Day 069 - 19 Dec 94 - Page 22


     
     1   Q.   I think they finish on page 77.
     2        A.  Yes.
     3
     4   Q.   From there, we move to Arkansas.  Can you please tell us
     5        what is the nature and effect of these documents?
     6        A.  The US Department of Agriculture and the Food
     7        Inspection Service, who is responsible for the inspection
     8        of meat products, has a computer programme called
     9        Performance Base Inspection Service.  The purpose of that
    10        programme is to facilitate the job of the inspectors.
    11        Rather than leaving an inspector to walk around the
    12        facility, they wanted to have an idea and collect some
    13        statistical information and have a statistically sound
    14        inspection service.  This is the purpose of this service,
    15        to give the inspector -- if you can see here -- a number of
    16        tasks that he is to inspect that particular day or that
    17        week.  So you can see in column number 1 a schedule of
    18        task, and you can see "condition of surfaces", for
    19        instance, on page 50, or the hand wash available, on page
    20        50.
    21
    22   Q.   On page 50?
    23        A.  That is correct.
    24
    25   Q.   Do you want to turn to page 50, because that is a Tyson
    26        plant that supplies you, so it may have more relevance,
    27        although there does not seem to be a lot of difference?
    28        A.  We will also give some freedom to the inspector if he
    29        feels that there is more area needs to be inspected.  That
    30        is the second column on the schedule inspection.  The third
    31        column will give you the number of tasks performed.  It
    32        will calculate a percentage of the tasks that were
    33        performed.  They might not necessarily add 100, because it
    34        adds -- well, it gives the question how to calculate, so it
    35        can be more than 100.  If the inspector finds minor
    36        deficiencies, as they are called, or major or critical,
    37        they will record it, and it will give you a final score.
    38
    39   Q.   We see on page 50 that there is a total of 13 minor
    40        observations?
    41        A.  Yes.
    42
    43   Q.   That is right.  Then we see there is a total of four major
    44        observations against "toilets available", "storage
    45        condition", "lighting condition outside"?
    46        A.  That is correct.
    47
    48   Q.   What would be the effect of a finding of four major -- I do
    49        not know what to call them.  Are they criticisms?
    50        A.  Deficiencies; they are called deficiencies. 
    51 
    52   Q.   What is the effect of a store ----- 
    53        A.  The effect is that if the inspector finds -- and I must
    54        tell you the degree in which they look into, so you can
    55        have an idea -- if he finds any deficiencies, if he sees
    56        condensation on the ceiling, if he sees a little piece of
    57        meat on any table or any processing equipment, that would
    58        be a deficiency.  To give you a deficiency, with all due
    59        respect to this court, this court would not pass, it would
    60        flunk this test in about 30 seconds.

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