Business Interruption & Crisis Management – Coronavirus, Extreme Weather, Natural Disasters, Terrorist Attack, Civil Unrest, Food Security

In recent months there has been many events that would have a profound impact on food production for businesses directly and indirectly affected. The ‘Gilets Jaunes’ protests, African Swine Flu, Australian bushfire crisis, and most recently the Coronavirus outbreak.

As with any hazard that has the potential to disrupt business, logistics, supply, processing and deliveries it is recommended that food businesses have a crisis management and business interruption plan, with full details of contingency measures and key decision makers and contacts. Also that this plan is kept regularly updated. As part of this, the Food Business Operator (FBO) should be proactively aware of those particular hazards that may impact on their business and keep abreast of measures to reduce their likelihood. If the business, their employees or customers are particularly vulnerable to a hazard then their obligations to follow best practice advice and guidance will be increased according to their size and resources. For example, our recent blog on the potential for avian flu which would particularly impact poultry and egg producers.

Precautionary Measures

A crisis of any kind be it via a virus, a contamination or pollution, bacteria, chemical or even radiation may have domestic, European or global repercussions for production, customers and supply chains.

Precautionary and planning measures that should be considered for any crisis are as follows:

  • A full Hazard Analysis Critical Control Point (HACCP) plan should incorporate all major risks and seek to protect against them at vulnerable points within the supply, processing and distribution chain. This should be kept regularly updated to ensure that specific risks are reviewed and protections, as far as possible, included.
  • A company should have a detailed and up to date crisis management plan, listing key decision makers, experts and responsibilities. This should be regularly reviewed/tested and any recommendations implemented
  • The crisis management plan should be linked to a business continuity plan. Are there alternative supply locations for key ingredients? Alternative production facilities?
  • Check insurance policies and terms
  • Check contractual terms of supply and distribution agreements
  • Health and safety legislation obliges employers to provide a safe as reasonably practicable environment for staff and visitors; suitable risk assessments for employees and other persons affected by the work activities should be carried out and all reasonable precautionary measures implemented
  • Keep abreast of new developments – legal, scientific and medical that may affect your product / assist you in protecting against risks and so protecting your customers, consumers and employees and ultimately your business/brand

Novel Coronavirus outbreak

Based on the World Health Organisation's declaration that this is a public health emergency of international concern, the UK Chief Medical Officers have raised the risk to the public from low to moderate.  The current evidence from PHE is there is no immediate cause for concern in the UK; however FBOs will need to consider their own particular logistics depending on location of sites and supplies.

There may be particular commercial repercussions due to disruption in supply chains and markets whether this would require stockpiling of certain supplies versus seeking alternative customer bases or considering restricting production. It will be important to review contracts and agreements and provisions for this, as above.

Some basic additional health precautions for UK FBOs would include:

  • Monitor the situation and follow all advice given by Public Health England (PHE) (see website update here.)
  • Inform - Keep employees, contractors and suppliers/customers informed of the PHE website and updated on how to minimise risks.
  • Travel implications – keep abreast of the restrictions and travel advice via the Government’s foreign travel advice website Postpone visits scheduled to China or any visits by persons from China. Request employees intending to travel to, or have direct contact with anyone from China or a Coronavirus infected area (as updated by PHE and the Government’s foreign travel advice) inform the business. Consider what controls might be required for any employee or contractor or visitor who has travelled to or been in direct contact with anyone from Wuhan or Hubei Province (or elsewhere in China if they have symptoms) and any other Coronavirus infected area (as updated by PHE and the Government’s foreign travel advice); PHE guidance states asking them to remain at home for 14 days post contact as a precautionary measure.
  • Hygiene - Those attending facilities to be reminded (as usual) about the importance of good hygiene including regular washing of hands and the use of hand sanitiser (location and availabililty etc.)
  • Cleaning - Any enhanced winter cleaning programme, if deigned applicable.
  • Update - Keep measures updated.

Our content explained

Every piece of content we create is correct on the date it’s published but please don’t rely on it as legal advice. If you’d like to speak to us about your own legal requirements, please contact one of our expert lawyers.

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