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Mandatory Directive for Agricultural, Food Packing, and Food Processing Businesses

*Please confirm that your facility or worksite may open under the State Order. Where there is a difference between the local County Order and the State Order, the more restrictive order must be followed. The State also has specific guidance for certain facilities and worksites that must be followed in addition to this mandatory directive.*

Issued: July 10, 2020

Information on the State’s Order and State guidance is available at covid19.ca.gov.

The agricultural, food packing, and food processing industries provide vital services that support the nation’s food supply chain.  These industries include businesses that raise animals, crops, or crop trees both indoors and outdoors (including horticulture, crops grown within greenhouses, livestock farming, fish farms, and dairies) and that pack or process agricultural products, including meat, fish, dairy, or produce.  Because agricultural businesses often house and feed their workers onsite and because these industries often involve shared workplace transportation, they face unique challenges for preventing and controlling the spread of COVID-19.  In addition, many food processing and packing operations have been hotspots for COVID-19 transmission because of their work environments, including ventilation conditions and processing lines and other areas that facilitate close contact among workers.

This Directive explains how agricultural, food packing, and food processing businesses may operate.  This Directive is mandatory, and failure to follow it is a violation of the Health Officer’s Order issued on July 2, 2020 (“Order”).  You must comply with the Order and all requirements of this Directive.

The July 2 Order

The Order imposes several restrictions on all businesses and activities to ensure that the County stays as safe as possible, including but not limited to the following:

  • The Social Distancing Protocol: All businesses must fill out and submit the newest version of the Social Distancing Protocol to the County using the online form, available here. The Protocol is submitted under penalty of perjury, meaning that everything written on the form must be truthful and accurate to the best of the signer’s knowledge, and submitting false information is a crime.  The Protocol must be distributed to all workers, and it must be accessible to all officials who are enforcing the Order.  Businesses are responsible for ensuring that workers understand and are trained on Protocol requirements in a language that they understand.
  • Signage: All businesses must print (1) an updated COVID-19 PREPARED Sign and (2) a Social Distancing Protocol Visitor Information Sheet, and both must be posted prominently at all facility or worksite entrances. These are available for printing after submission of the Social Distancing Protocol online.
  • Face Coverings: Everyone at a business facility or worksite must wear a face covering at all times (except very young children, people for whom face coverings are medically inadvisable, or for communication by or with people who are hearing impaired). Agricultural, food processing, and food packing workers must wear face coverings (or other respiratory protection as prescribed by Cal/OSHA for certain activities, such as pesticide applications) at all times during their workday, unless a face covering would pose a job safety risk. Workers must also wear face coverings while performing deliveries, except when alone in a delivery vehicle.
  • Density Limitation: All businesses must limit the number of people who may be at the facility at the same time.  For staff members, the limit is 1 person per 250 gross square feet of indoor facility space (this means total space, including areas open only to staff like storage rooms).  For customers, the limit is 1 person per 150 square feet of indoor space open to the public.  The density requirements tell businesses how many people (staff or clients) they can let into their facility before another person leaves.  Children under 12 who are accompanying a parent or guardian do not count against the limit, but everyone age 12 and over does.  (Note: This density requirement does not apply to outdoor areas like fields or to worker housing.)

See the Order and the FAQ page for more details.

In addition to these general requirements applicable to all businesses under the Order, agricultural, food processing, and food packing businesses must comply with the following directives.

