Managing COVID-19 risks: Meat and poultry processing

Restrictions apply across Victoria

Depending on your industry your workplace may:

• be subject to restricted operations or industry specific obligations
• be subject to COVID-19 vaccination requirements

It is mandatory for every Victorian business with on-site operations to have a COVIDSafe Plan. COVIDSafe plans should be reviewed and updated regularly.

COVID-19 restrictions in Victoria may be updated at any time. You must stay up to date with changes for your industry.

How are my occupational health and safety (OHS) obligations impacted by the restrictions?

There is no change to your obligations under the Occupational Health and Safety Act 2004 (OHS Act) and Occupational Health and Safety Regulations 2017 (OHS Regulations) as a result of the Pandemic Orders issued by the Victorian Minister for Health.

Preparation of a COVIDSafe Plan forms part of the development of a safe system of work. However, having a COVIDSafe Plan and complying with the Victorian Pandemic Orders does not necessarily mean you have complied with all of your duties under the OHS Act and OHS Regulations.

You must follow any Pandemic Orders that apply to how your business must operate, and ensure that you are meeting your obligations under the OHS Act. Employees must also comply with their duties under the OHS Act.

Transmission of COVID-19

Researchers are still learning about COVID-19, its long-term effects and emerging variants.

COVID-19 is a respiratory disease caused by a coronavirus (SARS-CoV-2) that can result in mild to very severe illness and death.

The main way COVID-19 spreads is when a person with COVID-19 exhales droplets and/or aerosol particles containing the virus. This can happen when they breathe out, cough, sneeze, speak, shout or sing.

Exhaled droplets range in size. Large droplets settle out of the air faster than they evaporate. Small droplets remain suspended in the air for longer periods. Very fine droplets may contain the virus, and can stay suspended in the air for anywhere from minutes to hours. Small droplets and particles are often referred to as 'aerosols'.

Transmission of COVID-19 can occur in a number of ways, and possibly in combination.

1. Airborne transmission

This occurs when a person inhales aerosols that may contain viral particles that are infectious.

While the risk of transmission is highest when close to an infectious person, air currents can disperse small droplets and particles over long distances. These may be inhaled by people who have not had face-to-face contact or been in the same space with the infectious person. Airborne transmission is more likely to occur in indoor or enclosed settings that are poorly ventilated, crowded, or both. In these kinds of settings, the virus may remain suspended in the air for longer and increase the risk of spread as people tend to spend longer periods in indoor settings.

2. Droplet transmission

Transmission occurs where exhaled droplets from a person with COVID-19 come into contact with another person's mucosal surfaces (nose, mouth or eyes). The risk of transmission is highest when close to the source, where the concentration of these droplets is greatest.

3. Contaminated surfaces transmission

People may also become infected by touching surfaces that have been contaminated by the virus, and then touching their eyes, nose or mouth without cleaning their hands.

COVID-19 and the meat and poultry processing industry

Employees in the meat and poultry processing industry are not exposed to COVID-19 through the meat products they handle, however there is the potential for an increased risk of exposure to COVID-19 due to tasks that normally require close interaction between employees such as processing lines and the rapid nature of the work.

Under the Occupational Health and Safety Act 2004 (OHS Act) employers have a duty to provide and maintain, so far as is reasonably practicable, a working environment that is safe and without risks to the health of employees. This includes preventing risks to health (including psychological health) and safety associated with potential exposure to COVID-19.

Employees have a duty to take reasonable care of their own and others health and safety in the workplace, and cooperate with their employers about any action they take to comply with the OHS Act or Regulations.

Identifying risks

Employers must identify hazards and assess the level of risk to the health of employees from exposure to COVID-19 at their workplace. This must be done in consultation with health and safety representatives (HSRs), if any, and employees, so far as is reasonably practicable.

Each group of employees in the workplace should be considered, from delivery of raw product to final product. This may include such areas as kill floor, plucking, boning, manufacturing, packaging, storage, warehouse, forklift movement, cleaning, maintenance, and cafeteria staff.

Some of the main factors that could contribute to meat and poultry employees contracting COVID-19 are:

Controlling the risks of exposure to COVID-19

Where a risk to health is identified at a workplace, employers must, so far as is reasonably practicable, eliminate the risk. Where it is not possible to eliminate the risk, it must be reduced, so far as is reasonably practicable.

Employers also have a duty to consult with employees and HSRs (if any), so far as is reasonably practicable, on matters related to health or safety that directly affect, or are likely to directly affect them. This includes consultation on decisions about how to control risks associated with COVID-19.

