The recent experience with Hurricane Laura is a stark reminder that we must plan for continued operations or for rapid recovery in the face of potential disasters. Hurricane season lasts from June 1 to November 30 and thus there is still time for tragedy to strike and, correspondingly, for preparations to be made. Keep in mind that planning for a hurricane will also prepare you for other emergencies so even if you don’t live on the Atlantic or Gulf coasts you may be in a tornado zone or a region prone to severe winter weather. Here are five ideas to get you started.
Write an Emergency Operating Plan
For anyone new to the concept of emergency planning a good place to begin is by referencing the Conference for Food Protection’s, “Emergency Action Plan for Retail Food Establishments, 2nd ed.” As the plan’s subtitle suggests, this is a practical guide for food establishments to plan for and respond to emergency situations from the perspective of food safety and facility operations. Included among the excellent recommendations is a matrix that identifies procedures for handling refrigerated TCS food during a power outage. Also included are guidelines for water service disruption, contaminated water supply, flood & fire, and other conditions likely to be encountered in a disaster.
Just as significant as the CFP guidance is guidance provided by the Association of Food & Drug Officials (AFDO) in their publication, “AFDO Food Emergency Regulator Pocket Guide, 3rd ed.” While the former document is a guide for operators the latter document is a guide for regulators. Great care was taken to ensure alignment between the two sets of recommendations so that the things operators are being coached to do are the same things regulators are being coached to look for. Between the two documents anyone looking to build an emergency plan will have best practices at their fingertips.
Here are links to the two resources:
Emergency Action Plan
Food Emergency Pocket Guide
Confirm Vendors & Supplies.
You will not be permitted to operate unless staff and customers can access restrooms. How can that be accomplished during a water service disruption? The answer: establish a relationship now with a provider of Port-o-lets. They will be in high demand and short supply at the last minute. This kind of need is best anticipated when conditions are calm and normal, and no one is under duress. What else should you be thinking about? Extra dumpster capacity and an accelerated pick up schedule, grease trap pumping, pest control, alternate sources for water and ice, generators to run power to the facility and pre-installing any hook ups that might be necessary, logging-in a supply of disposable plates, flatware, cups, napkins and to-go supplies, etc. Speak to your suppliers about the feasibility of maintaining a robust supply chain. Make sure you have contact numbers safely stored.
Given that some items, especially those that are perishable, may not be readily available, consider how you will limit your menu. In some cases, offerings may need to be reduced due to product shortage. In other cases, offerings may need to be limited due to the availability of electric or gas service to the establishment. How would you adjust your menu if electricity were out, but gas was still on or, conversely, if the gas were out but the electricity was still on? What could you serve if you only had disposables and no access to a dish machine or three-compartment sink? Anticipate these things ahead of time and draft limited, throwaway menus accordingly.
Coordinate with the Local Regulatory Authority.
Refer to the 2017 FDA Food Code, Section 8-404.11. Paragraph C provides that a food establishment may not need to cease operations in the face of water or power disruption if they have a written emergency operating plan approved by the regulatory authority. When an emergency occurs, that plan must be swung-up and the regulatory authority informed. In this way a food establishment may be permitted to continue operations or, just as significantly, reopen after the disaster without the necessity of a pre-opening inspection. Entire communities can return to normal faster when food establishments resume operations quickly; citizens, first responders, your own staff, and the regulatory agency itself which can deploy limited resources to those establishments without approved emergency operating plans. This is also a great way to build positive relationships with your regulators as you work together to arrive at consensus on the plan. Here is a link to the FDA Food Code.
Preparing the facility for business continuity means more than ensuring your TCS food is safe when the power goes out or that you have contingencies for alternate hand washing stations. It also means the safety and well being of your staff. When your staff has piece of mind that their families are safe, they will be better able to respond to the needs of your business.
Here is a partial list of reminders to help staff prepare their homes and families: Get cash and secure important family documents, including insurance policies and bank information, in waterproof containers. Gather prescription drugs and glasses and if possible, store valuables in upper floors to guard against potential flooding.
Fill vehicles and five-gallon cans with gas and fill propane tanks if appropriate. Fill sinks, tubs and containers with potable water and get or make extra ice. Turn refrigerators to their coldest settings and do not upon unless necessary. Provide at least a 3-day supply of nonperishable food and one gallon of water per person per day (do not forget a can opener.) Check your first aid kit for completeness, have a battery powered radio with extra batteries, and a flashlight with extra batteries. Have moist towelettes, garbage bags and plastic ties for personal sanitation. Ensure a supply of infant formula and diapers if appropriate and pet food and extra water for pets. Finally, gather some books, games, and other activities for children if appropriate.
Watch for future editions of this Blog where we will take a deeper dive into some of the ideas mentioned here and consider others like a master matrix to coordinate the emergency planning efforts of the entire enterprise. We will also be sharing information about EmergiProtect®, our mobile emergency management tool that puts solutions at your fingertips. At Active Food Safety we have the expertise to help get you started or, for those who might already have nascent emergency operating plans in place, to review those plans.