Social Distancing Measures

  1. Mandatory Measures to Ensure Social Distancing

    In addition to the requirements listed in the Social Distancing Protocol, agricultural, food processing, and food packing businesses must take the following steps to make sure that everyone at the facility or worksite can maintain at least 6 feet of social distance whenever possible: 
    1. Post signage reminding and instructing everyone at the facility or worksite to stay at least 6 feet away from everyone outside their household at all times. This 6-foot requirement applies to both indoor spaces (such as production, packing, and processing lines and greenhouses) and outdoor spaces (such as fields).
    2. Implement measures to ensure that workers remain at least six feet apart from each other whenever possible on processing/packing lines and at other workstations. Such measures may include physical partitions (such as strip curtains, Plexiglas, or other impermeable dividers or partitions) as well as visual cues, like floor markings, colored tape, or signs to indicate where workers should stand to maintain adequate social distance. 
    3. Modify the alignment of workstations, including along processing/packing lines, if feasible, so that workers are at least 6 feet apart in all directions (e.g., side-to-side and when facing one another). Ideally, modify the alignment of workstation so that workers do not face each other.
    4. Designate workers to monitor and facilitate social distancing on processing and packing floor lines and during crop harvest and field work.
    5. If necessary to ensure adequate social distancing, increase the number of shifts in a day, slow down line speeds, and space out workers. Adjust shifts and stagger workers as necessary to maintain adequate social distancing.  Consider reserving at least one shift specifically for cleaning and sanitation in processing plants.  Practice six-foot social distancing to the greatest extent possible, even if it requires that production slows down.
    6. Use visual cues (like floor markings) where lines form (such as at time clocks and break areas) to show workers where to stand to maintain at least 6 feet of social distance.
    7. Wherever possible, provide virtual meetings and training opportunities or move them outdoors. In person meetings should not occur unless necessary to ensure the safe operation of the facility.
    8. Designate drop-off locations to receive deliveries away from on-site and on-farm high traffic areas. Ensure that workers maintain at least 6 feet of social distance from delivery drivers. 
    9. Call recipients ahead of time when making deliveries and deliver to confirmed drop-off locations that eliminate physical contact with recipients.
    10. Train workers to avoid shaking hands, hugging, or using similar greetings with each other and with delivery drivers and others that visit the facility or worksite.
    11. Stagger staff break schedules, in compliance with wage and hour regulations, to limit the number of workers in a break room or cafeteria at the same time or taking breaks together.
    12. Reconfigure, restrict, or close break rooms and other common areas to maintain social distancing. Breakrooms pose risk due to staff removing their face coverings when eating or drinking and also are often in smaller, enclosed spaces.  Where possible, create outdoor break areas with shade covers in accordance with Cal/OSHA requirements.
  1. Strongly Recommended Measures to Ensure Social Distancing

    The following additional social distancing measures are strongly recommended by the Health Officer but not strictly required:
    1. Consider cohorting (grouping together) workers by making sure that workers are always assigned to the same shifts with the same coworkers. Cohorting may reduce workplace transmission by minimizing the number of different individuals who come into close contact with each other over the course of a week and may reduce the number of workers who need to quarantine if a positive case occurs in the workplace.
    2. Designate one-way pathways in narrow passageways (like hallways or field rows) to avoid workers coming into close contact.
    3. Modify or stagger start and end times and alternate locker locations to increase social distancing inside locker rooms and at the time clock.

Worker Transportation Measures

  1. Mandatory Measures for Employer-Provided Transportation

    Employers that provide transportation for workers must take the following measures:
    1. Limit the number of people in the vehicle as much as possible to maintain social distance. Additional vehicles or multiple trips may be required to transport all workers to and from facilities or worksites.
    2. To the extent possible, transport workers in vehicles that have enough room for everyone inside to sit at least 6 feet away from everyone outside their household.
    3. Require drivers and passengers to wear face coverings at all times when inside the vehicle.
    4. Instruct passengers to social distance as much as possible from members of other households while inside the vehicle.
    5. Clean and disinfect commonly touched surfaces after each trip (such as door handles, handrails, seat belts, and seat belt buckles).
    6. Keep the vehicle windows open whenever possible and set the heater/AC on fresh air as opposed to recirculate.
    7. Provide hand sanitizer for drivers and passengers to use when entering the vehicle and as needed while in the vehicle.
  1. Measures to Reduce Risks Associated with Worker Carpools

