Day 095 - 02 Mar 95 - Page 38
1
2 Q. Is this basically, as you understand it, the official?
3 A. Yes, it is.
4
5 Q. Yes. I do not know whether we need to go through it in
6 that case. Would it help if you just identify some
7 particular paragraphs?
8
9 MR. JUSTICE BELL: Now that I know that it is accepted that it
10 is the appropriate document, all I suggest is -- is there
11 anything in it which you would suggest contradicts
12 something which Dr. Gomez Gonzalez has said?
13
14 MR. MORRIS: Yes. OK. Very briefly, if we just -- by the way,
15 page 8 did not come through from the fax machine. That is
16 why page 8 is missing.
17
18 MR. JUSTICE BELL: We will pick that up later.
19
20 MR. MORRIS: Yes, I did not get that. First of all, the
21 critical, major and minor categories, if you look at page 2
22 point A at the top, are classified as deficiencies, are
23 they not?
24 A. Yes.
25
26 Q. If you look in point C deviation?
27 A. Yes.
28
29 Q. A deviation under category C is something that is less than
30 a deficiency, yes, a departure from an approved system or
31 programme where no deficiency is found still can qualify as
32 a deviation?
33 A. Yes, starting with "a departure from", yes.
34
35 Q. So for something to be classified it would mean on that
36 chart we saw before, the form we saw form before, it would
37 have to be more than a deviation to be classified as a
38 deficiency; that is obvious. If you turn over the page to
39 page 3 and we look at the bottom of the page, point 2?
40 A. Page 3?
41
42 Q. Yes, page 3 at the bottom, the last paragraph, the second
43 sentence: "It should be understood that conditions may
44 sometimes exist that are less than perfect yet
45 acceptable".
46 A. Yes.
47
48 Q. So it is not about classifying anything that is not
49 perfect, is it, this system?
50 A. That is correct. There is nothing perfect in nature.
51
52 Q. Yes, but if it is imperfect it does not qualify either as a
53 deviation or as a more serious deficiency necessarily, does
54 it? You said that they were concerned only with perfection
55 and nothing is perfect?
56 A. No. You are getting it totally wrong. This document
57 is different from what we talked about. We have been
58 talking about the evidence that you provided ----
59
60 Q. Tysons?
