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.

All NOAA SIP inspection and audit personnel will adhere to the following procedures upon entry:

• NOAA SIP personnel will operate consistently with NOAA’s reintegration plan, which includes location-specific mitigation measures based on CDC’s COVID-19 Community Levels in a given area, when performing onsite activities.  Current mitigation measures indicate masks are optional in areas of Low and Medium Community Levels and required in areas of High Community Levels. 
• Some firms may have additional PPE or masking policies that apply in their own facilities.  Firms may require NOAA SIP personnel to follow other reasonable PPE and masking policies and any other COVID-mitigation measures when accessing their facilities as long as they do not interfere with the ability to perform an inspection or audit.  Firms are expected to provide the necessary masks, gowns, face shields or other PPE required by the firm. 
• If required by the firm, NOAA SIP personnel will submit to temperature check and verbal health screening upon entry prior to accessing the production floor. 

• NOAA SIP personnel will report directly to the designated work area and limit unnecessary interactions with firm personnel. 

• Upon work completion, NOAA SIP personnel will notify firm staff 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/or 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 consistent with any COVID-19 mitigation measures.

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 entry into the facility.  NOAA SIP employees will only respond to questions verbally and will not sign any attestations or submit any written questionnaires.  Industry may verbally ask SIP employees about the following:

The industry has the authority to determine whether to permit or deny entry into its facility based on the NOAA SIP employee answers to any of the above questions. Vaccination status should not be used as a basis to deny entry to the facility but may be used to determine what safety protocols must be adhered to on-site, including face masks and other PPE and physical distancing. The denial of entry could affect a firm’s abilities to receive audits, inspections, certification, or approvals under SIP.  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, including vaccination status.

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 all applicable CDC guidelines 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.