Day 102 - 13 Mar 95 - Page 29


     
     1   Q.   You said that catchers are not skilled in terms of the
     2        amount of training that is required.  What training do you
     3        give the catchers, or do you give them any?
     4        A.  The catchers each get a specific induction training
     5        when they start the job, which involves going through those
     6        job task procedures that you have a copy of there, telling
     7        them what is involved, telling them what their duties and
     8        their responsibilities are.  So, they all do get a training
     9        period when they start.
    10
    11   Q.   That is what the training consists of?
    12        A.  Yes.
    13
    14   MR. JUSTICE BELL:  Could you just pause a moment, please?  If a
    15        lorry were to come about every 45 minutes, and let us say
    16        the average lorry and trailer has, say, 5,000 birds, even
    17        allowing for breaks, if one lorry was filled every hour,
    18        that would be 90,000 birds, which is why I ask the question
    19        because I am obviously not following the basis of the
    20        questioning or your answers unless that is so.
    21
    22   MS. STEEL:   It is 4 to 6,000 birds per lorry.
    23
    24   MR. JUSTICE BELL:  4 to 6.  I took 5 and then allowing for
    25        breaks here and there and so on, I took 18 lorries in 18
    26        hours and I came out at 90,000.
    27
    28   MS. STEEL (To the witness):  I think when you gave evidence
    29        previously you said that per day you transport about
    30        170,000 birds?
    31        A.  Yes, that would be right.
    32
    33   MR. JUSTICE BELL:  I remember that too, but how many birds are
    34        you collecting from a particular farm, for instance?
    35        A.  Well, it could -----
    36
    37   Q.   Or do they do a unit in one farm and then perhaps move
    38        three or four miles down the road to another and so on?
    39        A.  Yes, I mean, that could happen.  Again, it depends on
    40        the geography.
    41
    42   Q.   Just so I make sure that I am not completely
    43        misunderstanding, what happens during the 18 hour day?  Is
    44        this one farm with, may be, four units on it which are
    45        being cleared during that 18 hours or what?
    46        A.  Well, it could be -- it depends really so much on the
    47        size of the farm.  I mean, there are small farms that would
    48        only have 20,000 birds on the whole farm.  There are other
    49        farms where the maximum size is  -----
    50 
    51   Q.   You might clear that farm in about four hours --- 
    52        A.  Yes. 
    53
    54   Q.   -- then if the lorries are coming one after the other?
    55        A.  Yes, that is right.  The big farm could, if it has more
    56        than 200,000 birds on, form the bulk of that day's catch,
    57        in which case there would be several teams working on the
    58        farm.
    59
    60   Q.   Working for over the full 18 hours?

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