Update Your Food Industry Crisis Management Plans after COVID

As we pass the three-year anniversary of the declaration of a public health emergency brought about by COVID-19, we can identify and incorporate lessons we’ve learned from the pandemic into food safety operations. With the pandemic now mostly in the rear-view mirror, food companies would be well advised to carefully evaluate the overall impact it has had on their operations and use that assessment to determine what changes or programs could be implemented now to protect the company and its brand in the event a similar crisis occurs in the future. As most readers know, the pandemic caused substantial disruptions within the food industry, including many that were significant for both the workforce and the overall global supply chain. Though many food companies had crisis management plans in place prior to the COVID-19 public health emergency, many of these plans did not anticipate or consider an emergency like the pandemic.

Moving forward, food companies should reevaluate their crisis management plans to account for—and incorporate—the important lessons learned from COVID-19.

Crisis Management Plan

Though FDA and USDA’s Food Safety and Inspection Service (FSIS) do not require food companies to have written crisis management programs, many companies have, nevertheless, developed such programs to help them navigate unexpected crisis situations. In addition, third-party audit standards such as SQF and BRC do, in fact, require a crisis management or business continuity program, further increasing the number of food companies that have developed and implemented such programs.

Typically, crisis management plans evaluate all known potential dangers that could impact the company’s ability to produce and deliver safe food, and then identify the methods and responsibilities for responding to the danger if it occurs. Dangers such as power outages, floods, severe weather events, and strikes are often considered in crisis management plans; however, a pandemic event may not have been considered in these programs prior to the COVID public health emergency.

Now that the food industry has experienced a pandemic and seen firsthand the disruptions one can cause, crisis management plans should be updated accordingly. Possible impacts to the company’s operations should be identified by evaluating the specific impact of COVID on operations, and control measures to reduce or eliminate future disruptions should be specified in the program. Control measures to address each possible impact should be specific, actionable, and based upon what the company learned about best practices and the feasibility of its own responses while managing COVID.

Companies that do not have crisis management plans should consider developing and implementing them. Like a recall plan, a crisis management plan allows a company and its leadership to consider how a potential event would impact the company and to determine how the company would respond if the event actually occurred. By engaging in this process long before an event occurs, the company will be better prepared to respond to ensure the event does not create a food safety concern.

Workforce and Training

Food safety regulations require that individuals engaged in food handling, processing, or packing be adequately trained, appropriate to their position, to ensure that food remains safe. In normal operations, food companies conduct initial onboarding training to first ensure new employees are adequately trained and then require regular refresher training.

The COVID-19 pandemic, however, introduced a number of new complexities for companies when considering food safety training. First, companies faced workforce shortages as outbreaks occurred and, in many cases, an increase in new employees or additional temporary employees. Programs and plans to conduct initial onboarding training for each new employee should account for differences in the quantity of new employees, possible lack of experience of new employees, potential turn-over of new employees, and the frequency of start dates.