Day 093 - 28 Feb 95 - Page 72


     
     1        forgot, if they forgot to cover it with plastic, that would
     2        be a major.
     3
     4   Q.   What would be critical?
     5        A.  If they forget, if they see water on top of the lining
     6        that they put on top, that would be a critical.
     7
     8   Q.   Now that might be helpful.  Can you do the same sort of
     9        example for trained employees where Mr. Morris, in due
    10        course, is going to urge me that they have failed on three
    11        quarters of the test -- those were the words he used -- or
    12        equipment disassembly, this is pre-operational sanitation
    13        facilities and equipment, where they failed on 95 per cent,
    14        Mr. Morris would suggest?
    15        A.  OK.  Let me just clarify the beginning by clarifying
    16        what the 95 per cent is.  95 per cent of the test -----
    17
    18   Q.   They did 64 tests and on 61 of them something attracted
    19        notice?
    20        A.  Their attention, OK.  So, something, let us say, when
    21        they are disassembled, they are supposed to never be in
    22        contact with the floor.  The equipment has to be laid on
    23        stainless steel.  So, if one of the sanitation people
    24        happens to forget a bolt or drop it on the floor and the
    25        inspector -- and he did not see it and the inspector
    26        happens to be walking by, he will call it a critical and
    27        say:  "Clean that bolt, pick it up, clean it and put it
    28        back" and that is what happens.
    29
    30   MR. MORRIS:  So are you saying that virtually the most serious
    31        thing that can happen in terms of sanitation problems
    32        arising out of the disassembling equipment, is the touching
    33        of parts of that disassembling equipment on the floor?
    34        That is the most serious thing that could be wrong with
    35        that process?
    36        A.  From this process, it could be.
    37
    38   MR. JUSTICE BELL:  No, it would be one of a number of serious
    39        things, no doubt, which would attract a critical mark.
    40        That is what he has said.
    41
    42   MR. MORRIS:  What would be a major?
    43        A.  Something, may be there is a little bit of soap left in
    44        some of the parts, a screw or something, that would be a
    45        major.
    46
    47   Q.   Because it may contaminate the meat?
    48        A.  Yes.
    49
    50   Q.   What will be a minor then? 
    51        A.  If it is not too shiny, a little bit of speck of meat 
    52        or a little piece of dust, that would be a minor.  I have 
    53        worked in a plant where we were producing with boxes and
    54        there is a little bit of box dust that is on a piece of
    55        equipment, that is a minor.  You have to clean it.
    56
    57   MR. MORRIS:  I am mindful of the time.
    58
    59   MR. JUSTICE BELL:  What I suggest is we break off now until
    60        10.30 in the morning.  What I suggest is you spend just a

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