Mr. Philip Carroll:

I did not respond to the other two points Deputy Cairns made so I will respond to those now. In terms of the Covid-19 outbreak we have had a task force, the national outbreak control team, NOCT, with experts, virologists, epidemiologists and people who understand how clusters form and how one can mitigate those. We have engaged thoroughly, although not directly with the NOCT. At every single factory site where we have had significant clusters management has been deep in discussion and co-operation with the NOCT. That is what needs to be done, it is the right direction in which to go and we are happy with that. As far as a task force is concerned, I do not see the merit, but if that emerges from the committee's deliberations, we will look at that closely.

As far as responsibility for outbreaks is concerned, I have tried to indicate on a number of occasions, and we have put it clearly in our submission and in my opening statement, that we made clear right from the beginning - in fact, a number of weeks before the lockdown commenced and before the first positive Covid-19 case had taken place in Ireland - that we had developed a set of protocols that applied in every single establishment. There has been no perfect solution in any environment to preventing the spread of Covid-19. This came at us out of the blue, as it came at the rest of our community out of the blue. We, as a sector, would not have had the expertise to deal with that. The HSE produced its set of protocols on 15 May 2020, but two months before that we had a substantial set of protocols already in place. They were not expanded to any great degree on 15 May.

In other words, that suggests the things we had done were the proper measures to put in place.