Dietary supplement and functional food companies, by and large, have been considered in all 50 states in the U.S. to be essential businesses allowed to maintain operations in the midst of the global COVID-19 pandemic. Broad, sweeping changes in supply chain protocols have proven necessary to keep employees safe, in order to deal with the dilemma of ensuring that vital consumer packaged goods are distributed to people without those same distributors losing their lives by exposure to the novel coronavirus.
 
A patchwork of recommended safety protocols has been established by state governments, which vary region by region, and, additionally, many federal and international agencies dealing in health and safety matters pertaining to the coronavirus have issued their own advisory documents. How companies have been integrating these safety protocols varies, but recent events indicate that food manufacturers are clearly vulnerable despite lockdown orders, and guidelines in place for protecting essential employees.
 
Smithfield Foods recently closed pork plants in South Dakota, Montana, and Wisconsin which produce over 5% of U.S. pork products, following an incident in which 80 of its employees tested positive for COVID-19. With facilities producing at this scale seeing full-blown compromises due to severe outbreaks, many maintain concern over whether shortages may arise for consumers down the line.
 
While dietary supplement manufacturing facilities typically involve less “high-touch” scenarios than the processors and packers of conventional food products, those who’ve elected to continue operations have had to employ measures above and beyond standard protocol.
 
In addition to the fact that protecting people is paramount for any CPG brand in times of normalcy, that obligation extends to taking measures to protect workers from exposure to pathogens on the job site, as well.
 
Occupational Safety and Health Administration (OSHA) reports a number of workplace protection laws which may be pertinent to any incidences of COVID-19, such as the Occupational Safety Hazard Act of 1970, which requires employers to furnish each worker “employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm.” Additionally, OSHA’s Personal Protective Equipment standards require the use of gloves, eye and face protection, and respiratory infection, “when respirators are necessary to protect workers,” in accordance with the Respiratory Protection standard.
 
While OSHA has issued this warning, the agency has not issued any enforceable COVID-19-specific requirements that employers must implement to protect workers. Further, it has suspended its onsite inspections during the crisis leaving the onus entirely on manufacturers themselves to implement their own safety guidelines on a voluntary basis. In an unprecedented move, the CDC has relaxed recommendations on how to protect health care workers, and all other essential employees, through the use of equipment due to the lack of PPE supply, according to non-profit group National Employment Law Project.
 
The advisory document issued by OSHA highlights many of the new measures that ought to be employed in workplace environments which have seen some success so far, since the pandemic made its deadly advance in the U.S., and trade associations and consultants involved with the manufacturing of natural products largely echo many of OSHA’s recommendations verbatim.
 
Many companies are stressing the importance of taking into account a number of individual factors pertaining to each worker. The agency states that factors such as an employees’ non-occupational risk factors at home and in community settings, their age, history of chronic medical conditions, and more should be taken into account.
 
Essential businesses have seen success in planning ahead for increased rates of absenteeism, largely attributed not only to the virus itself, but to the fear of contracting the virus. OSHA reports that rates of absenteeism should be less severe in workplaces that offer new flexibilities and protections, and communicate about these measures effectively.
 
Many companies are actively encouraging sick employees to stay home, and ensuring that sick leave policies have increased flexibility consistent with public health guidance, as punitive policies could cause workers to show up in spite of minor symptoms to avoid punishment, or because they can’t get a doctor’s note. Additionally, allowing employees to stay home in order to take care of a sick family member is of vital importance to reduce the risk of an employee becoming infected in their homes and bringing the virus to their workplace.
 
Sweeping operational changes are underway at many manufacturing facilities to prevent the transmission of COVID-19. People are working from home wherever possible, overseeing operations virtually if it can be done that way. Additionally, certain employees are being cross-trained in order to prevent product lines from disappearing, as skeleton crews with redundancy training can keep up capacity in the short term. The ability to centralize a team that can deploy by car to multiple locations is something sought after by many contract manufacturers, as a backup.
 
Harvard Business Review recommends that any company should have an emergency operations center, with a detailed process and structure, and designed roles for functional representatives. “Most organizations today have some semblance of an emergency operations center (EOC), but in our studies we’ve observed that these EOCs tend to exist only at the corporate or business unit level. That’s not good enough,” HBR reports.  
 
Workplace controls that employees should be made aware of include education on identifying symptoms of COVID-19, engineering controls, administrative controls, and the use of personal protective equipment (so long as it is available). Additionally, there are many ways to monitor employees to spot signs that they may be exhibiting symptoms of COVID-19, some of which may be on a voluntary basis, while others, such as observing hand-washing, can be done unconditionally.
 
Many locations used for manufacturing have been equipped with high-efficiency air filters, increased ventilation, clear physical barriers to divide workers in areas where they are more prone to come in close contact with one another, and a new mapping-out of different rooms within a facility, designating who can use them and when. This is especially crucial in areas such as hallways, locker rooms, restrooms, and building entries, where people who ordinarily don’t congregate as part of their daily tasks may be at risk of transmitting the virus to one another.
 
Experts suggest companies may soon discover that under ordinary circumstances their employees were exposed to a majority of a facility’s staff prior to the adjustments, in ways that were not necessary to job function prior to a widely enforced segregation plan. Further staffing segregation has been achieved through staggered shifts, either done through reductions in hours worked by employees, or by setting up shifts similar to those seen in the nursing field. If these staggered shifts are segmented with an off-hour dividing them, that hour can be used for a thorough cleaning of an entire manufacturing facility, as recommended by leading safety officials.  
 
Leading healthcare agencies also stress the importance of dedicating an enclosed space in any facility where those suspected of exhibiting COVID-19 symptoms can be isolated until they are able to safely be removed from a workspace, either through permanent or temporarily-constructed barriers. Additionally, they stress the importance of separating the suspected cases from confirmed cases, to prevent the possibility that someone suspected of having the virus will be exposed to any positive coworkers.
 
Additionally, in many aspects, a facility’s safety protocols are only as effective as those matched by their weakest link in the supply chain. Since the threat is posed by a viral infection vulnerabilities exist by proxy in, for example, a packaging facility that receives products from a remote location with poorer safety plans. Many facilities have vetted their suppliers, agreeing to continue contracts only if adequate safety measures are being implemented at external facilities which are a part of a supply chain.