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U.S. Department of Labor
Occupational Safety and Health Administration
71 Stevenson Street, Suite 420
San Francisco, CA 94105
Phone: (415) 975-4310
FAX: (415) 975-4319
April 8, 1999
RE: Inspections resulting from the March, 1999, food poisoning outbreak.
Dear <Name Withheld>:
OSHA initiated the subject inspections on March 24, 1999, in response to an apparent
food poisoning outbreak which occurred among garment workers who had eaten at the company
cafeteria. As a result of the inspections, we identified the need for your company to
expand its health programs as described below to minimize the risk of future outbreaks.
Example elements for these programs are provided in the attached appendix.
- Food Procurement Program to ensure food purchased for distribution to
employees is free of harmful chemical and biological contamination.
- Food Storage and Preparation Program to ensure food served to employees
is stored and processed using safe practices to minimize food contamination.
- Water Quality Program to ensure that employees are provided safe
potable water for drinking, washing, and culinary purposes.
- Medical Management Program, including the on-going analysis of
accurately recorded illness records, to assist in the recognition, evaluation, and control
of potential disease outbreaks and hazards.
During our meeting of April 6, 1999, you concurred with our general recommendations and
immediately assigned your safety and health staff to develop and implement specific
programs to achieve the above stated objectives. We acknowledge your commitment to this
effort and have decided to close out these specific inspections. However, as discussed
during the meeting, it is our intention to monitor your timely progress toward full
implementation of these programs through targeted follow-up inspections, as necessary. To
expedite this process, please provide us with copies of company policies and procedures
adopted to implement the needed programs. It is recognized that the programs may be
implemented in phases, and will otherwise be updated as self-auditing identifies ways to
improve their effectiveness.
- Employee Hazard Identification Program to ensure that employees have an
active role in reporting unsafe working conditions without fear of reprisal.
For additional information, please contact me at (670) 323-1200 in Saipan or
415-975-4300 in San Francisco.
This appendix presents example elements which may be adopted within <Name
Withheld> health programs to reduce the risk of water and food-borne diseases among company
employees. It is noted that per the OSHAct, it is the employer's responsibility to provide
a safe working environment, including the responsibility of selecting and implementing
program elements necessary to achieve that objective. This appendix is provided for
informational purposes only to assist <Name
Withheld> in the development of its health
programs, and to give examples of some of the elements OSHA and the Department of Public
Health expect to observe as they monitor the implementation of the company's programs. As
with all safety programs, full implementation requires the adoption of appropriate
policies and procedures for program training, enforcement, and periodic auditing to ensure
|Appendix: Example Elements of Needed Health Programs
Food Procurement Program to ensure food purchased for distribution to
employees is free of harmful chemical and biological contamination. Example program
elements to achieve this objective include the following:
- Procurement will be limited to food stocks which have passed inspection to meet
applicable government standards including those pertaining to quality, cleanliness, and
the absence of pesticide residues and biological contamination. In the absence of
established government testing, the company shall obtain commercial testing and/or
implement in-house testing to ensure food quality.
- Food stocks will be purchased from vendors who rigorously follow industry good practices
in both production and quality assurance techniques.
Food Storage and Preparation Program to ensure food served to
employees is stored and processed using safe practices to minimize food contamination.
Example program elements to achieve this objective include the following:
- Upon receiving, food stocks will be visually inspected to ensure quality was not
compromised during storage and shipping.
- The company will adopt recognized safe food handling and storage practices, such as
those recommended by USDA, FDA, CDC, and public health organizations, as standard
operating procedures. These organizations prescribe safe practices for a wide scope of
food operations including specifications for food storage and cooking temperatures, dish
washing temperatures and procedures, training and medical screening of food handlers, and
appropriate cleaning procedures for food preparation surfaces and hand washing.
Water Quality Program to ensure that employees are provided safe
potable water for drinking, washing, and culinary purposes. Example program elements to
achieve this objective include the following:
- Food handlers will be adequately trained, medically screened, and will otherwise comply
with applicable regulations to maintain current certification.
- Periodic testing of all water sources utilized by the company including those furnished
to the company by <Company> as well as those obtained from
company wells or other sources, to ensure compliance with standards published by the
Environmental Protection Agency (EPA) and those enforced by the Commonwealth of the
Northern Marianas Islands (CNMI), Division of Environmental Quality (DEQ). The frequency
of testing will depend on the water source and the results of previous tests. For example,
initial weekly testing can be used to establish acceptable base line concentrations of
indicator contaminants (such as total coliform and/or residual chlorine) for use in
comparing future tests. Routine sampling may then be performed at longer intervals, such
as monthly or even quarterly, as long as the results are consistent with base levels. When
an excursion above base line levels occurs, more frequent sampling is again necessary to
verify the excursion, assist in identifying its cause, and to verify the effectiveness of
measures taken to bring the levels back to base line.
- Periodic maintenance and testing of potable water systems within the facility will be
conducted to ensure water quality. This must include cooperation with DEQ in identifying
water system piping and distribution points to facilitate the design and implementation of
an effective testing program and to establish an appropriate testing schedule (see above
example regarding frequency of testing).
- Training of employees will be provided regarding the cleaning and use of personal water
containers, and ensuring adequate cleaning facilities are available and utilized.
Medical Management Program, including the on-going analysis of
accurately recorded illness records to assist in the recognition, evaluation, and control
of potential disease outbreaks and hazards. Example program elements to achieve this
objective include the following:
- Employees will be provided 24-hour access to adequate and convenient potable water.
- Employees are instructed to report all illnesses as part of the company record-keeping
- Epidemiologic analysis to establish base-line incident rates for common illnesses and
injuries (e.g., diarrhea, flu, nausea, wrist and back strains, etc.), and on-going
analysis to identify higher excursion rates which may indicate potential disease outbreaks
and hazards. The cause of the excursion rates will be investigated and mitigating controls
will be implemented as appropriate. Note: It is recognized that the existence of
excursions does not constitute an OSHA violation -- only the failure to monitor the rates
and respond appropriately when excessive rates occur.
Employee Hazard Identification Program to ensure that employees have
an active role in reporting unsafe working conditions without fear of reprisal. OSHA
recognizes the primary role of employee hazard identification programs in ensuring a safe
worksite since employees are usually the first to confront unsafe conditions. Example
program elements to achieve this objective include the following:
- Periodic medical screening (such as annual physicals, screening for communicable
disease, etc. if appropriate) commensurate with good medical management recognizing the
dependence of the foreign work population on the company for all medical care.
- Employees are trained to recognize potential hazards associated with both their work and
living areas such as fire hazards and blocked egress.
- A program should be implemented which encourages and responds to worker reports of
unsafe conditions. The auditing of this program must be able to recognize when the absence
of reports indicates a failure of the program in either identifying or reporting of