Facility managers – not just food facility managers – are being “encouraged” to take strong preventative measures to help mitigate the risks of COVID-19 for individuals within their premises. Managers are also reminded that the actions taken need to be documented. It is recognized that certain of the recommended measures made by the Center for Disease Control (CDC) and/or the Occupational Safety and Health Administration (OSHA) may not be possible in some operations. The documentation made should acknowledge this and outline the preventative measures that are in place instead.
For example, where CDC guidance for physical distancing is 6 feet, but this cannot easily be accommodated, it may be possible to:
- adjust on-site inspection practices and frequencies,
- increase the distance between employees and location staff, or
- adjust traffic patterns through the premises to avoid “people-congested” areas.
Operators are encouraged to have plans that respond to both suspected and confirmed cases of COVID-19. They are also encouraged to consult with local public health authorities for applicable guidance as well.
Mitigation and Response
Facilities need to have documented procedures in place that describe the measures being taken to prevent or minimize the occurrence or exposure to COVID-19.
- Sanitation procedures – a facility’s normal procedure and what goes into place when someone in the facility tests positive for COVID-19.
- How is physical distancing addressed in the facility?
- Are there any self/company/health assessment protocols/practices and a description of screening methods in place?
- What is the policy for facility personnel to report their, or their colleagues, illnesses? This should include documentation on how notification to the facility was made if not by the employee notifying the facility – if it occurred through local authorities such as the health department – to the facility of any COVID-19 finding(s).
- Describing the specific response/action plans that will be implemented at the facility when there is a finding of a COVID-19 positive employee.
Remember, the key is to have documented procedures following the CDC guidelines, document that the procedures are followed, then document how the procedures are followed. OFW Law is happy to provide assistance in developing procedures to be sure that a facility is addressing all required parameters as to sanitation procedures as well as proper documentation.