Facility managers – not just food facility managers – are being “encouraged” to take strong preventative measures to help mitigate the risks of COVID-19 for individuals within their premises. Managers are also reminded that the actions taken need to be documented. It is recognized that certain of the recommended measures made by the Center for Disease Control (CDC) and/or the Occupational Safety and Health Administration (OSHA) may not be possible in some operations. The documentation made should acknowledge this and outline the preventative measures that are in place instead.
For example, where CDC guidance for physical distancing is 6 feet, but this cannot easily be accommodated, it may be possible to:
Operators are encouraged to have plans that respond to both suspected and confirmed cases of COVID-19. They are also encouraged to consult with local public health authorities for applicable guidance as well.
Mitigation and Response
Facilities need to have documented procedures in place that describe the measures being taken to prevent or minimize the occurrence or exposure to COVID-19.
Remember, the key is to have documented procedures following the CDC guidelines, document that the procedures are followed, then document how the procedures are followed. OFW Law is happy to provide assistance in developing procedures to be sure that a facility is addressing all required parameters as to sanitation procedures as well as proper documentation.