Every workplace will need to develop a unique plan to minimise the risk by introducing different control measures. The types of control measures required depends on the level of risk as well as the availability and suitability of controls for each workplace, including individual work areas.

Consult with employees

Employers have a duty to consult with employees, independent contractors and any health and safety representatives (HSRs), so far as is reasonably practicable, on matters related to health or safety that directly affect, or are likely to directly affect them. This includes consultation on identifying hazards or risks and decisions about how to control risks associated with COVID-19.

The consultation should be conducted in accordance with any agreed consultation procedures.

Screening

Employers should implement an employee screening process to minimise the introduction of COVID-19 into the workplace. The process could include:

• Asking employees before they enter the workplace if they are currently subject to any Pandemic Order requirements (such as needing to isolate or quarantine), and instructing employees who have been in contact with confirmed or probable cases of COVID-19 to follow Department of Health (DH) procedures.

• Conducting temperature checks with touch-free thermometers. It should be noted that such tests will not tell whether a person has COVID-19. A person may have a temperature for other reasons or be on medication that reduces their temperature or may be asymptomatic. If used, temperature checks should only be used as a guide along with other tools to assist in making decisions.

Equipment for conducting temperature checks needs to be clean and reliable, and protocols should be in place in the event of elevated temperatures.

Policies and procedures for screening employees should be developed in consultation with employees, HSRs and occupational medical professionals.

Ensure employees know what to do

An employer's duty to eliminate or reduce risks associated with exposure to COVID-19 so far as is reasonably practicable includes ensuring that:

• confirmed COVID-19 cases do not attend the workplace
• employees know what to do or who to notify if they feel unwell or suspect they've been infected, according to the information provided by DH
• employees who have been in contact with confirmed or probable cases of COVID-19 are instructed to follow DH procedures
• any unwell employee does not attend the workplace, including those who have been tested for COVID-19 and are awaiting their test result

The symptoms of COVID-19 are: fever, chills or sweats, cough, sore throat, shortness of breath, runny nose and loss or change in sense of smell or taste.

Some people may also experience headache, muscle soreness, stuffy nose, nausea, vomiting and diarrhoea.

If an employee develops any COVID-19 symptoms, however mild, they should:

• self-isolate immediately, get tested and if needed, seek advice from their doctor or the Victorian Coronavirus Hotline on 1800 675 398.
• tell their employer as soon as possible, follow the procedures their workplace has in place to deal with symptomatic people, and update their employer if their situation changes, for example: if they receive a positive COVID-19 diagnosis

In the event of a suspected or confirmed COVID-19 case or cases at the workplace, Pandemic Orders issued by the Victorian Minister for Health may also require employers to take specific response actions.

Physical distancing

One of the ways COVID-19 spreads is by people coughing or sneezing, causing droplets to transmit from one person to another. That is why one of the best ways to protect others is to practise physical distancing.

Physical distancing means maintaining a distance of at least 1.5m between people wherever possible. Every attempt needs to be made to ensure at least a 1.5m distance between employees is achieved and maintained.

Under Pandemic Orders made by the Victorian Minister for Health, workplaces may also be required to comply with particular density quotient rules for shared spaces.

Physical distancing should be practised and encouraged in meat and poultry processing workplaces. This includes the factory floor, entry and exit points, amenities (toilets and change rooms), dining and smoking areas, and at meetings.

Ways that employers and employees can encourage physical distancing include:

