Children Fed Since 2018:

1,000,000

ENGLAND LOGISTICS, INC.

 

POLICY PERTAINING TO CORONAVIRUS DISEASE 2019 (COVID-19)

Updated March 12, 2020

Background

Centers for Disease Control and Prevention (“CDC”) is responding to an outbreak of respiratory disease caused by a novel (new) Coronavirus that was first detected in Wuhan City, Hubei Province, China and which has now been detected in 50 locations internationally, including cases in the United States. The virus has been named “SARS-CoV-2” and the disease it causes has been named “Coronavirus disease 2019” (abbreviated “COVID-19”).

On January 30, 2020, the International Health Regulations Emergency Committee of the World Health Organization (“WHO”) declared the outbreak a “Public Health Emergency of International Concern.” On January 31, 2020, Health and Human Services Secretary Alex M. Azar II declared a public health emergency (PHE) for the United States to aid the nation’s healthcare community in responding to COVID-19.

On March 11, 2020, WHO characterized COVID-19 as a pandemic. WHO also noted that, “more than 90% of cases are in just four countries, and two of those – China and the Republic of Korea – have significantly declining epidemics.” https://www.who.int/dg/speeches/detail/who-director-general-s-opening-remarks-at-the-media-briefing-on-covid-19—11-march-2020

 

Scope of Written Policy and Procedure.

England Logistics’ efforts to mitigate the spread of COVID-19 are centered around incorporating the CDC prevention & treatment guidelines in its employee training and education as found on the CDC website: https://www.cdc.gov/coronavirus/2019-ncov/about/prevention-treatment.html Facts sheets similar to those attached are posted at England Logistics’ offices and have been circulated to all England Logistics employees.

In addition, England Logistics also has protocols in place to manage business from an alternate location should a particular office be negatively impacted by technology and pandemic shut-down. Such Business Continuity Plans and protocols are under constant review and testing to identify, address and remedy any newly developed risks. England Logistics is confident its plans and protocols are appropriate for the situation.

England Logistics is also sensitive and responsive to the particular situations and requests of its customers, vendors and others with whom it works. To the extent practical and reasonable, England Logistics is making efforts to accommodate specific requests and is collaborating with shippers, receivers, carriers and others to address and comply with specific instructions and unique situations.

Finally, England Logistics maintains a Policy and Procedure Pertaining to Safe Transportation of Food (“England’s FSMA Policy”) in compliance with the Sanitary Food Transportation Act of 2005 and the Food Safety Modernization Act (2011) (for convenience collectively referred to herein as “FSMA”) and the Food and Drug Administration’s (FDA) published a final rule and regulations regarding the safe transportation of human and animal food to be consumed within the United States which has been codified at 21 C.F.R § 1.900–1.934. For convenience, such regulations will be referred to herein as “the FSMA Rule.” England’s FSMA Policy has been posted and maintained on England’s website at www.englandlogistics.com for several years and may additionally be provided to you upon request.

In summary, England’s FSMA Policy defines each party’s responsibilities with respect to protecting the safety of food during transportation, including: a) practices for cleaning, sanitizing (if necessary), inspecting and maintaining vehicles and transportation equipment that the carrier provides for use in the transportation of food (See § 1.908(e)(6)(i)); b) instructions pertaining to effective measures to protect food from contamination by raw foods and nonfood items in the same load; c) protecting food transported in bulk vehicles or food not completely enclosed by container from contamination or cross-contamination during the transportation operations; and/or, d) instructions to ensure that food is transported under adequate temperature controls. See, § 1.908(3).

England’s FSMA Policy provides that England Logistics will endeavor to provide the written instructions provided by the shipping customer to the carrier arranged to transport the food and will endeavor to assign the responsibilities to comply with such instructions to the carrier. The carrier, through its acceptance of the subject load, will agree to comply with such requirements and instructions. Any assignments or reassignments of transportation operations will be made to competent supervisory personnel, which for purposes of complying with the FSMA Rule and all other purposes will be conclusively deemed to include all drivers for carriers and all loaders or other dock workers for shippers or receivers. England’s FSMA Policy requires the following of carriers:

 

Carriers

By acceptance and/or agreeing to provide transportation or transportation operations for the subject load of food, the carrier arranged by England Logistics agrees to be responsible for all sanitary conditions and temperature control requirements applicable to the subject load as specified in writing by the shipping customer or shipper, including, but not limited to, the following:

  1. The carrier will ensure that the vehicle(s) and other transportation equipment meet the shipping customer’s specifications and are otherwise appropriate and maintained to prevent the food from becoming unsafe during the transportation operations. § 1.908(e)(1)
  2. Transport the food products maintaining the operating temperature specified by the shipping customer and monitoring the same in accordance with the method of demonstrating maintenance of such temperature as agreed with the shipping customer.
  3. The carrier will not remove any seal(s) placed upon the vehicle, trailer or transportation equipment, except in the immediate presence of and being accompanied by authorized representatives of the receiver in doing so.
  4. In addition, and in accordance with § 1.908(e)(6), each carrier that England Logistics arranges to transport food that is subject to the FSMA Rule will develop and implement a written procedure that:
    1. Specifies practices for cleaning, sanitizing (if necessary), inspecting and maintaining vehicles, bulk vehicles (if applicable) and transportation equipment that the carrier provides for use in transporting of food in order to prevent food from becoming unsafe from being transported with such vehicles and transportation equipment;
    2. Describes how the carrier will comply with the operating temperature requirements and the carrier will demonstrate that it has maintained appropriate operating temperature conditions consistent with those specified by the shipping customer during transportation operations pertaining to the subject food;
    3. Describe how it will comply with the provisions for using bulk vehicles or other transportation equipment in order to comply with shipper requests to identify: i) previous cargo transported in the vehicle, bulk vehicle and transportation equipment; and, 2) the most recent cleaning of the vehicle, bulk vehicle and transportation equipment.
  5. Carriers shall also provide adequate training to personnel engaged in transportation operations in order to provide an awareness of potential food safety problems that may occur during transportation of food, as well as training regarding basic sanitary transportation practices to address those potential problems and the responsibilities of carriers under the FSMA Rule. Such training must be provided upon hiring of such personnel and reasonably as needed thereafter. § 1.910(a). Carriers shall also establish and maintain records documenting such training, which include at least: a) the name of the person trained; b) the date such training occurred; and c) the type of training provided. Such records will be retained for at least twelve (12) months beyond the date the person identified in such records stops performing the duties for which he/she was trained. §§ 1.910(b) and 1.912(c).

 

England believes that it has reasonable controls in place to help prevent the spread of COVID-19 and to protect the safety of food during transportation, in general. If a party has questions regarding these written procedures, such questions should be directed to England Logistics Legal Department at 801-656-4703 or jolsen@englandlogistics.com.