company was missing monitoring records.

"...firm did not have post cooking process cooling monitoring records documenting times and temperatures of products that were cooled after cooking between January 3 and January 14, 2019. Review of your firm's Cooking CCP monitoring records during this period revealed that your firm was manufacturing and cooking fish products during this time."

3) The company did not have corrective action records for certain process deviations. 

"a review of your Post Cooking Process Cooling monitoring records revealed that at least on one occasion products were not cooled below the listed critical limit......Your firm’s response dated December 4, 2019 stated that a corrective action was performed at the time of the deviation even though a record was not created."

4) The firm did not take appropriate corrective action in response to certain deviations.

"...firm’s “Cooking” critical control point monitoring records identified deviations from your temperature critical limit on multiple production days. However, you determined these deviations were the result of the improper use of (b)(4) temperature recording devices by employees. You firm did not perform or document any corrective actions."

FDA Warning Letter

https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/shung-kee-food-co-ltd-598630-03202020
Shung Kee Food Co., Ltd.
MARCS-CMS 598630 — March 20, 2020

Food Handlers and COVID-19 Guide - Handout

Food Employee Guide for COVID-19 - a poster / handout providing information on COVID-19 for employees.  Can be used as a poster or handout to remind employees about safeguarding against the COVID-19 virus.

Download PDF
https://extension.psu.edu/food-handlers-and-covid-19

COVID-19 - People Shed Virus for Week After Symptoms Disappear

In research presented on the Amercian Thoracic Society website showed that individuals diagnosed as having the COVID-19 virus continued to shed the virus for up to eight days after symptoms disappeared.  It is critical for those who had the virus to be tested per CDC guidelines before resuming normal activities.

The CDC guidance - Discontinuation of In-Home Isolation for Immunocompromised Persons with COVID-19 (Interim Guidance)
Possible Strategy to Discontinue Home Isolation For Immunocompromised Persons with COVID-19 When A Test-Based Strategy is Feasible and Desired:
Maintain home isolation until:

• Resolution of fever without the use of fever-reducing medications and
• Improvement in respiratory symptoms (e.g., cough, shortness of breath) and
• Negative results of an FDA Emergency Use Authorized molecular assay for COVID-19 from at least two consecutive nasopharyngeal swab specimens collected ≥24 hours apart (total of two negative specimens)[1]. See Interim Guidelines for Collecting, Handling, and Testing Clinical Specimens for 2019 Novel Coronavirus (2019-nCoV).

When a test-based strategy is not feasible or desired, healthcare providers and public health officials should follow the non-test-based strategy outlined in the guidance for non-immunocompromised persons.

For Non-Immunocompromised Persons, see Interim Guidance on Discontinuation of Home Isolation for Persons with COVID-19

American Thoracic Society
https://www.thoracic.org/about/newsroom/press-releases/journal/2020/some-covid-19-patients-still-have-coronavirus-after-symptoms-disappear.php
Some COVID-19 Patients Still Have Coronavirus After Symptoms Disappear

FDA on Heat Lethality of COVID-19 Virus

The Consumer Brands Association (formerly GMA) posed question to FDA on heat lethality of CORVID-19.  While there are no specific studies, the virus is expected to be easily destroyed by heat and no special resistance to pH.  Processes used to destroy other organisms should be easily take care of COVID-19, and again, it is a respiratory virus, not foodborne.

“When manufacturing a food or beverage, what is the time/temperature lethality for COVID-19 and is there a specific pH that impacts the survivability of COVID-19 in general and in food?”

In response, FDA FCIC staff said the following: “Currently there is no evidence of food or food packaging being associated with transmission of COVID-19. Unlike foodborne gastrointestinal (GI) viruses like norovirus and hepatitis A that often make people ill through contaminated food, SARS-CoV-2, which causes COVID-19, is a virus that causes respiratory illness. Foodborne exposure to this virus is not known to be a route of transmission. Because of this, there are no specific studies to determine the impact of heat or pH on SARS-CoV-2 in food. However, there is no reason to believe SARS-CoV-2 would have greater resistance to heat or pH than foodborne viruses. Some studies show that coronaviruses (which are enveloped viruses) are less resistant to treatments including heat, alcohol, and others, as compared to foodborne viruses such as hepatitis A virus (HAV). For example, heating at 145°F (63°C) for 4 min has been shown to result in a 4 log reduction of coronaviruses, but the same temperature only inactivates 3 logs of HAV on green onions after 20 hours of heating/dehydration. Following measures intended to inactivate foodborne viruses should work for inactivation of coronaviruses, including SARS-CoV-2. However, to reiterated, foodborne exposure to this virus is not known to be a route of transmission.”