• Configure communal work areas so that employees are spaced at least 1.5m apart, if possible. Changes in production practices may be necessary in order to maintain appropriate distances between employees.
• Use floor markings to provide minimum physical distancing guides between workstations.
• Modify the alignment of workstations so that employees do not face one another.
• Where 1.5m distancing between employees is not possible, install screens or plastic strip curtains where practicable to minimise the risk of droplet transmission from one employee to another. Screens need to be high enough to prevent potential droplets from coughing or sneezing directly reaching other employees.
• Ensure each employee has their own equipment/tools.
• Where allocated smoke areas exist, ensure smokers are at least 1.5m apart. This could be achieved by creating markings on the ground and, if necessary, extending the allocated smoking area.
• Minimise the build-up of employees waiting to enter and exit the workplace and various parts of the workplace by:
  • allocating different doors for entry and exit throughout the workplace where possible
  • using an entry and exit system to the site that is as contactless as possible and quick to enter and exit
  • using floor markings to provide minimum physical distancing guides at entrances and exits
• Arrange separate lunchrooms for work teams if possible. Consider moving lunchrooms outside.
• Identify additional or alternative break and lunch areas for employees such as training and conference rooms, or portables.
• Provide each employee with a permanent chair in the lunchroom. Where this is not practicable, the employer must ensure appropriate cleaning and disinfecting occurs between lunchroom access by different groups.
• Install barriers on tables and between chairs in lunchrooms.
• Limit each table to 2 people, at each end, unless greater distancing can be achieved (remove excess seats), otherwise add partitions to tables.
• Stagger arrival, departure and break times where practicable to avoid congestion.
• Consider increasing the time separation between shifts.
• Increase amenities on site (including portable toilets and wash areas) if required to maintain 1.5m distances.
• Isolate sections of bench seating to ensure 1.5m distancing.
• Increase the number of hand washing facilities.
• Increase the number of areas for changing, or allow more time for changing, and consider staggering change times where practicable.
• Slow down production in order to create additional time to reduce congestion in boot wash and change and locker rooms.
• Change taps on site to knee or foot-operated, create partitions between taps and between hoses, and use exhaust fans to reduce the high humidity.
• Create single file pathways with markings every 1.5m.
• Ensure supervisors or designated persons monitor, encourage and facilitate distancing, particularly on processing floors, and hand washing and sanitising.
• Encourage employees to avoid car-pooling.
• If one shift is normally operated, consider splitting employees over two shifts if practicable.
• Consider providing additional leave where leave is necessary due to COVID-19. This may reduce the risk of employees attending work when unwell due to financial needs.
• Consider grouping of work teams into sub-teams, to reduce the number of different people each employee works directly next to. This may minimise the spread of COVID-19 if present in the workplace, minimise the number of employees that need to quarantine if quarantine should be required, and increase the effectiveness of any changed systems of work (such as split shifts).
• Record staff positions each day for trace back purposes.
• Establish regular communication to reinforce the need to maintain physical distancing and other control measures. Any non-essential face-to-face meetings or training should be postponed or cancelled.

If physical distancing measures introduce new health and safety risks, employers must manage those risks too.

The DH and the Australian Government Department of Health have posters and other resources aimed at educating the public about COVID-19. These can be placed in client-facing work environments (for example in workplace entrances).

Physical distancing practice examples

Bad

Employees are within 1.5 metres of one another, side by side or facing workstations.

Good

Physical barriers such as partitions, separate employees from each other.

Partitions may need to be adjusted to integrate with the processing line or other manufacturing equipment.

Good

Employees are spaced at least 1.5 metres apart, not facing one another.

Other configurations may be used to achieve similar distancing between employees.

Good

Physical barriers such as partitions, separate employees from each other.

Partitions may need to be adjusted to integrate with the processing line or other manufacturing equipment, including where employees need to perform tasks in tandem across with each other.

For tasks performed in tandem, with employees across from one another, partitions can be positioned to protect employees while allowing the pass-through of materials.

Source: These images have been adapted from the United States Center for Disease Control and Prevention (CDC), Coronavirus Disease 2019 (COVID-19), Meat and Poultry Packing Industry: Interim Guidance from CDC and the Occupational Health and Safety Administration (OHSA).

Ventilation

People in indoor environments, particularly in crowded or inadequately ventilated spaces, are at a higher risk of becoming infected with COVID-19. When someone infected with COVID-19 has been present, the virus may linger in poorly ventilated spaces or areas with stagnant air for a longer period of time.

Providing an adequate supply of fresh air (ventilation) to enclosed areas of a workplace dilutes the number of airborne virus particles and lowers transmission risk. Improving ventilation alone does not reduce the risk of transmission via droplets and contaminated surfaces. It needs to be considered as part of a suite of infection control measures.

Adequate ventilation can be achieved using natural or mechanical ventilation, or a combination of the two.

• Natural ventilation is fresh air coming in through open windows, doors or air vents.
• Mechanical ventilation means a method of forced or induced ventilation using mechanical air-handling systems that bring in fresh air from outside. It forms part of a building’s heating, ventilation and air conditioning (HVAC) system.

Note: Natural ventilation is dependent on variable local conditions (eg window opening size, weather conditions including wind speed and direction) and may not always be effective in quickly removing airborne virus particles.

