Background

The ongoing COVID-19 pandemic presents an exceptional and unprecedented challenge for competent authoritiesa with responsibilities for national food safety control systems b to continue conducting routine functions and activities in accordance with national regulations and international recommendations. In many countries, competent authority staff are largely working from home, teleworking being the normal practice, and all face-to-face meetings cancelled or rescheduled as teleconferences. It is challenging to maintain, without interruption, routine activities such as the inspection of food business operations, certifying exports, control of imported foods, monitoring and surveillance of the safety of the food supply chain, sampling and analysis of food, managing food incidents, providing advice on food safety and food regulations for the food industry, and communicating on food safety issues with the public. To preserve the integrity of the national food safety control system and to support international trade and the food supply chain, each competent authority will need to prioritize critically important services during the ongoing COVID-19 pandemic. These may include introducing temporary suspensions of low-risk control activities that do not immediately affect the supply of safe food. Temporarily suspending low-risk control activities will allow authorities to continue to safeguard the health and safety of their staff while refocusing efforts in areas of higher risk and towards activities that are critical to the safety of food. Depending on national priorities, some competent authorities may decide to prioritize selected activities, for example, inspection of highrisk food businesses, export certification, import control services, food incident management or investigation of food complaints. It is important that competent authorities continue to monitor developments regarding the COVID-19 pandemic and respond by making the necessary adjustments to their work programmes and continue to deliver critical services that preserve the integrity of their food safety systems.

The challenges facing national competent authorities arise from:

• implementing contingency plans;
• reduced capacity to maintain a fully functioning food safety inspection programme resulting from the reallocation of staff to national COVID-19 emergency response teams, staff working from home, and staff illness and self-isolation;
• reduced food testing capacity of food laboratories reassigned to COVID-19 clinical testing;
• increased risk to the integrity of the food supply chain from food fraud;
• need to respond to an increasing number of queries and questions from Ministers, the food industry, consumers, and the media. Competent authorities have a critical role to play during this pandemic in working with all sectors of the food industry so that producers and processors can continue to operate effectively and keep safe food supply lines open.

This guidance aims to address some key issues, namely, how to ensure the effectiveness of a reduced food safety inspection programme in mitigation of risk; and temporary measures that can be introduced to contain widespread food safety risks and reduce serious disruption to national food safety programmes. 


Multi-agency cooperation and contingency planning

All competent authorities should have emergency response or contingency plans in place following FAO/WHO guidance1 and be able to put them in action. Competent authority contingency plans should include details of the roles and responsibilities of the central, regional, and local competent authorities and mechanisms for cooperation and collaboration during times of crisis. Contingency plans should include details of how to prioritize the delivery of essential services; the organisation of operational teams for information management, communication, risk assessment and risk management, and food incident management; the scaling up of robust IT systems to facilitate working from home, teleworking, and on-line conferencing. Cooperation and collaboration between all relevant national agencies are essential components of an effective, whole-ofgovernment response to the COVID-19 pandemic. The need for cooperation between public health and food safety authorities has never been more urgent.


Maintaining a functioning national food safety inspection programme

As a consequence of restricting the movement of people, the capacity of competent authorities to deploy suitable staff for inspecting food businesses and other food control activities can be seriously impaired. For example, food safety inspection requiring the physical presence of control staff in food premises may no longer be feasible. It may no longer be possible to test food samples taken during an inspection because of reduced capacity in food testing laboratories. The key issue for competent authorities is to ensure compliance with food legislation in those categories of food premises that pose the greatest risk. Many food businesses are introducing new biosecurity measures to limit the entry of external personnel, which may extend to food inspectors. However, food safety inspectors have a right to enter unhindered any premises where they have reasonable grounds to believe that food processing activities are conducted, for the purpose of verifying compliance and preventing non-compliance with food regulations. 

A risk-based approach

National food safety inspection programmes should be organised on a risk basis where food businesses are ranked to determine the frequency of inspection. A risk profile of each food business for inspection purposes should be based on the nature and extent of the food business, taking into account the type of food handled, processed and distributed; the methods of processing (cooked food, ready-to-eat products); scale of the operation, and possible at-risk groups among consumers of the products. Issues to take into account in deciding on risk categorisation of food businesses include the history of compliance or non-compliance with food legislation, confidence in the implementation of the food businesses’ Food Safety Management System (FSMS), and verification records. This risk-based food safety inspection approach can identify those high-risk food premises that require inspection. It may be necessary to temporarily suspend inspections of low- to medium-risk food premises for the duration of this pandemic.

One of the critical areas where food inspections will need to continue is in abattoirs including oversight of ante- and postmortem controls. Food inspectors in such premises will require Personal Protection Equipment (PPE) and will need to be aware of the importance of physical distancing, handwashing, sanitizing, and disinfection especially if production conditions change for example due to increased production line speeds.

Another critical group of businesses where inspection may need to be strengthened are those where production relies heavily on imported ingredients. With international transport often dramatically reduced, these businesses may have delayed or interrupted supply chains that may pose food safety concerns and could demand increased inspection and controls. Similarly, new suppliers may need to be rapidly identified by food businesses without going through the full supplier approval programme, which may put the integrity of products at risk.

Some food businesses will expand production as a result of increased demand and will recruit temporary staff. Food safety authorities will need to ensure that temporary staff are supervised and adequately trained.

