In the days since Hurricane Harvey's impact, AIB has fielded a number of calls from facilities directly impacted by the hurricane, as well as companies whose suppliers were impacted. While circumstances vary at each affected site, these general guidelines for recovery from a major weather incident are based upon our collective experience, commonly accepted best practices, and publicly available sources of information.
+ Do we need to notify any regulatory agencies that we have been impacted by the storm?
Although it varies from state to state and county by county, it is likely that these local officials require notification. However, you are not required to report the situation to the FDA. It is likely that regulatory agencies will visit your site during cleanup activities and monitor your efforts. They may even inform you that your site is considered closed until the cleanup efforts have met their approval.
+ Do GMPs and other prerequisite programs still apply during cleanup?
During the cleanup of muck and debris, it may not be necessary to require personnel to comply with the same GMPs as they would during a production run. However, your team must decide which GMPs and prerequisite programs are non-negotiable.
+ What occupational safety considerations are there for our employees coming into this environment?
OSHA has provided excellent guidance for personal safety during and after floods. https://www.osha.gov/dts/weather/flood/index.html
+ How will we know if the water is safe to use?
As there are many variables to consider, it is advised that you contact local officials for guidance for your area.
+ What criteria should we use to determine if products (raw materials, packaging, work-in-process, finished goods) that were onsite during the event are safe?
The first step is to quarantine all materials on site. All materials should be put through a formal review and disposition process by authorized personnel. Perishable products that have not been adequately refrigerated should be discarded. Any materials (packaging, ingredients, processing aids, finished goods, work-in-progress) that have come in contact with flood waters should be discarded. Crops and commodities exposed to flood waters are not acceptable for use in animal feed.
+ How do we dispose of contaminated product?
Follow trademark disposal procedures to protect branded product, which may include certified disposal. Where possible, ensure disposal of material is documented from a traceability standpoint.
+ What method should we use to clean equipment?
Flood water cleanup should be treated the same as body fluids cleanup, with the same requirements for sanitation. In addition, equipment that was submerged in the water should be fully disassembled to effectively clean it. Standard sanitation procedures are not enough in this environment. Wet cleaning and sanitizing will be required in areas that were submerged even in facilities that typically only do dry cleaning.
+ What method should we use to clean floors and walls?
Once soil has been removed, keep in mind that these surfaces must be sanitized. Dehumidifying is the final step. Depending on the degree of saturation, this may be achieved with fans or portable dehumidifiers, or a professional heat treatment may be required.
+ What environmental testing should be completed?
We advise that a comprehensive environmental testing plan be completed prior to startup, with consideration for direct and indirect food-contact surfaces and the building structure.
+ Do we need to change our pest management program?
Conduct periodic assessments and upgrade your pest management program to meet existing needs, which will likely change throughout the recovery and re-start process. Anticipate a changing pest population within the facility as time goes on, such as presence of fungus-feeding insects.
+ How do I protect my company from receiving materials that were affected by the flood?
Your supplier approval process may need to be amended for suppliers located in affected areas. Modifications may include a site visit, additional testing, or affidavits of non-salvage materials or commodities.
+ What have we overlooked?
Exterior areas are commonly overlooked during storm cleanup. A detailed survey of the exterior should be completed with consideration given to items such as:
- equipment stored on the grounds
- silos and tanks
- bulk receiving lines
- roof tops
- air handling systems