Day 019 - 27 Jul 94 - Page 63


     
     1
         Q.   If people took a bit more time about loading these crates,
     2        even using the crates that are being used now, would it be
              possible to avoid those?
     3        A.  It would certainly be possible to reduce the
              prevalence of crushed skulls by taking additional time and
     4        care, yes.
 
     5   Q.   Right.  In terms of improving the design, I think you
              said, putting ----
     6        A.  You could have a bigger gap between the front of the
              drawer and the frame which holds the drawer.  If the birds
     7        tended to stick their heads out, say, during transport,
              you could have a brush there which could act as way of
     8        trying to contain them.
 
     9   Q.   Right.
              A.  Or you could have a flexible flap.
    10
         Q.   You recommended that, you suggested that, did you, to
    11        them?
              A.  I suggested it once to a manufacture.
    12
         Q.   Right.  When was that?
    13        A.  In the late 80s.
 
    14   Q.   Has anything changed?
              A.  Correction -- it would have been post this survey.
    15        I beg your pardon, I am wrong when I say late 80s.  It
              would have been in the 1990's.  It might have been about
    16        the time of the publication.  I beg your pardon.
 
    17   Q.   Has anything changed since then?
              A.  To the best of my knowledge, no.
    18
         Q.   Is this something you discussed with anybody from Sun
    19        Valley Poultry?
              A.  I cannot recall the occasion; I may have.
    20
         Q.   So you are not able to help us with what their response
    21        might have been?
              A.  If I was in their position, I could give you, you know
    22         -- am I allowed to put myself in their position?
 
    23   MR. JUSTICE BELL:  No.
              A.  I apologise.  Could you re-ask the question?
    24
         MR. JUSTICE BELL:  Do you have any clear recollection of making
    25        any recommendation in this respect to Sun Valley?
              A.  No.  I think I brought to their attention this figure, 
    26        a high figure, of crushed skulls on one occasion. 
  
    27   Q.   Then next question:  Do you know if anything was done
              about it or not?
    28        A.  I do not know.  Can I add, it is difficult for them to
              do things considering they do not manufacture the
    29        material, crates.
 
    30   MS. STEEL:   When were you asked to write a report on the
              procedures at Sun Valley for the purposes of this case?

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