The Food Safety Authority of Ireland and the Nestlé company have shared how they handled challenges posed by the coronavirus pandemic, including doing official controls and dealing with supply shortages.
During a session at the International Association for Food Protection – Europe event this past week, the presenters covered the experiences of the regulator and food company in managing the assurance of food safety as well as COVID-19 disruption.
Wayne Anderson, director of food science and standards at the Food Safety Authority of Ireland (FSAI), said the agency had to make sure it could ensure the continuity of official controls and protection of consumers’ health.
“Bearing in mind the normal food safety problems of bacteria and contaminants were not going to go away, we prepared a COVID-19 incident response plan outlining the priority services of the FSAI that we would need to keep running in the short term. We didn’t have a policy of remote working in the FSAI until this time. We tested home working with our food incidents team to make sure they could keep the European Rapid Alert System for Food and Feed running and coordinate any response to immediate threats to food safety,” he said.
“We had to ensure our food safety inspectors were designated as essential workers within the legislation passed to lock the country down as we needed to move our staff around the country to maintain official controls on food businesses.
“We had to focus on securing food safety rather than the technical compliance with legislation. So it was important we made sure food was safe even if we had to relax our approach to things like origin labeling. We had to facilitate short term changes in suppliers and substitution of ingredients which were caused by the disruption to supply chains while ensuring that businesses still maintained allergen labeling. The food chain became more vulnerable to food fraud and quality and safety issues as due diligence in suppliers wasn’t possible at the time.”
Disruption to official controls and industry self-checks
COVID-19 also disrupted operations of other state agencies doing official controls on behalf of the FSAI. Most inspections became remote, focusing on documentation, but FSAI maintained physical inspections for complaints or food incidents and where public health was at risk, said Anderson.
“We also suffered quite a few resource issues in the inspection agencies, particularly those under the health authority, because the environmental health officers were redirected into human case tracing for HSE to keep up with COVID and also the laboratories that work for HSE, many of those were redeployed into the clinical testing of COVID and that decreased our ability to take food samples. We are still collating the data on the impact of COVID on our official controls, inspections and testing and I suspect they will be down versus other years,” he said.
“The disruption of official controls coupled with the disruptions to the normal checks and balances within the food business brings extra challenges. Business to business audits were not done and certification audits delayed and after that they were largely remote. All the checks and balances which keep food safe were significantly disrupted and that did raise issues at a time when food businesses were suffering as staff were becoming ill with COVID-19.
“We found it a challenge to ensure businesses kept a focus on food safety measures when they were so busy fighting COVID-19 to keep themselves open as an essential service. There were also issues with closed businesses reopening and wanting advice on stock rotation, sanitation and staff training.”
Anderson said the agency faced challenges such as potential fraud; people operating illegal food businesses and unauthorized health claims.
“Online selling blossomed and we had big problems with restaurants moving to takeaway which they may not have been used to doing and also starting a large business in delivery to home takeaway boxes which people would prepare at home,” he said.
“Even when we found unregistered food businesses our inspections were more complicated as they often required court orders and police presence because they were domestic premises. All these new business models bring with them new safety risks which businesses aren’t familiar with which is why I was surprised the reports of food poisoning had gone down in 2020 versus other years.”
Initial shortage of supplies needed flexibility
John Donaghy from Nestlé said the company’s top two priorities were protecting people and ensuring business continuity.
“We had two big opposing challenges, on one hand we had a large increase in consumer demand, particularly for some types of products because there was panic buying, and on the other hand the opposing pressure was many people were forced to stay at home as they had contracted COVID-19 or were part of a contact tracing program. On top of that, different countries had different approaches with regards to dealing with the pandemic,” he said.
A lack of supplies at the start of the pandemic posed a big problem, said Donaghy.
“We were short in a lot of different commodities that we needed to make our products. This impacted how we designed products, we already had packaging printed and suddenly some of the ingredients in those products were not available. So we had to have this flexibility to change and in a lot of cases the regulatory environment allowed this change but there was no compromise on food safety. You still had to make sure it met the safety requirements with respect to allergens, microbiology or chemical hazards,” he said.
“The fact that there was a shortage of some supplies meant there was an opportunity for an unscrupulous supplier to indulge in some adulteration so we had to reinforce our verification methods to make sure we were not getting fraudulent material.”
Rise of remote tech
Other issues included sourcing food grade containers and onboarding new suppliers at short notice.
“Where you have to use food grade containers for transport of materials suddenly we were finding some of these containers were in a different part of the world than where they were needed so you had to reassess can you use an alternative? How do you ensure they are still safe to transport food? What was in the containers beforehand?” said Donaghy.
“Typically if we go for a new supplier we will audit them and it would be a physical visit and we would do some testing on the materials delivered for the first batches. Suddenly we are having to onboard new suppliers without being able to visit them and this accelerated the use of remote auditing. What you lose in terms of verification in an audit you have to enhance through analytical verification. So we found ourselves having to do more testing on new materials from new suppliers.
“Remote technology came to the fore during the pandemic. Machines don’t know there is a pandemic, they break down and have to be maintained. In auditing, we are seeing a move to hybrid which is partial remote and part physical and that is the nature of audits we have to do internally and with our suppliers.”
Donaghy also spoke about cleaning and sanitation with shortages of hand sanitizers and people trying to sell products to kill COVID. Another issue was supply disruption with laboratory consumables, PCR reagents and gloves that were being directed to clinical labs.
Handling change and country issues
Donaghy said in one factory 300 people were taken on in four months to meet manufacturing capacity.
“How do you train them in a short space of time in the middle of a pandemic? We appointed a COVID champion in factories as the interface between the factory personnel and the local public health people. As vulnerable workers had to stay at home, in some cases 50 percent of our quality team were not being allowed to come to work,” he said.
“Sometimes we had to adjust our environmental monitoring programs, in some cases we had longer production runs to cope with the demand for food. Spaces between cleaning and start-up of production were different so that impacted how we cleaned, how we did our environmental monitoring and analytical verification. Shortages of chemicals for cleaning meant switching to an alternative and revalidating your cleaning process and that new chemical may have residues that have an MRL in some jurisdictions and then you have to test for residues.
“We have not introduced environment monitoring for COVID-19 in our processing factories unless we have a specific demand by a government or supplier as I don’t believe it brings a great deal of benefit given all the preventative measures we have in place and the uncertainties around the result you would obtain and what you would do.”
The out-of-home part of the food chain almost disappeared as people were not eating out in restaurants. Nestlé noted about a 50 percent increase in sales through e-commerce.
“That meant we had to switch product portfolios and production from a factory to another to cope with this new demand. We had a confectionery factory in one country where the government said it was non-essential so it has to close. Yet in other countries we were short of resources as we couldn’t produce enough food to meet the demand in retail,” said Donaghy.
“In some countries we had restricted movements of goods. In India, our testing lab was in a different location than our manufacturing footprint and we couldn’t take the samples from our environmental monitoring or finished product testing to the lab despite the fact both were in India and this normally happened so we had to find other labs that could do our testing.
“In February, China said there could be a risk to their personnel of handling goods coming from any country that could have a high risk of COVID so overnight I had to advise all our factories exporting to China that we must disinfect the inside of containers and the outer packaging of goods going to China. We had to be able to issue disinfection certificates for the Chinese import authorities.”
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