Better ventilation can be achieved by:

• increasing the rate that air is supplied
• increasing the supply of fresh outdoor air
• reducing or eliminating recirculated air in HVAC systems
• improving filtration for air recirculated by HVAC systems if the ventilation rate is not compromised
• regular maintenance of the HVAC system, including changing filters

Guidance on HVAC systems is available in AS1668.2:2012 The use of ventilation and air-conditioning in buildings, Part 2: Mechanical ventilation in buildings. Further information on HVAC systems and COVID-19 is available in World Health Organization (WHO) guidance Roadmap to improve and ensure good indoor ventilation in the context of COVID-19 (who.int).

In areas where it is not possible to maintain adequate ventilation and there is a high risk of transmission, portable high-efficiency particulate air (HEPA) filtered air cleaners may be appropriate to be used to reduce the concentration of airborne virus particles and other aerosol contaminants. These units are not a substitute for ventilation. Employers should assess the risk and/or undertake a ventilation assessment to identify what ventilation strategies are appropriate for the space and whether an air cleaner is needed and consider operational placement and maintenance of these units.

Employers should work with the building's owner or manager to improve ventilation where possible. Engaging a suitably qualified person such as an occupational hygienist or a ventilation engineer to advise and assist should also be considered.

For more information about ventilation, see the following documents on the DH Infection prevention control (IPC) resources page:

• COVID-19: Ventilation principles and strategies to reduce aerosol transmission in community and workplace settings.
• Department of Health IPC Ventilation Policy.
• Coronavirus (COVID-19) transmission from air-circulating, wind-blowing devices and activities.
• Ventilation strategies to reduce COVID-19 infection, when used as per DH guidelines.

Hygiene

Environmental cleaning

The amount of time the COVID-19 survives on inanimate objects and surfaces varies. Environmental cleaning is one way to remove the virus.

Follow the DH advice about cleaning - see the document 'Cleaning and disinfecting to reduce COVID-19 transmission' on the DH Business and industry coronavirus disease (COVID-19) page.

Usual cleaning regimes should be increased, including at the end of each shift. In addition:

• Ensure frequently touched surfaces are cleaned and disinfected regularly with appropriate detergent or disinfectant solutions.
• Frequently cleanse and disinfect personal items used in the workplace such as glasses and phones.
• Clean boot and wash rooms (including hoses) after each major break.
• Workplace amenities including kitchens, lunchrooms, common areas, change rooms, toilets, showers, drink fountains and vending machines should be cleaned and disinfected, and the frequency of this cleaning should increase.

Additional cleaning and hygiene controls that may be required include:

• Ensure that surfaces are cleaned if an employee spreads droplets (such as sneezing, coughing or vomiting).
• Ensure people who are conducting cleaning wear gloves and follow manufacturer’s recommendations for use of PPE. For example, employees may need protective eye wear when using some chemicals. Where possible, wash hands with soap and water after cleaning or, if washing is not possible, use alcohol-based hand sanitiser.
• Make alcohol-based hand sanitiser available throughout the workplace.
• Provide closed bins in appropriate locations for employees to hygienically dispose of waste such as used tissues as soon as possible after use.
• Provide alcohol-based hand sanitiser for employees to use after they dispose of their waste.
• Where employees’ work clothes are washed on site, appropriate procedures should be in place and reviewed to ensure effectiveness.
• Consider increasing the use of fresh (outside) air and reducing the use of recirculated air-conditioning in common areas.

For more information about cleaning, see the documents on 'Cleaning and disinfecting to reduce COVID-19 transmission' on the DH Business and industry coronavirus disease (COVID-19) page.

Employee hygiene

Ensure all employees practise good hygiene, including by:

• washing hands frequently with soap and water for at least 20 seconds, including before and after eating and going to the toilet
• covering coughs and sneezes with an elbow or a tissue
• avoiding touching the eyes, nose and mouth
• immediately disposing of tissues into a waste bin then washing hands
• using alcohol-based hand sanitisers
• cleaning and disinfecting surfaces and shared equipment after use
• limiting contact with others, including shaking hands

Employers should ensure that washroom facilities for employees have adequate facilities for good hygiene including clean running water, and an adequate supply of soap, water, single-use paper hand towels or hand drying machines, and toilet paper. These must be kept clean, properly stocked and in good working order.

Employers should also provide alcohol-based hand sanitizers containing at least 60% alcohol if soap and water are not immediately available. Hand sanitizer should be placed in multiple locations to encourage hand hygiene. If possible, choose hand sanitizer stations that are touch-free.

