Day 146 - 03 Jul 95 - Page 16


     
     1        she had it on offer.
     2
     3        Then:  "There is no separate chilled detention room for
     4        condemned or detained carcasses.  This led often to a
     5        situation where detained carcasses were kept in the same
     6        chillers with carcasses that had passed the inspection.
     7        This practice easily leads to either contact or airborne
     8        contamination".  Again, no detail in that whatsoever.
     9        Which chillers is she talking about?  Is she talking about
    10        the chillers for McKey meat or is she talking about the
    11        chillers for carcass meat?
    12
    13        Then:  "The carcasses were washed with high" -- this is No.
    14        6 -- "pressure water before the inspection".  Then she says
    15        it is dangerous.  She has had a look at the plan, that is
    16        clear enough, which plan was then available on the basis of
    17        this statement.  There is in this statement before us now
    18        no indication whatsoever that she is talking about some
    19        stage earlier in the process than the washing which takes
    20        place after the main inspection which one can see perfectly
    21        well from the plan.
    22
    23        When she gets to court, having looked at the plan, she put
    24        some kind of a carcass wash at an earlier stage of the
    25        operation.  That is something of which we should have been
    26        told because, of course, as we now see from Mr. Bone, it
    27        can be dealt with.
    28
    29        Then, finally, 7:  "The chillers were, as a rule, over
    30        filled, this leading to contact contamination and
    31        preventing proper chilling of the carcasses".  Again, there
    32        is an astounding lack of detail.
    33
    34        My Lord, all that detail, the missing detail, was filled in
    35        when she came to give evidence-in-chief.  In addition, of
    36        course, there were things that she said of which one has no
    37        indication in this statement whatsoever.
    38
    39        My Lord, can I do that this way, first of all, by looking
    40        at the statement from Mr. Bone ---
    41
    42   MR. JUSTICE BELL:  Yes.
    43
    44   MR. RAMPTON:  -- one can see that Mr. Bone has picked up a
    45        general allegation made by Ms. Hovi, perhaps by
    46        implication, from her detailed allegations.  I start on
    47        page 3, my Lord, and because I accept that the swab tests
    48        are not new, those are the two "E"s in paragraphs 3 and 4,
    49        but there is an "N" against paragraph 5.  The reason is
    50        that the overall implication of Ms. Hovi's evidence as 
    51        opposed to what we find in her written statement is that 
    52        the whole plant was, frankly, a bacteriologist's nightmare; 
    53        that nothing was properly cleaned, no walls were cleaned,
    54        surfaces were filthy.  Your Lordship will remember, for
    55        example, an allegation by Ms. Hovi, quite unnoticed in her
    56        statement, that the white vinyl cutting boards in the
    57        boning room were always dirty and could not be cleaned
    58        properly.  We had no notice of that allegation whatsoever.
    59
    60        So Mr. Bone deals with the whole range of cleaning

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