Day 295 - 06 Nov 96 - Page 18


     
     1        further batches are sent down the same line and the
     2        manufacturing equipment is not sterilised between each
     3        batch, which clearly leaves a risk because of their system,
     4        almost a guarantee, that the contamination will spread.  So
     5        that is --
     6
     7   MR. JUSTICE BELL:   Yes.
     8
     9   MR. MORRIS:   That point is also made on page 55, coming on to
    10        page 58.  If I had had time to prepare this submission
    11        fully, then I would have done it systematically.
    12
    13   MR. JUSTICE BELL:   You are doing pretty well.
    14
    15   MR. MORRIS:   At each stage.
    16
    17   MR JUSTICE BELL:    The main point is to make sure you draw my
    18        attention to the material on which you rely so I understand
    19        the way you put your case, which I do.
    20
    21   MR. MORRIS:   Right.  Going back to page 58.  Going back to the
    22        slaughter house, Jarrett's slaughter house.
    23
    24   MR JUSTICE BELL:  You see, what you said a little while ago, "We
    25        have demonstrated that the contamination in the raw
    26        material is multiplied at every stage and there is a risk,
    27        and that leaves the issue of potential undercooking in
    28        McDonald's systems."  If I inserted in that 'and there is
    29        no proper testing', that really is the heart of your case,
    30        is it not?
    31
    32   MR. MORRIS:   Up to the point of cooking, yes.
    33
    34   MR JUSTICE BELL:  Well -----
    35
    36   MR. MORRIS:   The risk is there.
    37
    38   MR. JUSTICE BELL:  You have already said that you have got
    39        potential undercooking, in what I read out.  So you have
    40        got it all there.
    41
    42   MR. MORRIS:   Basically, in a nutshell.  Yes.
    43
    44   MR. JUSTICE BELL:   That is it, is it not?
    45
    46   MR. MORRIS:   Yes, and it is because of the particular product
    47        produced in a particular sort of way that is responsible
    48        for that risk; it is not some kind of inevitable risk.
    49
    50   MR. JUSTICE BELL:  I am not putting the detail.  I just hoped I
    51        had got the skeleton.
    52
    53   MR. MORRIS:   Yes.  Dr. North explained very, very well why
    54        minced beef in particular, and chicken as well -- but
    55        minced meat, beef -- the way the whole process that
    56        McDonald's use is the most risky type of procedure at all
    57        stages.  Anyway --
    58
    59   MR. JUSTICE BELL:  Do you want to take the break there?
    60

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