    Employers must encourage workers to avoid self-arranged carpools to and from work with people who are not from their household.  Instruct workers that if they do need to carpool with people outside their household, they should:
    1. Limit the number of people in the vehicle as much as possible to maintain social distance.
    2. Maintain social distance as much as possible from members of other households while in the vehicle.
    3. Use face coverings at all times while in a vehicle with others who are not from the same household.
    4. Clean and disinfect commonly touched surfaces after each carpool (such as door handles, seat belts, and seat belt buckles).
    5. Keep vehicle windows open whenever possible and set the heater/AC on fresh air as opposed to recirculate

Sanitization and Hygiene Measures

Agricultural, food processing, and food packing businesses must implement the following sanitization measures to minimize the risk of transmission inside the facility or at the worksite:

  1. Regular Facility and Worksite Cleaning

    Perform regular facility and worksite cleaning following CDC guidelines, including:
    1. Regularly disinfect all high-touch areas and surfaces (such as doorknobs, handles, rails, light switches, sanitizing stations, restrooms, sinks, toilets, time clocks, and locker rooms).
    2. Perform regular and thorough cleaning in high-traffic areas (such as break rooms and changing areas).
    3. Clean and sanitize all tools, equipment, shared protective equipment (like hard hats), and controls between shifts or between users, whichever is more frequent.
    4. If necessary, modify operating hours to ensure that regular and thorough sanitization of the facility or worksite can be accomplished.
    5. The disinfectants used to comply with this section of the Directive must be effective against COVID-19. The CDC has provided a list of effective disinfectants here.
  1. Handwashing

    In addition to making hand sanitizer available to workers throughout the facility or worksite (as required by the Social Distancing Protocol), post signage requiring workers to use hand sanitizer or wash their hands (with soap and water, for at least 20 seconds) regularly.  Workers’ hands should be washed:
    1. When arriving at work and before leaving work
    2. After using the restroom
    3. After coughing, sneezing, using a tissue, or smoking
    4. Before, during, and after preparing food
    5. Before and after eating food
    6. Before putting on disposable gloves
    7. After close contact with others
    8. After touching shared surfaces or tools
    9. Before and after wearing masks or gloves
    10. After touching an animal, animal feed, or animal waste
    11. After touching garbage
    12. After engaging in other activities that may contaminate the hands
  1. Washing and Toilet Facilities

    Provide washing and toilet facilities that have an adequate supply of cleansing agents, water, and single-use towels or hand dryers.  Install no-touch sinks, soap dispensers, sanitizer dispensers, and paper towel dispensers whenever possible.
  1. Ensure Adequate Time For Workers to Clean

    Provide adequate time for workers to implement cleaning practices during their shifts.  Cleaning assignments should be assigned during working hours as part of workers’ job duties.
  1. Additional Measures
    1. Consider installing portable, high-efficiency air cleaners, upgrading the building’s air filters to the highest possible efficiency, opening screened doors and windows, and making other modifications to increase outside air exchange and ventilation.
    2. If fans are used in the facility, ensure that the fans blow clean air at the workers’ breathing zone.
    3. Clean delivery vehicles and delivery equipment before and after delivery routes and carry sanitation materials during delivery.

Employee Housing Facilities

  1. Mandatory Minimum Standards
    1. Employer-provided agricultural worker housing facilities must meet the following minimum standards:
    2. Provide dedicated and segregated sleeping quarters, kitchens, and restrooms for farmworkers with confirmed or suspected COVID-19 to isolate and recuperate without infecting others.
    3. Worker housing facilities must meet State housing code requirements to prevent overcrowding. Ensure that workers are able to maintain at least 6-feet social distance at all times in housing facilities, including while recreating, cooking, eating, and sleeping.
    4. Beds in shared rooms must be arranged alternately head-to-toe and spaced at least 6 feet apart. If the housing facility has bunk beds, alternate upper and lower bunk assignments, or ideally leave a completely empty bunk bed between each occupied bed.  Never allow both the upper and lower bunk of a single bed to be occupied.
    5. Promote frequent and thorough handwashing. Ensure that handwashing stations are adequately stocked with soap, water, and paper towels, and provide hand sanitizer to supplement handwashing stations.
    6. Ensure that housing units are frequently cleaned and have adequate supplies of disinfectants and sanitizers on hand at all times.
    7. Ensure that shared rooms have good air flow and ventilation. Take measures to maximize outdoor air exchange, like opening windows, where safe and feasible.
    8. Minimize shared use of showers/bathing facilities. If groups of workers use showers/bathing facilities at the same time, groups must be small enough that workers can stay at least 6 feet apart from each other at all times while showering/bathing.  Showers/bathing facilities must be thoroughly sanitized between each group of workers.
  1. Mandatory Minimum Standards for Kitchens and Shared Dining Areas

