Guidance to Meat Slaughter and Processing Establishments on Prevention and Response to Suspect and Confirmed COVID-19 Plant Employees

Guidance to Meat Slaughter and Processing Establishments on Prevention and Response to Suspect and Confirmed COVID-19 Plant Employees 

Effective Date

This guidance takes effect on March 31, 2020.

Introduction

The Canadian Food Inspection Agency (CFIA) is dedicated to safeguarding food, animals and plants, which enhances the health and well-being of Canada's people, environment and economy.

The CFIA will continue to deliver critical services that serve to preserve the integrity of Canada's food safety system while safeguarding its animal and plant resource base.

Appropriate oversight of domestic production and imported food products is essential to meeting that objective while also supporting trade and the supply chain, including through the certification of exports.

The CFIA is committed to protecting the health and safety of its employees while maintaining that oversight, through critical inspection services.

The CFIA recognizes COVID-19 prevention and response activities at slaughter establishments to be a critical element for employee health and safety.

Establishment Requirements

In order to protect the health and safety of its employees, the CFIA expects that each establishment operator abide by the advice and guidance provided by the Public Health Agency of Canada (PHAC) as well as by local Public Health Authorities in addressing the COVID-19 outbreak.

This general public health guidance should be tailored to the specific needs and realities of individual establishments/operations, documented and thoroughly implemented.

Establishments are required to have COVID-19 prevention documentation which clearly articulates mitigation measures intended to address exposure risks. It is recognized that certain public health measures may not be possible in plant operations; documentation should recognize this and outline the mitigation measures that are place.

Establishments are also required to have documentation that outlines its response to a suspect and confirmed case of COVID-19.

Mitigation and response planning documents:

describe the measures that have been put in place to prevent or minimize the occurrence or exposure of COVID-19.
Examples include:

Procedure or Policy documents
Sanitation practices/schedules/locations
Approach taken regarding physical distancing
Self/company health assessment protocols / practices and description of screening methods in place or any supporting procedural documents
Policy for your staff to report their, or their colleagues illness and corresponding notification to CFIA of any COVID-19 finding

describe the specific response/action plans that will be implemented when there is a finding of a COVID-19 positive employee.

These documents are critical and will be expected by the CFIA to maintain CFIA oversight at slaughter establishments.

Discussions between the operator and CFIA are required in the development of mitigation and response plans to maximize opportunities for mitigation measures while maintaining the ability of both plant and CFIA personnel to continue their functions.

For example where physical distancing of two meters is the public health guidance but cannot easily be accommodated, it may be possible to adjust on-site inspection practices and frequencies, increase the distance between CFIA employees and plant staff or to adjust traffic patterns through the plant to avoid "people-congested" areas.

Additional examples of potential concerns and practical mitigation measures are included as an Annex to this document.

The CFIA will inform the operator when a CFIA employee is either a confirmed positive or suspect case to enable the operator to take appropriate steps to protect their staff and implement protocols that may be required.

Procedures for Operators

Operators are to include the following procedures in their COVID-19 response plans.

The operator shall notify the CFIA immediately upon receipt of information of:

a public health authority request for COVID-19 testing of a plant employee
a COVID-19 positive employee

Information provided should include all pertinent details such as:

The date of confirmed diagnosis (if applicable)
The date of onset of symptoms and if the employee was at the establishment
The locations at the establishment where the employee delivered their functions, were likely present (lunch room, etc.) or travelled through (specific corridors, stairways, etc.)
Any other information relevant to identifying individuals who may have had contact with the positive employee.

When receiving information of a COVID-19 positive employee or employee being tested as a suspect case the operator will:

notify local public health authorities
request their assistance in determining the risks to their other employees and to CFIA employees who also work at their establishment.

The operator will determine, as outlined in their response plan, if the duties of the employee may have resulted in close contact, as defined by PHAC, with CFIA employees. The operator will notify the CFIA of their determination.

If the local public health authority is not able to provide assistance in the determination of risks to other employees, the operator shall seek the support of appropriate expertise (for example, Occupational Health and Safety professionals or Provincial/Industry working groups) to develop and implement the appropriate remediation plans, including ensuring appropriate action to be taken with individuals potentially exposed to the COVID-19 positive employee.

