Day 093 - 28 Feb 95 - Page 72
1 forgot, if they forgot to cover it with plastic, that would
2 be a major.
3
4 Q. What would be critical?
5 A. If they forget, if they see water on top of the lining
6 that they put on top, that would be a critical.
7
8 Q. Now that might be helpful. Can you do the same sort of
9 example for trained employees where Mr. Morris, in due
10 course, is going to urge me that they have failed on three
11 quarters of the test -- those were the words he used -- or
12 equipment disassembly, this is pre-operational sanitation
13 facilities and equipment, where they failed on 95 per cent,
14 Mr. Morris would suggest?
15 A. OK. Let me just clarify the beginning by clarifying
16 what the 95 per cent is. 95 per cent of the test -----
17
18 Q. They did 64 tests and on 61 of them something attracted
19 notice?
20 A. Their attention, OK. So, something, let us say, when
21 they are disassembled, they are supposed to never be in
22 contact with the floor. The equipment has to be laid on
23 stainless steel. So, if one of the sanitation people
24 happens to forget a bolt or drop it on the floor and the
25 inspector -- and he did not see it and the inspector
26 happens to be walking by, he will call it a critical and
27 say: "Clean that bolt, pick it up, clean it and put it
28 back" and that is what happens.
29
30 MR. MORRIS: So are you saying that virtually the most serious
31 thing that can happen in terms of sanitation problems
32 arising out of the disassembling equipment, is the touching
33 of parts of that disassembling equipment on the floor?
34 That is the most serious thing that could be wrong with
35 that process?
36 A. From this process, it could be.
37
38 MR. JUSTICE BELL: No, it would be one of a number of serious
39 things, no doubt, which would attract a critical mark.
40 That is what he has said.
41
42 MR. MORRIS: What would be a major?
43 A. Something, may be there is a little bit of soap left in
44 some of the parts, a screw or something, that would be a
45 major.
46
47 Q. Because it may contaminate the meat?
48 A. Yes.
49
50 Q. What will be a minor then?
51 A. If it is not too shiny, a little bit of speck of meat
52 or a little piece of dust, that would be a minor. I have
53 worked in a plant where we were producing with boxes and
54 there is a little bit of box dust that is on a piece of
55 equipment, that is a minor. You have to clean it.
56
57 MR. MORRIS: I am mindful of the time.
58
59 MR. JUSTICE BELL: What I suggest is we break off now until
60 10.30 in the morning. What I suggest is you spend just a
