Day 148 - 05 Jul 95 - Page 49


     
     1        to know that she might criticise the plant for finding out
     2        contamination at a later stage if she had alleged that
     3        contamination was being missed at an early stage because of
     4        high pressure water before inspection, which she does in
     5        her statement.  She said:  "This practice is dangerous to
     6        high pressure water as it can lead to inspectors missing
     7        pathological changes and leads to airborne contamination".
     8        I think Mr. Rampton said something like, "Oh, they were not
     9        to know that then she might say that the pathological
    10        changes or contamination may be discovered at a later
    11        stage".  Obviously, if they miss it at an early stage, it
    12        is implicit that they may discover it later on.
    13
    14        Just carrying on through the document -- sorry, that would
    15        apply to paragraph 27 on page 14.   Moving on as quickly as
    16        possible .....
    17
    18   MS. STEEL:   29 is down as an N question mark and clearly this
    19        is with reference to the sheets, HACCP sheets, that were
    20        disclosed by the Plaintiffs and it is not new.  If they
    21        wanted to make a comment about that they could have made a
    22        comment about that, and, in fact, Mr. Bennett did give
    23        evidence about the checks that were made, starting on
    24        page -- he talked about the boning room temperature checks
    25        on page 21 of day 104 at line 51, and again he talked about
    26        the temperature checks on page 24 from line 53 onwards.
    27        Again, that is something that was -- it was in Ms. Hovi's
    28        statement anyway, but she expanded upon it in the witness
    29        box in response to the documents disclosed by the
    30        Plaintiffs, which they said asserted something different to
    31        what she had said and also in response to what Mr. Bennett
    32        said when he was in the witness box.
    33
    34   MR. MORRIS:  It follows on pages 16 and 17 of the Bone statement
    35        a lot of N question marks which I will not go into.  I
    36        believe they are all matters that were related to documents
    37        disclosed before Mr. Bennett and Mr. Bennett had had the
    38        opportunity to comment on and probably did.  I cannot
    39        remember exactly now whether he did or not.
    40
    41        The point 33 on page 18, most of that is general hygiene
    42        matter.  But, as far as the specific thing about the silica
    43        ceiling on the 8th line or 7th line down, the only thing
    44        I would say about that is that the witness actually says it
    45        probably did occur, that there were problems with the
    46        ceiling.  So there is not much point in calling him just to
    47        agree with our witness.
    48
    49        Anyway, the general point is one that was adequately
    50        canvassed, certainly alluded to in her statement and 
    51        canvassed with Mr. Bennett about the through rate and 
    52        whether the chillers are over-filled, and things like that, 
    53        and whether they are touching the edges.  Obviously
    54        Mr. Rampton said something like, "Just because they are
    55        over-filled" -- she said, "Chillers were, as a rule,
    56        over-filled leading to contact contamination and preventing
    57        proper chilling of the carcasses", and then he complained
    58        that he had had no notice that she would say they were
    59        touching the walls.  Well, if something is over-filled,
    60        then that certainly must be the implication that that is a

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