CFIA will ask the operator to provide information and documents to support an appropriate assessment of the risk to CFIA employees. While CFIA will consider the protocols/procedures in place by individual establishments, plus the particularities of the positive plant employee (where on the line, what kind of work, common areas with our employees, time spent with our employee, etc.) and ideally the advice from local public health, in the interim, if CFIA can't get this advice quickly, the Agency will need to consider the other information to the best of its abilities and weigh the potential risk to our workforce with the impact on establishment operations/animal welfare.
Where local public health authorities have determined that a site investigation is required or the operator and CFIA agree that such a site investigation is necessary, the operator will request the participation of CFIA in the investigation. The purpose will be to appropriately determine the health impacts to CFIA staff. The CFIA will identify a team which may include experienced slaughter/meat processing staff, Health and Safety Committee or Representative member, and if necessary to provide technical advice the Area OSH Coordinator/Advisor as well as appropriate CFIA management.
Slaughter operators are reminded to consult with suppliers and CFIA regarding receipt of live animals should production be affected.

Outcomes:

In collaboration with CFIA management and using information already collected, local public health authorities will make decisions regarding exposure to plant and CFIA employees, their need for self-quarantine and/or referral to health services for testing.
Based on the information gathered above, some CFIA employees may be deemed to have had negligible risk and can be cleared for further work
An assessment of the operator's plans for additional mitigation measures for COVID-19 will be jointly evaluated. Results from the CFIA review of written information from the company will be used by both CFIA and local public health authorities in the determination of appropriate steps to ensure the safety of all workers.

Further Information

Enquiries concerning the content of this guidance may be directed to your local CFIA office. Questions may also be sent by email.

This document will continue to be updated as new requirements and information are identified.

Annex

Key Concern: Employees do not have the ability to maintain the physical distance recommended by PHAC in specific areas of the plant.

Mitigation: Changes to employee behavior regarding moving within the plant, communicating between employees and access control to specific areas (i.e. CFIA office). Examples of mitigation measures include:

Stopping the line (reducing the noise level) to properly communicate a critical issue and eliminate the need for "close contact communication" in loud environment (anticipated to be infrequent).
Require the operator to have an employee closer (~2m) to the inspector on viscera to enable regular communication without moving through the kill floor.
Adjust on-site inspection practices and frequencies to increase the distance between CFIA employees and plant staff coupled with adjusting travel patterns through the plant to avoid people-congested areas.
Discourage non-essential communication between employees on the kill floor due to the noise level to reduce the occurrences of close contact and to adopt alternate communication practices like phone and email for essential communication.
Further restrict access to certain areas in the plant by employees by adjusting sanitation schedules and installing an in/out box outside of the CFIA office for example for exchanging documentation.

Key Concern: That not all employees are following public health advice or establishment protocols regarding general hygiene to mitigate the risk of COVID-19 transmission away from food production areas.

Mitigation: Employees are required to immediately raise concerns to their supervisor for discussion and resolution.

Definitions
Isolation requirements

You must isolate for at least 14 days if you have:

been diagnosed with COVID-19, or are waiting for laboratory test results for COVID-19
symptoms of COVID-19, even if mild
been in contact with a suspected, probable or confirmed case of COVID-19
been advised to do so by your public health authority
returned from travel outside Canada and have symptoms of COVID-19 (mandatory)

Close contact

A close contact is defined as a person who provided care for the patient, including healthcare workers, family members or other caregivers, or who had other similar close physical contact or who lived with or otherwise had close prolonged contact with a probable or confirmed case while the case was ill.

Exposure criteria

In the 14 days before onset of illness, a person who:

traveled to an affected area  or
had close contact with a confirmed or probable case of COVID-19 or
had close contact with a person with acute respiratory illness who has been to an affected area within 14 days prior to their illness onset or
had laboratory exposure to biological material (e.g., primary clinical specimens, virus culture isolates) known to contain COVID-19

Suspect (Person under investigation)

A person with fever and/or cough who meets the exposure criteria and for whom a laboratory test for COVID-19 has been or is expected to be requested.

Note: The surveillance mechanisms and systems for identifying a PUI may vary by jurisdiction according to perceived risk, resources, supporting structures and other context

Probable

A person:

with fever (over 38 degrees Celsius) and/or new onset of (or exacerbation of chronic) cough 

and

who meets the COVID-19 exposure criteria 

and

in whom laboratory diagnosis of COVID-19 is °inconclusive,

°negative (if specimen quality or timing is suspect), or

°positive but not confirmed by the National Microbiology Laboratory (NML) or a provincial public health laboratory by nucleic acid amplification tests (NAAT).

Confirmed

A person with laboratory confirmation of infection with the virus that causes COVID-19 is performed at a reference laboratory (NML or a provincial public health laboratory), and consists of positive nucleic acid amplification tests (NAAT) on at least two specific genome targets or a single positive target with nucleic acid sequencing.

Positive laboratory tests at a non-reference laboratory require additional testing at a reference laboratory for confirmation.

Note: laboratory tests are evolving for this emerging pathogen, and laboratory testing recommendations will change accordingly as new assays are developed and validated.

All definitions above from PHAC.

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