2nd April Update
COVID-19 RISK ASSESSMENT
Given that many are currently working from home, we need to look at the regular tasks that are completed on site and risk assess which ones can be reduced.
We’ve covered audits and pest control in previous updates:
Internal auditing – we should switch to paper-based desktop system audits
GMP inspections should continue, but we should relax the controls of who can conduct these – as on site personnel may need to inspect their own areas.
Pest control – minimise the number of visits required by external contractors:
- Delay any biologists visits delayed (to be reviewed in least 3 weeks)
- Where your site has monitoring equipment that they can be checked by on-site personnel – they should be checked and recorded in-house, under a risk assessment and following the guidance from the pest contractor
- Where toxic and non toxic chemical pest monitoring points are in place, these must be checked by the pest controller
- The pest controller must complete these checks alone and always keep a 2 meter distance from all personnel
- The suspension or extension of the window for changing of tubes or moth pot pheromones should be discussed with your pest contractor and where this is put in place, this should be under a documented risk assessment and a review date also documented
One of our Techie readers has also said that they are reducing the number of lab tests, by considering which are really essential.
What else you are looking to reduce? It would be good to use this as a forum to share what tasks we are looking to minimise and also the rationale behind the reduction.
Please provide your input to this – it would be great, if together we can compile one risk assessment that we can all use. We’ll be happy to compile it and provide it back out to you, to use.
27th March Update
Hot topic right now! As BRC now need COVID-19 emergency response controls in your incident management system, in order to extend your certificate – you now need to update your system.
Your system will definitely also need updating once this is over, as without a doubt BRC will publish a position statement for additional requirements, given what we’ve learnt from this situation.
This really reiterates why contingency planning is so important. Sure, we can’t have contingency plans for things we can’t forsee – but we can always learn from previous experiences.
It’s a good idea to go back to your system and really challenge it. We’ve written some articles on this, that you will find useful. Although some of them were written specifically for either food, or packaging – the principles (and the requirements) are the same:
- What’s changed in the incident, recall and withdrawal section for issue 6
- Incidents management in Issue 8 – the changes
- Withdrawal and recall procedures
- Emergency situation and business continuity planning
To comply with BRC you now need to ensure that you have the following in place for COVID-19:
- Medical screening
- COVID-19 policy for staff
- Details of contingency plans for resourcing
- Additional cleaning and controls for where low risk cleans cannot be achieved
- Ingredient supply chain plans
- Critical visitor and contractor controls
Given that approx one third of us are working from home, we thought it would be beneficial for us to create a task list of good ideas – of things you can do from home. Although it’s a horrendous situation – every cloud has a silver lining. We never get this sort of time; to be able to sit, concentrate and work on the things we’ve always wished we could. So, let’s make the most of it. As always, it would be great if you could get involved and share any of your own good ideas, that other techies can pick up, to use this time to improve their systems.
Many of you have said their HACCP is at the top of your list of things you want to work on. Most of us have inherited their HACCPs and this is a perfect time to go back to the drawing board (if needed).
Here are a few things that are good to check, when updating at your HACCP:
- Make sure that you have clearly defined definitions for your severity and likelihood risk ratings.
- Check your severity ratings are consistent. Pathogenic contamination for example, should always have the same severity. It’s the likelihood rating that will change. It’s a good idea to do a severity risk assessment for all your hazards first and write an explanation of your rating. That way you can then use this ‘set’ severity rating, consistently – throughout your hazard analysis.
- Check that you’ve listed the PRP for each control, when doing your hazard analysis. Check that you have a procedure for each PRP (it’s a good idea to reference the procedures in your PRP list) and check that the controls you’ve listed being managed by the PRP, are actually covered in that procedure.
- Make sure that your severity and likelihood risk calculation result – actually means something. For example, what is the consequence of a low risk rating result? We only put medium and high risk ratings through to the decision tree for example. Low risk ratings go no further. There’s no point doing the risk assessment, if the result doesn’t have a consequence. This article has more information on this: ‘The purpose of hazard significance in HACCP‘
- If you’re using the old Codex decision tree, this is a good time to switch to the one which includes the PRP question – this article will help you ‘Are you using the old Codex decision tree?‘
We have some great HACCP packs that can help you with updating your systems. Our HACCP packs, include example risk assessments – which cover 95% of all the hazard analysis you’ll need. You just need to piece them together. We know that this saves tons of time and ensures consistency, not just because it’s how we build HACCPs every week – but also because those who have bought the packs, have told us so. You won’t be disappointed.
- You have a risk assessment, which determines the frequency of the audits. Again, the risk result must have a consequence. For example – high risk = a set frequency such as 3 monthly, medium risk could be 6 monthly and low risk could be annual.
- Your risk assessment also needs to take into account the previous audit performance. Our advice would be not to use previous NCNs as your measure for this – as it creates the wrong culture. But instead, assess if that topic has caused any complaints or incidents, as this is an indication as to whether the controls are working.
- Make sure that you are also grading your non-conformances – such as minor, major and critical and that you’re applying root cause analysis to the ones that need it.
- Have a think about who is carrying out the internals audits and check that auditors are not auditing their own work. But, also check that the auditors have enough understanding of the subject they’re auditing too – you really shouldn’t have anyone auditing your HACCP who isn’t HACCP trained, as they won’t be able to pick up the issues with it.
Our best practice internal auditing course, teaches you how to create and manage an internal audit system – as well as how to audit. It also includes training on root cause analysis; when to use it and it teaches you our Smart Analysis method as well. It’s available in eLearning and distance learning.
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