The WHO and FAO interim guidelines on COVID-19 and food safety are flawed, according to one expert who is hoping a planned update will solve the problem.

Roger Cook said the Food and Agriculture Organization (FAO) and World Health Organization (WHO) interim guidance published in April 2020 suggested COVID-19 was a food safety issue.

“That guidance as it’s written now is blatantly and simply wrong, it’s misleading, we told them so last year, the UK, US, EU, Australia, Canada and ICMSF have all told them the same but they’re only now looking at an update. It will be interesting to see what that says and how far it goes,” he told attendees at the 18th annual UK Association for Food Protection (UKAFP) conference.

“It’s our conclusion, and we agree with the ICMSF and most other regulatory risk assessment groups, that there is no direct food safety risk from food or food packaging. Since the WHO investigators have been to China, they have been suggesting that is the case as well. There doesn’t seem to be a risk but that’s not what the guidance says.”

The event was held virtually this past week with “Global Food Safety in a COVID Era” as the theme.

“There is no definitive evidence that SARS-COV 2 virus can be transmitted on food or its packaging. There has not been one case reported anywhere that definitively links the consumption of food or contact with packaging to a human case,” said the president of the International Association for Food Protection (IAFP).

“You might argue that it’s hard to see them, especially in countries where person-to-person spread in the community is rampant. But what about in New Zealand where the virus has virtually been eliminated from the community? If it’s transmitted by food or packaging, and we import a lot of food into New Zealand from countries were COVID-19 in the community is rampant, then we would expect to see cases and clusters randomly turning up in the community but we don’t.”

Trade problems
Cook, who is manager of food science and risk assessment at New Zealand Food Safety, part of the Ministry for Primary Industries (MPI), said some trading partners have taken the interim guidelines literally and say it is a food safety problem and frozen and chilled food is the issue.

“That is non-peer reviewed science, poor epidemiology, poor risk assessment and unfortunately those trade barriers are escalating. Despite being COVID free, having risk proportionate controls and no community cases we are still being told we can’t export to these countries and we are getting this from the importers, who are getting it from the ports, unless our exporters test their workers for COVID and that puts a huge strain on our testing capabilities,” he said.

“They want the product and packaging tested, they want to disinfect the packages and to implement cleaning programs that are stronger than any we would put in place for Listeria, which is a far trickier organism to control.”

Cook said this is being demanded because the interim guidelines doesn’t specify any difference in risk level.

“It’s just one size fits all and I’m sorry but one size doesn’t fit all. We need a risk-based, escalating, region based regulation of procedures and that’s what we’ve put in place. We’re hoping the new updated FAO/WHO guidelines may state that and then we’re hoping trading partners will reverse what they’ve been doing and trade in food will continue and the price won’t go up to cover what are inappropriate mitigation strategies. Trade is being disrupted and we may see more disruption over the next six months until the FAO/WHO guidelines are made to represent a proper risk and regionalization basis,” he said.

Regulator’s view on trust
Rebecca Sudworth, director of policy at the Food Standards Agency (FSA), also presented at the event.

Sudworth said trust in the FSA is high and has risen over the years but younger age groups and people from non-white backgrounds tend to have a lower level of trust in the agency.

“The COVID-19 pandemic has highlighted just how important it is that people trust the information they receive. Trusted information will be acted on. But the sources people trust are not always reliable,” she said.

“The experience of the COVID-19 pandemic has shone a spotlight on the potential consequences when some people trust public health advice less than others. This is a wake-up call to all regulators, we must treasure trust we hold were it is high and build trust were we can do better. It is important in risk communication to be clear about what we don’t know so what is the level of certainty or uncertainty we have in relation to the available evidence.”

Rebecca Sudworth, speaking at the event

Having a trusted food safety regulator is an important foundation for trade deals, said Sudworth.

“So if our trading partners and consumers in other countries trust our food is safe and produced to high standards then this will promote international trade. Regulation provides the level playing field for industry and it means consumers can have trust in what they eat. The economic role of a regular is often overlooked. Regulators are not just about telling people what they can’t do. They are at the heart of building consumer and business confidence.”

Sudworth also acknowledged the pressure on local authorities to use their scarce resources in the most effective way.

