Day 111 - 30 Mar 95 - Page 46
1 to be done fairly regularly to serve a purpose at all. If
2 it is done as a random sample every now and then, it does
3 not really -- I do not know what it could be used for. If
4 it is used once a month, for example, you are in a
5 situation where you could be asked: "Well, what kind of a
6 purpose does this serve?"
7
8 It tells you about the situation on that day of the month
9 at that time, but it does not tell about the general. It
10 should not be used in that sort of a manner. When
11 I suggested that we would start using TVC monitoring at
12 Jarretts, I had in my mind the fact that during my visible
13 examination of the inspection of the plant, and knowing
14 what was going on in the plant, I suspected whether the
15 cleaning could be effected. There was not enough time for
16 it and there was no drying allowed. Obviously, I want to
17 start monitoring the situation before I condemned it.
18
19 Q. It might be helpful if you actually have the documents in
20 front of us?
21
22 MR. JUSTICE BELL: Yes. Do you want the Jarrett file?
23
24 MR. MORRIS: Yes.
25
26 THE WITNESS: There is one file here.
27
28 MR. JUSTICE BELL: It is a file which has "Jarrett" on it. It
29 is quite a thin one.
30
31 MR. MORRIS: If we go to the section starting on page 67 which
32 continues until page 86, yes?
33 A. Yes.
34
35 Q. Here we see some, effectively, monthly checks. I believe
36 the evidence from McDonald's witnesses is this is when the
37 checks were done monthly?
38
39 MR. RAMPTON: No, there is no evidence about that one way or
40 another; it is an assumption made from the documents.
41
42 MR. MORRIS: Assumption by McDonald's witnesses.
43
44 MR. RAMPTON: No, an assumption made by Mr. Morris.
45
46 MR. MORRIS: I thought Mr. Bennett assumed that.
47
48 MR. JUSTICE BELL: It is an assumption I am asked to make from
49 the fact that I have in front of me a document like this
50 coming about every month. In fact, the first one is 23
51 days after the first, and is still in March, if I remember
52 correctly, but then it is late April, late May, and so on.
53 So I will be invited in due course to infer from that there
54 are monthly checks.
55
56 MR. MORRIS: You were not aware of any swab testing?
57 A. No. I asked particularly about surface swabbing tests
58 being done.
59
60 Q. To be done?
