opposed to our standard practice of operating around the clock
with three seven-hour shifts, we would have to change to two shifts
working nine to ten hours each.
Under our old system, we employed sanitation crews continu-
ously. We also deployed them for intensive clean-ups with high
pressure cleaning equipment on operating equipment during the
down time provided by three one-hour lunch breaks and the six
15-minute relief breaks of the three shift operations. At least once a
week a longer period was dedicated to across-the-house cleansing
operations.
With the proposed change, these sanitation crews would provide
this intensive cleaning during two one-hour lunch periods and the
four 15-minute relief breaks. An additional four to six hours daily
would be used for redundant cleansing of the idle plants. The only
way we could compensate for the lost daily production hours would
be to increase our dependency on costly cold storage to lengthen
our processing season and to schedule seven-day production weeks
instead of our normal six-day weeks.
Aside from the obvious economic burden, I was appalled at the
employment consequences to the Modesto community where our
fruit canning plants are located. The elimination of our third shifts
meant the loss of 1,800 seasonal jobs in a rural community already
suffering from excessive unemployment.
Because of the heavy negatives with this two-shift alternative, I
chose to delay a final decision and sought to achieve assurances of
other than zero tolerance guidelines. When this proved impossible,
I reluctantly made the decision to move to the two-shift schedule.
We then issued a public statement to inform the Modesto
community of the reasons for our action. We believed this
announcement necessary because of the significance of cannery
employment to local residents and to avoid any implication that
this action had been forced by any past sanitation failures in our
canneries.
Nevertheless, when agency officials were contacted by the local
press, the published response was to the effect that no change was
required if our previous operations were in compliance. There we
were: hung by what amounted to a “when did you stop beating
your wife?” allegation!
Shortly after our public announcement, one of our canneries
that does not process fruit was visited by an FDA inspector. His
mission, we learned, was to determine if our labeling of a formulated
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