    Shared kitchens and dining areas in employer-providing housing facilities must meet the following minimum standards:
    1. Stagger food service hours to reduce crowding in kitchen and dining areas and allow staff and residents to maintain at least 6-feet social distance at all times. Thoroughly clean dining areas between each seating.
    2. Remind kitchen staff of best hygiene practices, including washing their hands often with soap and water for at least 20 seconds, and provide frequent breaks for handwashing.  
    3. Increase frequency of cleaning and sanitizing all hard surfaces in kitchen and dining areas, including tables, countertops, and cooking utensils utilized by kitchen staff and workers picking up their food, following CDC guidelines.
    4. Do not allow workers to serve themselves from buffets, salad bars, or other communal food and drink containers. Provide food in pre-packaged containers or assign staff to dispense food and beverages.
    5. Disallow sharing of dishes, drinking glasses, cups, and eating utensils. Non-disposable food service items must be washed with dish soap and hot water or in a dishwasher between uses.

Positive Case Requirements

  1. General Requirement

    Whenever an agricultural, food packing, or food processing business learns that a person who has tested positive for COVID-19 was at the facility or worksite within 48 hours of the date they were tested or within 48 hours of becoming symptomatic, the business must follow the instructions at www.sccsafeworkplace.org, including:
    1. Immediately implement the jobsite-specific Social Distancing Protocol’s procedures for when a person tests positive for COVID-19.
    2. Report the positive case to the County Public Health Department within four hours of the time the business learns about the positive case by following the instructions at sccsafeworkplace.org.
    3. Close off any locations where the infected worker was known to have been present within the last 48 hours, and keep these areas closed until they are cleaned and disinfected.
    4. Comply with all case investigation, contact tracing, and worker testing measures by the County.
  1. Labor Contractors Must Report Positive Cases Immediately

    All labor contractors must immediately (within 1 hour, regardless of the time of day) alert the agricultural or food packing/processing business upon learning that one of their employees has tested positive who is currently at the jobsite or was at the jobsite within 48 hours of the date they were tested or within 48 hours of becoming symptomatic.

Sick Leave Requirements

Effective April 16, 2020, California Executive Order N-51-20 requires that all employers with 500 or more workers who are engaged in the food supply chain are required to provide up to 80 hours of sick leave for full-time workers (as well as leave calculated on prior hours for those who work less than full-time).  This includes farmworkers and those in food processing and packing.  Workers can access sick leave if they are (1) subject to a quarantine or isolation order, (2) advised by a health care provider to self-quarantine or self-isolate due to concerns related to COVID-19, or (3) prohibited by their hiring entity to work because of concerns related to the transmission of COVID-19.

Employers not subject to this law are strongly encouraged to expand access to emergency sick leave for their Personnel to protect workers and their families from the spread of COVID-19.

Stay Informed

For answers to frequently asked questions about this industry and other topics, please see the FAQ page.  Please note that this Directive may be updated.  For up-to-date information on the Health Officer Order, visit the County Public Health Department’s website at www.sccgov.org/coronavirus.

Additional Resources for Agricultural, Food Processing, and
Food Packing Businesses and Workers

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Last updated: 7/11/2020 12:46 PM