Performance of On-Site Activities During the Current Pandemic

Performance of On-Site Activities During the Current Pandemic

The NOAA Seafood Inspection Program (NOAA SIP) seeks a unified effort with the seafood industry in preventing the spread of COVID-19 while continuing to produce safe, quality seafood for consumers.  NOAA SIP is closely monitoring the COVID-19 situation and is implementing applicable guidance for on-site activities during the pandemic.  We may revise the following guidance accordingly as conditions change.

First, we want you to know that our top priority is to ensure the safety of our employees and those of the users of the Seafood Inspection Program.  This continues to be an evolving situation and we continue to track developments and consider how they could potentially affect seafood inspections, particularly in the areas of audits, product inspections and certifications.

Keeping our people healthy and safe, while minimizing impacts to seafood trade, is critical for us during this time.  NOAA SIP and industry must work together as partners to ensure these goals.  We are fully committed to continuing to provide quality services to the seafood industry in the safest and most efficient way possible during these ever-changing times.

Performance of On-Site Audit Activities

Audits of approved establishments are a cornerstone of our agreements with trading partners in export certification and for ensuring confidence in the seafood market.  When we schedule audits and site visits, we take into consideration numerous factors, one of which is the risk associated with COVID-19.  To that end, we are managing audit schedules to determine when a site visit is required.

On-site activities will perform only those assessments that cannot be made virtually such as thorough documentation review.  Activities requiring on-site assessment include sanitation evaluation and observation that agreed-upon monitoring procedures are being followed.  As such, on-site assessment will be minimal.

When conducting on-site audit activity only one NOAA SIP inspector is mandated to be present. All inspection and audit personnel will adhere to the following procedures prior to entry:

1. Obtain approval and schedule the visit with plant management prior to entry of firm premises. (This means all audit activity for the time being will be announced.) Note: The firm will be expected to provide a location for the inspector to safely change into proper PPE prior to conducting on-site activities.

2. Wear full PPE including hair restraints, face shield, cloth masks that cover the nose and mouth, gloves and isolation gown.  If the firm chooses to provide these items, the inspector will use them.

3. Submit to temperature check and verbal health screening upon entry, prior to accessing the production floor.  NOAA SIP personnel will also be taking their temperatures and recording this for our records prior to starting the day’s activities.  Body temperature must be below 100 degrees F for NOAA SIP personnel to be allowed to conduct on-site activities.

Upon entry, NOAA SIP will:

• Report directly to the designated work area.  Maintain six feet social distancing at all times. Make no contact with firm personnel.  Any contact that inadvertently occurs will be documented to include duration, name and location in the firm.

• Notify firm staff upon work completion for escort off premises.

The report will be issued when the audit is complete.  An audit is not complete until, all required assessments, both on-site and virtual, are complete.

Product Inspections

Shipment and export certification will continue to be required by importing countries and buyers.  Product inspection is often required to issue the certificate.  We will continue to work on solutions that will meet certificate requirements and keep commerce moving as much as possible during the pandemic.

Product inspections may still be necessary to meet a requirement of a buyer or importing country.  In those circumstances, we will work with industry on a case-by-case basis, as requested, to meet these requirements and determine how best to proceed to maximize social distancing for your employees and ours. 

Inspectors entering a facility to perform product inspection activities will follow the entrance procedures described above.

Employee Safety

During this pandemic, industry employees may verbally ask NOAA SIP employees questions concerning COVID-19 prior to allowing entrance into the facility.  NOAA SIP employees will only respond to questions verbally and will not sign any attestations or submit any written questionnaires.  NOAA SIP permits industry to verbally ask the following:

• If the employee is experiencing symptoms of COVID-19, including shortness of breath, body aches, coughing, and fever of over 100.4 degrees.
• If someone living in the employee's household or someone the employee is caring for has been diagnosed with COVID-19, or had any recent contact with a confirmed case of COVID-19.
• In the last 14 days, if the employee, someone living in the employee's household, or someone with whom the employee has been in close or frequent contact with, or someone the employee is caring for, or returned from seeing has been diagnosed with a confirmed case of COVID-19.
• If the employee made a travel connection through a CDC Level 3 or Level 2 country or State Department Level 3 or Level 4 country, for example, China, Korea, Brazil, the European Union, or Iran.
• Industry may also measure an employee's temperature via a digital forehead thermometer before permitting entry into the facility.

The industry has the authority to determine whether to permit or deny entry into its facility should a NOAA SIP employee answer in the affirmative to any of the above questions.  The industry may retain a record of NOAA SIP employees that are both permitted or denied entrance.  However, the industry may not retain any confidential or medical information associated with any NOAA SIP employee's responses.

NOAA SIP inspectors entering facilities must also be protected from inadequate procedures relative to COVID-19.  All users of the Program must protect the on-site inspector by following CDC guidelines to maintain social distancing and must follow federal, state and local mandates or recommendations to mitigate exposure risk within their facilities.  Any firm failing to adhere to this policy will not receive the necessary services.  This could affect its ability to receive inspection or certification.

We thank you for your continued commitment to protecting the health and safety of all of our employees during this difficult time.