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The restaurant industry has faced many challenges over the last year and, in response, has been forced to quickly adapt to the ever-changing landscape of the COVID-19 pandemic. As federal public health authorities have explicitly discouraged self-serve dining (CDC 2021; FDA 2020), venues that typically rely upon buffet style dining, such as hotels, cruise ships, resorts, casinos, and some restaurants, have been significantly impacted. The impact of this guidance has understandably resulted in speculation that the COVID-19 pandemic has brought an end to buffet dining, adding to the uncertainty facing the resort, travel, and leisure industry (AL 2021; RGJ 2021). As the COVID-19 vaccine rollout allows for the possibility of eventually returning to normal business operations, dining out – particularly at venues that utilize buffets – is among those social activities that needs to evolve to instill consumer confidence and ensure public health protection from COVID-19 and other communicable diseases.

Hazard analysis critical control point (HACCP) is an internationally recognized food safety management system commonly used by food managers to proactively identify, control, and monitor biological, chemical, and physical hazards related to food safety (FDA 2017; Safe Food Alliance 2021). As the COVID-19 pandemic reinforced, specific infection control practices can be implemented to reduce the risk of disease transmission (FDA 2020). To break the cycle of disease transmission, Zisook et al. (2020) argued for integrating the infection prevention hierarchy of controls framework (Fig. 1) into the Chain of Infection model (Fig. 2). For restaurants, a HACCP plan can be adjusted to incorporate specific aspects of the hierarchy of controls and chain of infection hybrid model to better reduce pathogen spread based on lessons learned surrounding SARS-CoV-2 control in public venues. Indeed, federal agencies have already developed a checklist offering guidance on how SARS-CoV-2 can affect a company’s HACCP plan (FDA 2020). In the context of buffet dining, however, HACCP planning must include specific controls that will address the unique nature of buffets, which often serve many diners over short periods of time, increasing the risk of contact to ready-to-eat food products.

In addition to common foodborne bacterial pathogens (e.g., E. coli, Salmonella, Campylobacter, Listeria), risk of exposure to viral pathogens (e.g., noroviruses, rhinoviruses, Hepatitis A) at retail food facilities have been, and will remain, a threat to buffet-style dining venues. While HACCP planning has traditionally been used to address specific food safety practices and procedures within the kitchen, it can also evolve to work with the infection control hybrid model in order to specifically prevent disease transmission outside of the kitchen at buffet-style dining venues. To do so, specific critical control points addressing concerns related to self-service by patrons, gatherings near or around food areas, and exposed or unprotected foods in dining areas should be identified. Corrective actions can then be taken, and controls continually monitored by applying the aforementioned hybrid model guided by HACCP’s  seven principles.

Cardno ChemRisk is experienced at developing and assisting with COVID-19 risk management and response plans for a variety of industries (e.g., media and television, food and beverage manufacturers, construction, and retailers). To learn more about the ways Cardno ChemRisk can support your business, please contact Tony Cappello, or visit our website.

Figure 1. The hierarchy of controls adapted for infection control (figure adapted from NIOSH 2015).

Figure 2. Applying the hierarchy of controls to the chain of infection (figure adapted from NIOSH 2015 and Zisook et al. (2020)).