“This has included changing guidance so they can concentrate on the most important interventions. For lower risk businesses, if they have a Food Hygiene Rating Scheme (FHRS) score of 3 or higher, we’ve advised some planned interventions could be deferred. Some businesses have been waiting longer for their FHRS rating – whether it’s a new rating or re-inspection. We’ve advised local authorities where appropriate to prioritize new ratings. After a sharp drop in March when lockdown started we have now seen numbers of new ratings increase steadily but not yet back to pre-pandemic levels,” she said.

“The food industry asked for more flexibility in applying certain labeling regulations so some products could be repurposed to maintain supply and reduce food waste. As retail demand surged products designed for catering and hospitality remained unsold as businesses had to suspend trading and the supply chain was disrupted. The FSA agreed some temporary flexibilities but we also laid out some red lines to protect consumers.”

Online food sales
Home delivery was already a growing trend before COVID-19 but now it has come to fore, said Sudworth.

“Food eaten outside the home is also a growing category. There is a trend away from people preparing fresh cooked meals themselves and a move towards people having food prepared by somebody else. Which is quite an important shift,” she said.

“On ghost and dark kitchens – if there is a business that is unregulated and operating under the radar that is unacceptable and something we want to stamp out. But the idea of these new facilities to serve the delivery market, they are regulated depending on the arrangement. This is where as regulators we need to keep in touch with new developments to know how we regulate environments like that. It is an opportunity to get information about pop-up businesses to pass that along to local authorities and enforcement agencies.

“The rate of change on these new styles of business is different depending on the location. In urban centers there can be a bigger growth and they can be in places where you would not normally expect to find a food business. We have been scanning the publicly available information, like looking on delivery platforms to see who is listed there and checking that against the businesses that are registered. We’ve found in general we do know about most things and people want to do right thing and are engaging with local authorities to go through the right processes.”

Sudworth added it was too soon to tell if a decline in lab confirmed infections reflects an actual fall or if the reporting or testing dropped. The FSA is trying to understand more but it will take months or years to gauge the pandemic’s impact.

How OSI handled the pandemic
Other presenters included professor Ben Chapman, professor Kali Kniel, professor Donald Schaffner, and Danièle Sohier from Thermo Fisher Scientific.

Sharon Birkett, director of quality and regulatory affairs at OSI Group, ran people through how the firm handled the pandemic. This included controls at all sites and staggered shifts with 30 minutes gaps to ensure the first shift left before the second arrived on the floor.

“We had employees enter on a single file pattern to collect their temperature. We were trying to avoid them congregating in around areas like the time clock, hygiene stations, or in the canteen. We reduced the number of people allowed in the changing room at one time and put in place a lot of visible markers to help them understand better social distancing and what was important,” she said.

“In places where we couldn’t keep social distancing we put in physical barriers or provided eye protection in the form of goggles or a face shield. In the operating space we put barriers in place because in many places they were in close and constant contact for eight hours.”

No OSI site was closed by local authorities due to COVID clusters but the company did shut three plants in the US for this reason.

“During the initial lockdowns in Europe, OSI had more than 1,000 metric tons of product in the market, either in restaurants, in distribution or in storage and this was worth more than €5 million. Most of the product was frozen and had a shelf life of between 90 and 120 days. We had so much product on the market we had no need to continue to produce so we suspended operations in eight plants in the EU because of the level of inventory, most restarted in May 2020,” said Birkett

“We didn’t want to waste food so we did agree with our customers to extend the best before shelf life for most products in the market. We agreed with local authorities and that customer on how to visualize the new longer shelf life. We didn’t want to move it back to our sites and repackage it just so it would have a new longer shelf life. In the end, 90 percent of our products received new longer shelf lives.

“When we restarted operations in May for those plants that were closed, typically these machines run hard every day and now they’ve stopped for three months, so we went back through and started our lines up slowly and we had to retrain our employees on how to use the PPE.

“All of our food service products sold frozen received new best before dates and we did not waste food. Dates were extended by 15 to 60 days. Our refrigerated products moved through the market as there was a high demand for retail. All the extensions on the best before dates were validated based on data we already had at the sites.”

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