Day 103 - 14 Mar 95 - Page 31


     
     1
     2   MR. RAMPTON:  My Lord, I do not think it says four degrees;
     3        I think it says minus four degrees, actually.
     4
     5   THE WITNESS:  That is correct.
     6
     7   MR. MORRIS:  Is that true?
     8        A.  It says minus four degrees on there.
     9
    10   Q.   OK.  We will leave that then.  You say there are something
    11        like 30 to 40 microbiological tests a day of McDonald's
    12        chicken products, raw materials.  Do you know how many
    13        tests are done for other -- is it roughly the same for all
    14        other tests, it is about the same number of tests?
    15        A.  What other tests?
    16
    17   Q.   I do not know.  I mean, for example, the cartilage
    18        tests  ---
    19        A.  Yes.
    20
    21   Q.   -- which would be done?
    22        A.  Yes, I could not be certain of the actual numbers.
    23
    24   Q.   Is it something roughly equivalent?
    25        A.  Well, I think you get, by looking at these documents,
    26        you get a feel for the number of tests that we do in a
    27        day.  Some of them are tests, some of them are
    28        measurements, some of them are quality control checks.
    29
    30   Q.   Can we just go to the fax number at the top, page 10?  It
    31        is ESSAI OIS, No. 6?
    32        A.  Yes.
    33
    34   Q.   Can you see that?
    35        A.  Yes.
    36
    37   Q.   Do you know what this is about?
    38
    39   MR. JUSTICE BELL:  You said right at the beginning of your
    40        evidence that about one-fifth of the Sun Valley turnover
    41        was McDonald's.  Is that why 20 per cent of the tests are
    42        on McDonald's, purely and simply, it is one-fifth of the
    43        product?
    44        A.  No, it is not really because some other products would
    45        actually have more testing relatively.  For example, if we
    46        are producing cooked products which are actually ready to
    47        eat, proportionately we would do more tests on those.
    48
    49   Q.   But does the number of tests, i.e. the 20 per cent, take
    50        into account the fact that only 20 per cent of your produce 
    51        is for McDonald's anyway, or is it partly that and partly 
    52        the fact that it is not a finished product, or entirely one 
    53        or the other?
    54        A.  I mean, the actual microbiological tests on food for
    55        McDonald's are probably less in proportion because it is a
    56        raw product that we are supplying, but the number of tests
    57        around it, for example, weighing, temperature tests,
    58        measurements along the line are probably proportionately
    59        more because it is actually quite a complex process.
    60

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