Employers should also consider other ways to promote personal hygiene, such as:

• building additional short breaks into staff schedules to increase the frequency that staff can wash their hands
• extending currently rostered breaks to allow employees to follow proper hygiene procedures
• providing tissues and no-touch trash receptacles (eg foot pedal-operated) for employees to use
• educating workers that cigarettes and smokeless tobacco use can lead to increased contact between potentially contaminated hands and mouths, and that avoiding these products may reduce the risk of infection
• educating workers not to share items such as drink bottles or cigarettes
• reducing the number of touch points for employees, for example by leaving access doors open where appropriate

Workers should be educated to avoid touching their faces, including their eyes, noses, and mouths, particularly until after they have thoroughly washed their hands upon completing work and/or after removing personal protective equipment (PPE).

Personal protective equipment (PPE)

Under Pandemic Orders made by the Victorian Minister for Health, employers may need to ensure employees wear specific PPE in the workplace.

In addition:

• where the work or task requires the use of specific types of PPE in the workplace, these must be provided by the employer
• training on the use and maintenance of the PPE needs to be provided, along with supervision to ensure it is appropriately used
• disposable masks should be disposed of after a break
• non-disposable masks need to be appropriately cleaned and stored when going on a break
• PPE that is reusable must be appropriately cleaned and disinfected after each use

Face masks in workplaces

Pandemic Orders made by the Victorian Minister for Health about face masks are in place across Victoria. For more information see the guidance Managing COVID-19 risks: Face masks in workplaces.

COVID-19 vaccinations in workplaces

COVID-19 vaccination is one control measure that can reduce the risk of COVID-19 in workplaces. This should be part of a suite of controls used to reduce the risk of COVID-19 in workplaces.

Deliveries, contractors and visitors attending the workplace

• Limit or decrease the number of visitors to the workplace.
• Minimise the number of employees attending to deliveries and contractors as much as possible.
• Delivery drivers and other contractors who need to attend the workplace, to provide maintenance or repair services or perform other essential activities, should be given clear instructions of requirements while they are on site.
• Ensure handwashing facilities, or if not possible, alcohol-based hand sanitiser, is readily available for employees after physically handling deliveries.
• Direct visiting delivery drivers and contractors to remain in vehicles and use contactless methods such as mobile phones to communicate with employees wherever possible.
• Direct visiting delivery drivers and contractors to use alcohol-based hand sanitiser before handling products being delivered.
• Use, and ask delivery drivers and contractors to use, electronic paperwork where possible, to minimise physical interaction. Where possible, set up alternatives to requiring signatures. For instance, see whether a confirmation email or a photo of the loaded or unloaded goods can be accepted as proof of delivery or collection (as applicable).

Communication and employee welfare

Employers must consult with employees and HSRs (if any), on matters related to health or safety that directly affect, or are likely to directly affect them, so far as is reasonably practicable. Employers should also:

• provide updated information to all employees in a format that they can readily understand (eg in their own language), and in multiple formats (eg email, posters, verbal), including employees on leave, contractors and casual workers
• ensure there are contingency plans in place for staff replacement when necessary

Legal duties

Employers have duties under the OHS Act, which include that they must, so far as is reasonably practicable:

• provide and maintain a working environment that is safe and without risks to the health of employees and independent contractors
• provide adequate facilities for the welfare of employees and independent contractors
• provide such information, instruction, training or supervision to employees and independent contractors as is necessary to enable those persons to perform their work in a way that is safe and without risks to health
• monitor the health of employees of the employer
• monitor conditions at any workplace under the employer's management and control
• provide information concerning health and safety to employees, including (where appropriate) in languages other than English
• ensure that persons other than employees of the employer are not exposed to risks to their health or safety arising from the conduct of the undertaking of the employer
• consult with employees and HSRs, if any, on matters related to health or safety that directly affect them, or are likely to directly affect them

A person with management or control of a workplace must ensure, so far as is reasonably practicable, that the workplace and the means of entering and leaving it are safe and without risks to health.

Employees also have duties under the OHS Act, which includes that they must:

• take reasonable care for their own health and safety
• take reasonable care for the health and safety of persons who may be affected by the employee's acts or omissions at a workplace
• cooperate with their employer with respect to any action taken by the employer to comply with a requirement imposed by or under the OHS Act

References

United States Centers for Disease Control and Prevention (CDC), Coronavirus Disease 2019 (COVID-19), Meat and Poultry Packing Industry: Interim Guidance from CDC and the Occupational Health and Safety Administration (OHSA).