How to Handle COVID-19 Positive Person in a Food Facility - Industry Guidance Updated 4/2/20

A consortium of food related associations have come together  and developed a guidance document for handling a situation where a worker tests positive for COVID-19.  It is important to understand who has come in close contact with the positive person and then handle those individuals.   Product does not need to be put on hold.

Other guidance documents for the Food and Beverage Issue Alliance include

• Screening Food Industry Employees for COVID-19 Symptoms or Exposure  3/30/2020 Version 1.0 
• Emergency Prevention Measures to Achieve Physical (Social) Distancing in Food Manufacturing Facilities as Related to COVID-19 March 31, 2020  Version 2.11  

https://static1.squarespace.com/static/5e7d1107dac60a6b3e3f098d/t/5e8664c27e5db072ad336918/1585865924826/FBIA+COVID19%2BCase+Recommended+Protocols_2April20+Version+4.pdf
Food Industry Recommended Protocols When Employee/Visitor/Customer Tests Positive for COVID-19 As of April 2 , 2020 (Version 4 )

Contents:

I. Background 

II. Steps To Be Taken When An Employee Tests Positive For COVID-19 Or Has Symptoms Associated With COVID-19 

III. Steps To Be Taken When An Employee/Visitor/Customer Is Exposed (In Close Contact) With An Individual Who Is Positive For COVID-19 

IV. Cleaning and Disinfection Guidelines 

V. Disposition of Food

I. Background

Food production facilities, distributors, retailers and wholesalers are part of our nation’s “critical infrastructure” and must remain operational to feed the country. Inconsistent approaches to reacting to an individual, particularly manufacturing personnel, who test positive for COVID-19, have the potential to jeopardize our food system. This document recommends a consistent approach in how a company can continue operations in the event an individual has tested positive or is potentially exposed, given the global COVID-19 pandemic and high transmissibility of this respiratory virus from person to person. This guidance is not intended to replace or supersede federal, state, or local guidance or authority. It highlights key recommendations from the Centers for Disease Control and Prevention (CDC) and the Occupational Safety and Health Administration (OSHA) on:

Workers Petition PA Fulfillment Center as COVID-19 Cases Increase

An Amazon fulfillment center in Hazlton PA was petitioned by workers after 9 workers in the facility were diagnosed with COVID-19.   The petition aims at a shutdown and deep cleaning.   It is interesting to note that the COVID-19 positive cases in Hazleton spiked to 300 in the last few days, which for a city of 25,000, is very high, roughly 1.2% (as of yesterday, Pennsylvania was about 0.06%).

This where it becomes so important for facilities to manage COVID-19 within the facility.  With a high pressure of positives from the local community, there is increasing risk within the facility of wide-spread infection.

Citizens Voice
https://www.citizensvoice.com/news/workers-say-amazon-must-clean-hazleton-facility-1.2613885
Workers say Amazon must clean Hazleton facility

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