Food processing plants have operated throughout the pandemic, but now that the COVID-19 restrictions are loosening, will things change for them too?
It seems not. On 12 May, Jason Leitch, Scotland's Clinical Director, cautioned that the impending move to level two restrictions was not "a free-for-all"; the FACTS rules should still be followed, and we shouldn't be complacent.
That sentiment echoes the latest Scottish Government Guidance (updated 26 April 2021) which confirms that the controls introduced in food processing plants should not be relaxed or neglected. The Foods Standards Scotland Guidance, which emphasises that physical distancing remains a key control measure, asks food business operators to review, adapt and maintain COVID-19 control measures.
Accordingly, it seems that things will remain the same for food processing plants for some time to come.
We know that, in the past, food processing workers have been at the centre of many large-scale workplace outbreaks and that controlling infection in the workplace is crucial. So what are the key risks and control measures?
Risk factors
There are several factors; food processing buildings tend to be cooler than room temperature and have more moisture in the air - both known to create a fertile environment for the virus. The behaviour of workers is also likely to play a part, they are often involved in physical work which causes heavier breathing or in noisy environments which require shouting or louder speech. Operationally, it might also be difficult to ensure adequate physical distance between workers. Finally, many food process workers live with their colleagues, often in dormitories or work provided accommodation.
Guidance
What then can be done to reduce the risks posed? Food Standards Scotland (FSS) has provided specific guidance for food manufacturing operations during COVID-19. It was most recently updated on 26 April 2021 and can be found here. The Scottish Government also recommends that food business operators consider information and guidance issued by. Health Protection Scotland, the U.K. Government, NHS, Health and Safety Executive (HSE), environmental health and industry bodies.
In the most recent update to its guidance, the Scottish Government guidance highlights the importance of good ventilation; it is an effective way to clear virus particles from an indoor space. A ventilation information card is available here. If ventilation has not already been considered in risk assessments and safe systems of work, a review may be required. However, the guidance is clear that ventilation cannot be used in place of other control measures.
Like much of the advice arising from this outbreak, the FSS guidance focuses on the basic principles of social distancing and hygiene. Contact between staff should be reduced to the lowest level reasonably practicable. Clearly, it is not always possible to operate a business with employees two metres apart from each other. However, where that is not realistic, other mitigations must be put in place. That may be screens or, where there are no other options, PPE including masks, visors and protective clothing. It is also important to introduce and enforce regimes of environmental and personal hygiene. Those regimes involve providing ready access to handwashing facilities and frequent cleaning of hard surfaces and touch points. There should also be careful management of work equipment to avoid sharing where possible and, if not, cleaning in between users. The HSE has been clear, throughout the pandemic, that robust measures are necessary to reduce the risk of transmission. That means that, even if the only option is to slow production, or to make it less efficient, then it should still be done
Communication
But, to be effective, education is key; good training and the provision of clear information and instruction to staff is essential. You are unlikely to gain a benefit from risk reducing measures if staff do not know how to properly implement them. For the same reason, any new ways of working must also be backed up by robust supervision, to ensure the measures put in place are being followed.
Of course, no matter how careful or vigilant an employer is, there is always the risk of transmission of COVID-19 within the workplace. Should that happen, the key to limiting its impact is rapid and robust action.
Again, the importance of communication and instructions to staff cannot be emphasised enough. Employees should understand what symptoms trigger the need for isolation and testing. Those who display symptoms at work should be advised how to leave the workplace safely and be supported in doing so, wearing a mask if possible and travelling home without the use of public transport. They should be directed to obtain a test and to self-isolate for the appropriate period. Thereafter it is for NHS Test and Protect to identify close contacts and instruct them to isolate.
Accommodation
In normal circumstances worker accommodation is not considered part of the workplace. But circumstances at the moment are far from normal and employers should therefore consider whether the accommodation provided allows for adequate social distancing. The guidance states that where possible, only single occupancy accommodation should be used and occupancy of shared spaces should be as low as possible and restricted to specific groups – preferably those who work together. It might also be necessary to provide cleaning services to maintain hygiene and to ensure good access to welfare and handwashing facilities.
Employees living in provided accommodation may also pose problems if and when self-isolation is required. Clear arrangements should be made in advance of this situation arising.
Plan ahead
Even as society begins to open once more, the challenges for food processing plants remain, but by recognising the risks posed by your operation and by taking effective steps to remove or reduce them now, you could avoid, or at the very least, minimise, the risk of outbreaks occurring and mitigate against the disruption in the event that an outbreak does occur.
Contributor
Legal Director