Temporary measures

Examples of food safety controls where temporary measures may need to be introduced under exceptional circumstances include:  

• temporary use of electronic data exchange instead of original official paper certificates and official attestations that should accompany consignments of food producing animals;
• temporary authorization of accredited private food laboratories to conduct testing and analysis under the supervision of the competent authority;
• the electronic submission by food businesses of the results of their own checks to demonstrate that inhouse controls are still functioning (selfcertification);
• if food safety authorities do not have access to a sufficient number of suitably qualified and experienced staff, private sector bodies and independent qualified professionals may be temporarily authorized to perform food inspection functions provided that they are supervised by the authority, they act impartially and are free from any conflict of interest regarding the functions they carry out; and
• flexibility on some aspects of food labelling (e.g., date marking) to avoid food waste while still ensuring food safety

Staff protection

Where inspections of food businesses need to continue, measures should be taken to avoid serious health risks for staff of the competent authorities without jeopardizing the prevention of food safety risks. Food inspectors should be trained in procedures to minimize the transmission of SARSCoV-2 (the virus that causes COVID-19 disease).3 Food inspectors will need to ensure that they are free of symptoms of COVID-19; they will need to practice physical distancing while in the food premises, frequent hand washing, including before and after entering the food premises, and good coughing/sneezing etiquette. Food inspectors will also require PPE such as disposable overalls, overshoes, facemasks, gloves, and hairnets, which will need to be changed between inspections.

Temporary suspension of control programmes

Some monitoring and surveillance programmes that are routinely carried out by competent authorities could be temporarily suspended during this pandemic without jeopardizing the safety of foods, the health of the consumer, or international trade. Examples of such activities are annual residues monitoring programmes that aim to ensure compliance with contaminants regulations. There will be a reduced need for testing of food samples arising from the fact that a smaller number of food inspections will take place, with the closure of many bars, cafes and restaurants. In countries with hygiene rating schemes or “scores on doors” programmes for restaurants, these may be automatically extended for limited periods without the need to carry out an inspection.

Reduced sampling and testing of food will make it all the more important for national competent authorities to have access to and share information via global systems such as the International Food Safety Authorities Network (INFOSAN). 5 Food businesses should be obliged to report to competent authorities when they are aware of receiving or placing unsafe food on the market.

Food regulations – temporary exemptions may be required

Competent authorities need to liaise closely with the food businesses to assess whether temporary amendments or adjustments are required to food legislation due to the challenges posed by COVID-19 to ensure the supply of food is not compromised. Competent authorities will need to assess whether flexibility can be applied when enforcing technical aspects of food regulations, while ensuring the safety of food. 

Food labelling is one particularly challenging area where certain ingredients may be unavailable or where food packaging materials are no longer supplied due to interruptions in transport or imports. Where a food business uses an approved ingredient that has the same technical function as a previously available ingredient, a temporary authorization may be justified provided that safety concerns, such as allergen labelling and traceability requirements are taken into account. There can be no relaxation of regulations on unauthorized health claims and the principle that food labelling should not mislead the consumer.

Food businesses that would have supplied the catering sector may now need to find alternative markets for products. Similarly, restaurants that have purchased food products or ingredients may need to find markets for such products they no longer require to produce restaurant food. Temporary authorization to sell such products should be provided in these circumstances with the provision for use of temporary over-labels with a derogation on nutrition labelling (unauthorized use of health claims is prohibited) and in compliance with existing date marking and storage instructions.

Competent authorities should apply some flexibility when enforcing the technical aspects of food regulations; however, food safety cannot be compromised, and key information must be provided so that consumers can make informed choices. Some flexibility on labelling compliance can be considered once there is no risk to the consumer and critical information such as allergen declaration, durability (shelf life), traceability and any special storage conditions or conditions of use can be addressed or mitigated by overlabelling with this critical information. Food business operators are advised to discuss the situation with their inspector before placing products or ingredients with temporary non-compliant labels on the market.


Food laboratories: testing and analysis

A particular challenge for competent authorities is the reduced capacity in public sector laboratories to test foods, as these are reallocated to testing of COVID-19 clinical samples. A minimum capacity in microbiological and chemical safety needs to be maintained to support food inspections of highrisk businesses, for dealing with consumer complaints and food incidents, and for the investigation and management of outbreaks of foodborne illness. This may require the temporary authorization of private accredited food laboratories to carry out testing as part of the national food safety control programme. However, the competent authority must ensure the validity and reliability of the testing results. In addition, public health disease surveillance systems may have a reduced capacity to identify human cases of foodborne illness but it is essential that a minimum national capability is maintained.

Food laboratories will need to introduce measures to reduce the risk of transmission of SARS-CoV-2 in the laboratory environment. These measures will involve training laboratory workers to recognize symptoms of COVID-19, following physical distancing principles, frequent handwashing and sanitizing and disinfection, and coughing/sneezing etiquette. Laboratory staff should familiarize themselves with the biosafety guidance related to COVID-19 from WHO.

To achieve physical distancing, it may be necessary to reduce laboratory staff density through split-shift working and communication via intercoms when staff are working alone in a small laboratory space when it is not possible to remain more than one metre apart. Arrangements need to be in place for physical distancing during shift handovers. Working schedules should be arranged so that essential work will continue in the event of a laboratory worker becoming infected.

In may be necessary to temporarily suspend a food laboratory’s accreditation to ISO 17025 if the volume of samples for a particular test is reduced. This may result from the suspension of annual residues monitoring programmes.


Risk to the integrity of the food supply  

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