The Role of Asymptomatic and Presymptomatic in Spread of COVID-19

(Updated 4/1/20) In CDC's MMWR articles, they provide evidence in the difficulty for control of COVID-19 with people who are asymptomatic or presymptomatic.  These people do not have symptoms but are infected and can spread the virus.

In a US study, they looked at two nursing homes in Washington state in early March.  

A "facility-wide testing identified a 30.3% prevalence of infection among residents, indicating very rapid spread, despite early adoption of infection prevention and control measures. Approximately half of all residents with positive test results did not have any symptoms at the time of testing, suggesting that transmission from asymptomatic and presymptomatic residents, who were not recognized as having SARS-CoV-2 infection and therefore not isolated, might have contributed to further spread. Similarly, studies have shown that influenza in the elderly, including those living in SNFs, often manifests as few or atypical symptoms, delaying diagnosis and contributing to transmission (6–8). "

Another study in Singapore was posted.  "Investigation of COVID-19 cases in Singapore identified seven clusters (clusters A–G) in which presymptomatic transmission likely occurred. These clusters occurred during January 19–March 12, and involved from two to five patients each (Figure). Ten of the cases within these clusters were attributed to presymptomatic transmission and accounted for 6.4% of the 157 locally acquired cases reported as of March 16."

This enforces the need for social distancing, handwashing, and frequent cleaning, but also tracing personal contact with people who are ill.   As in this case with the nursing home, social distancing can be an issue in addition to having a population that is high at risk.

One interesting note sited in the MMWR report - "Speech and other vocal activities such as singing have been shown to generate air particles, with the rate of emission corresponding to voice loudness (7). News outlets have reported that during a choir practice in Washington on March 10, presymptomatic transmission likely played a role in SARS-CoV-2 transmission to approximately 40 of 60 choir members.*"

CDC MMWR
https://www.cdc.gov/mmwr/volumes/69/wr/mm6913e1.htm
Asymptomatic and Presymptomatic SARS-CoV-2 Infections in Residents of a Long-Term Care Skilled Nursing Facility — King County, Washington, March 2020
Early Release / March 27, 2020 / 69

In the Time of COVID-19, Customer Safety Sells

Food retailers including farmers’ markets are working to comply with new guidance on selling product.  Some have moved to some combination of online ordering, pre-order via phone, pre-packed pickup only, or delivery.   For those that have embraced online ordering with either delivery or pre-packed pickup, they have seen huge increases in sales.  Extension hosted a few local market meetings over the past week, and the anecdotal  evidence suggests that for those operations that have fully adopted and communicated COVID safety measures, business has been good....safety sells.

A butcher in Philadelphia that had focused a good portion of their business on supplying the foodservice channel has moved to a delivery, pre-order pickup model.  With good fortune, they had been experimenting with online and had to rush to get it in place for this pandemic.  They have seen record sales over the past days.  They sold to the regular retail customers but also had a number of new customers.  Another Farmers’ Market in SE PA had also moved to online.  They had pre-order pickup and sales were brisk.

But for many, they will have to work out of the traditional model where shoppers will come to the site to purchase and these operations will adopt the state guidance.  One traditional market reported that sales were down, but regular customers did come out.  They had rudimentary safety systems in place including spacing and hand disinfectant, but they did not seem that they did not communicate their plan well.  One market manager whose market had not opened wondered if it was worth the effort against the risk of getting themselves or their volunteers sick.

This Week in Mislabeled Products for Week Ending March 28, 2020

Wrong Back Label - Winter Gardens Quality Foods, Inc., is voluntary recalling one of its products: Whole Foods Market Vodka Sauce carrying the lot code 20057, because of an undeclared allergen (Milk).   The recall was initiated following a customer complaint regarding the incorrect back label which contained the wrong ingredient and allergen statement.

Sulfites Not Declared - Tiffany Food Corp. of Brooklyn, NY is recalling Huangfushanzen Huang Mountain Tea Mushroom (黄府山珍茶花菇) Dried Mushrooms with UPC 6 943153 804047 and no other coding, because it may contain undeclared sulfites. The recall was initiated after routine sampling by Florida Department of Agriculture and Consumer Services (FDACS) and subsequent analysis revealed the presence of sulfites in Huangfushanzen Huang Mountain Tea Mushroom (黄府山珍茶花菇) Dried Mushrooms which were not declared on the label at a level that could cause a life-threatening reaction in sulfite-sensitive individuals.