We recently had a FSSC 22000 /PAS 220 audit in which the auditor is requiring corrective action because our policy is only to require employees to self report communicable diseases. However in PAS 220 clause 13.5 it states that "Employees shall undergo a medical examination prior to employment in food contact operations, unless documented hazard or medical assessment indicates otherwise. Additional medicals shall be carried out at intervals defined by the organization, subject to legal restrictions in the country of operation."
FDA 21CFR110.10 suggests that diseases can be monitored through supervisory observation without requiring actual medical examination.
Is there a way around requiring actual medical examinations for each employee? Doesn't it violate some kind of right to privacy law??