September 22, 2021

Volume XI, Number 265

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FDA and OSHA Publish Employee Health and Food Safety Checklist for Human and Animal Food Operations During COVID-19

  • To help the food industry protect employees and maintain the safety of human and animal food throughout adjustments to operations during the COVID-19 public health emergency, the U.S. Food and Drug Administration (FDA), Centers for Disease Control and Prevention (CDC), and Occupational Safety and Health Administration (OSHA) have developed a number of resources and guidance materials. FDA and OSHA, working together and pulling from that existing guidance, recently developed the “Employee Health and Food Safety Checklist for Human and Animal Food Operations During the COVID-19 Pandemic.”

  • The Checklist addresses considerations for the assessment of FDA-regulated human and animal food operations during the COVID-19 pandemic, especially when reassessing operations due to changes brought about by COVID-19 or restarting operations after a shutdown. The Checklist is divided into two primary sections: employee health, screening, and configuration of operations for social distancing to prevent or minimize the spread of COVID-19 (based on CDC and OSHA guidelines); and food safety requirements (based on existing regulations) to help assess the potential impact of COVID-19-related operational changes on food safety practices (e.g., closures, changes to food safety staff, changes to suppliers and ingredients, etc.).

  • The Checklist may be useful to various FDA-regulated food establishments that grow, harvest, pack, manufacture, process, or hold human and animal food (such as produce, seafood, milk, eggs, grains, game meat, raw materials or ingredients, and resulting food products). The Checklist also provides information for foreign facilities that manufacture, process, pack, or hold food intended for consumption in the United States.

  • While the Checklist does not constitute a standard or regulation, and does not create new legal obligations, it describes recommendations and guidance, referencing existing mandatory safety and health standards. The Checklist is not intended to be an exhaustive list of all measures to protect employee health and food safety, but to serve as a quick reference source to identify areas where additional attention may be warranted.  Operations should continue to refer to guidelines provided by state and local governments, as well as regulations, requirements, and guidance promulgated and provided by FDA, CDC, OSHA, and other relevant agencies.

© 2021 Keller and Heckman LLPNational Law Review, Volume X, Number 234
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About this Author

Keller and Heckman offers global food and drug services to its clients. Our comprehensive and extensive food and drug practice is one of the largest in the world. We promote, protect, and defend products made by the spectrum of industries regulated by the U.S. Food and Drug Administration (FDA), the European Commission and Member States authorities in the European Union (EU) and similar authorities throughout the world. The products we help get to market include foods, pharmaceuticals, medical devices, veterinary products, dietary supplements, and cosmetics. In addition...

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