Charlton Smith of Local 768 opposes Intro 189 photo/video mandate
Charlton Smith, Executive Vice President of Local 768 with 24 years at DOHMH, opposes Intro 189. He argues mandatory photo or video documentation for every cited violation would create administrative burdens, privacy risks, inspector distraction, safety and confrontation risks, data storage issues, inconsistent enforcement, and over-reliance on visuals, and he urges the Council to retain the existing discretionary framework.
Good morning.
Good morning.
My name is Charlton H.L.
Smith.
I'm currently the Executive Vice President and Grievance Rep for Local 768.
I'm also, I have 24 years of service with New York City Department of Health and Mental Hygiene, Bureau of Food Safety and Community Sanitation.
Including eight years as a public health sanitarian and 16 years as an associate public health sanitarian.
As a dedicated public health professional with over two decades of field experience inspecting New York City food service establishment and in my capacity representing the frontline public health sanitarists of Local 768,
I write to express serious concerns regarding Intro 189.
While intended to increase transparency, making photographic or video documentation mandatory for every cited violation introduced severe operational safety and legal challenges.
that will undermine the efficacy of the inspection process.
The current system allows inspectors to submit photos on a case-by-case basis, such as documenting layouts during pre-operational inspection, which do not carry notices of violation.
Are capturing severe critical violations.
Examples, sewage backup structural defects, pest infestation.
To assist management in closer determination, expanding this to a mandatory blanket requirement for all violations is counterproductive.
For the following reasons.
One, significant administrative burden.
Two, privacy and confidential risk.
Three, inspector distraction and safety diminution.
Increased potential for confrontation, evidentiary and documentation complexities,
data storage and security infrastructure, inconsistent enforcement and documentation, and risk of visual over-reliance.
Conclusion.
Intro 18189 inadvertently compromises the safety, efficiency, and professional authority of New York City public health sanitation.
Sanitarians.
The existing discretionary framework strikes the correct balance.
It leverages visual data when critical public health threats...
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Threats warrant immediate managerial review without saddling the workforce with unsustainable administrative and safety risks.
Local 768 strongly urges the city council to reconsider this mandate.