Day 112 - 31 Mar 95 - Page 21


     
     1   Q.   Then I was going to ask you, what is the breach of
     2        regulation that you are asserting here, even supposing you
     3        had been right which you are not, of course?
     4        A.  Basically, I am referring to the fact that there was
     5        such resistance at me starting to do these quality control
     6        measures.  That is a breach of regulations of the OVS's
     7        authority in the plant.
     8
     9   Q.   You mean because the OVS wants you to do something that you
    10        are not compelled to do by law, it is a breach of the
    11        regulations to tell the OVS to mind their own business?
    12        A.  I did not ask them to do anything.  I asked if could I
    13        start doing -- I find, in my opinion, the OVS should act,
    14        and that is the best way of carrying out the job, as a
    15        consultant to the plant.  I strive to do my job so that
    16        I can work in the co-operation with the plant, that is why
    17        I usually inform -- I do not start taking new measures in a
    18        plant where they have not been done before without
    19        informing them and discussing it and, perhaps, doing it in
    20        co-operation with the plant, particularly since it is
    21        usually the plant that ends up picking up the bill in case
    22        we use outside services to do these.
    23
    24   Q.   Suppose I am the owner of an abattoir and I have the
    25        misfortune to be blessed with an over-officious,
    26        authoritarian, bossy OVS who tries to get me to do
    27        something, such as allowing him or her to take swab tests
    28        which it is not my legal obligation to do or have done on
    29        my behalf, what is the breach of regulation involved in my
    30        saying:  "Go away, mind your own business; do not be so
    31        bossy"?
    32        A.  It might not be directly a breach of regulation, but
    33        I see that it is a breach of their duty to -- a lot of
    34        these regulations do not refer to OVS's duties.  They refer
    35        to the management duties to run an abattoir where the risks
    36        to public health are not increased, where they are high
    37        regulations required to run an abattoir on a hygienic
    38        basis.
    39
    40        Most of the regulations, the schedules start, "the owner of
    41        the abattoir" or "the abattoir is required to do the
    42        following".  The OVS is there in a supervisory role, or
    43        I would like to see it in a consultancy role.
    44
    45   Q.   I am going to leave the third bullet point because I will
    46        have to come back to that (in view of the evidence you gave
    47        yesterday) at a future date.  Can you look at the fourth
    48        one:  "Throughout the plant there was a shortage of
    49        facilities for disinfection of hand tools and knives
    50        leading to contamination of the carcasses and meat".  Could 
    51        you please find the Jarrett plan -- I hope it is still up 
    52        there? 
    53        A.  I think it was at the beginning of this file.
    54
    55   Q.   I would like you to keep it out because I have another
    56        thing I want to ask you while we have it out.  You have
    57        written, as I said:  "Throughout the plant there was a
    58        shortage of facilities for disinfection of hand tools and
    59        knives".  Pausing there, where do you say in this plan
    60        there should have been sterilization points, is it, sorry,

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